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HomeMy Public PortalAbout2017-01-24 NS AJO January 11, 2017 VIA US MAIL AND EMAIL Steven Magoon Community Development & Planning, Director Town of Watertown 149 Main Street Watertown, MA 02472 Re: Responses to auestions reoardina 23 Elm Street Dear Director Magoon: In response to the questions contained in your email dated January 9, 2017, concerning NS AJO Holdings, inc.'s request for a letter of support or non-opposition from Watertown, and in anticipation of the upcoming City Council hearing scheduled for January 24, 2017, 1 have prepared the following responses: Question 1: Regarding operations, you refer to customer and employee information, however for the application process we will need this Information on a maximum number on a daily basis. How many employees at this site and when would they be there, when would there be the most at one time. Similarly for customers, when would the peak customer traffic be, etc. You have indicated 15 patients at peak, yet you don't indicate when that is or how that will grow as the total patients grow in the ensuing years. I Resoonse 1: The exact number depends on the number of dispensaries that are licensed and opened, not only in Watertown, but also In the surrounding communities, However, based our estimated number of proximate patients, as well as the growth thereof, we anticipate a peak maximum number of 250 patients per day, or hourly visits ranging from 3 to 5 patients per hour to 10 to 15 paiienis per hour. The anticipated time spent per patient range from 10 to 15 minutes for returning patlents to 30 to 45 minutes for first time patients. i I Question 2: I You have indicated there are 8 parking spaces, how will this accommodate the number of customers and employees on site? ! Prince Lobel Tye ALP One International Place Suite 3700 Boston,MA 02110 TEL:617 456 8000 FAX 617 456 8100 ` 2605643M www.princelobel.corn 0:3 PRince L OBeL Director Steven Magoon January 11, 2017 Page 2 Response 2: NS NO Holdings, Inc. has been able to secure an additional 8 to 10 parking spaces from the building owner, for a total of 16 to 18 spaces, Said additional spaces will be described in further detail in the Special Use Permit application. Employees will be brought to and from work in an employee van carpooling system or by use of public transportation. The employee vans will utilize 2 spaces, leaving the remaining spaces for patients. uestlon 3: You have indicated some significant expenditures for plans of this site, yet none are provided? Response 3: Please see Schedule A: Watertown RMD Project Costs within the Appendix of the previously submitted proposal. Question 4: You have Indicated the potential for anti-loitering devices aimed at discouraging loitering around the site, how will this address patients who are awaiting their rides? Response 4: NS AJO Holdings, Inc's waiting area is designed to be a pleasant and safe atmosphere,where patients who are waiting for transportation, or for their turn to make a purchase, will have access to comfortable couches, chairs, and reading materials. Our on-site security personnel will ensure that patients are directed to the appropriate areas, and any loitering and/or waiting outside the building will be strongly discouraged. Question 5: You need to address how you will deal with home delivery. Response 5: After careful consideration, NS NO Holdings, Inc, has decided to not pursue home delivery at this time. The Department of Public Health has established a caregiver system to provide for home bound patients in need of medical marijuana, if the city determines that there is a need for home delivery, NS NO Holdings, Inc. will work with city officials to establish a system. iQuestion 6: As part of yourhost agreement you have offered a$100,000 set aside to offset impacts, how will this be utilized and who will decide if and how it will be utilized. I zeosea�.vr Director Steven Magoon January 11, 2017 Page 3 Resconse 6: NS AJO Holdings, Inc. guarantees payment to the city of the higher of$200,000 or 6 percent of gross revenue generated annually from the Watertown dispensary. In addition, up to $100,000 is set aside annually for any verifiable expenses incurred by the city (such as police details, overtime, emergency services etc.). Should you wish to have me clarify any of these responses, or have any additional questions or comments, please do not hesitate to contact me, Best regards, lichael PIRs 617 466 8149 direct mross(@ orincelobel.com MPR/wf �I i i 2605643.v1 xs.:���s�-s zsGor.�s5czas�5.vs5si.w�r35un:�_.,..s�.ue,ara�.u:Aav:hSF.YrEi;SSJ#T'�n�iafi�Ya_%v^,C'."Y"?s?.SF1La7a�:h'x.-rerf•'�s=e�ti_�iX vi�i`Y,i�=�•:^�S�*` -+t.:tt+"JF�{ 61 PRince LoBeL. December 12,2016 Steven Magoon Community Development&Planning,Director Town of Watertown 149 Main Street Watertown,MA 02472 Dear Director Magoon: As you are aware, this office represents NS AJO holdings, Inc.,("NS AJO")in connection with the siting of a Medical Marijuana Treatment Center at 23 Clnr Street in Watertown. Please allow this letter to serve as a supplement to our previous filing. In response to your email dated December 7,2016 we respectfully submit the following: With regard to your request for a draft host agreement,enclosed please find a draft proposal from NS AJO. We are prepared to discuss this in greater detail at your earliest convenience, With regad to your question regarding the potential for recreational distribution in the future,NS AJO's response is that they are a non-profit company committed to serving registered Medical Marijuana patients within the Town orwatertown and tho surrounding community. As such,NS AJO has not yet determined whether it is within its business model and mission to enter the recreational marijuana maker. 'ro(late, the proposed statutory framework surrounding Medical Marijuana,as well as the necessity for additional regulatory framework,creates more questions than atswors for recreational sales operations in Massachusetts and precludes NS AJO front properly analyzing its potential for morentional distribution in the future. Moreover,due to complexity of developing and establishing proper regulations for a recreational marijuana program in Massachusetts, it is not likely that any recreational applications will be accepted until January of201 S. In any event,should NS AJO decide that it intends to make application for a recreational dispensary in the future in the Town of Wate town,it hereby commits to notifying the Town and working closely and diligently with the Town to determine whether a recreational marijuana dispensary is appropriate. - Moreover,we fully expect fhat any such process would require amending the Community Host Agreement, In any event,we hereby commit that in no way will the value of the Community Host Agreement be reduced or diminished in any way,more likely it will increase in the future. Please do not hesitate to contact the if you have any comments,questions,01'concerns, / regards, ichae! P, R 's d� Direct: 617-4 6-8149 Email: - - Piince Lobel Tye uP Gnefosu'es: One international Place Suite 3700 Boston,MA 02110 TEL:617 456 8000 FAX:617 456 8100 2587118.2 www,princelobel.com TOWN OF WATERTOWN AND NS AJO HOLDINGS,INC. HOST COMMUNITY AGREEMENT FOR THE SITING OF A REGISTERED MARIJUANA DISPENSARY IN THE TOWN OF WATERTOWN This Host Community Agreement("Agreement") is entered into pursuant to M.G.L. 44, §53A this day of December,2016 by and between NS AJO Holdings, Inc. a Massachusetts not- for-profit corporation with a principal office address of 67 Dana Sheet,III, Cambridge,MA 02138 (the"Operator") and the Town of Watertown,a Massachusetts municipal corporation with a principal address of 149 Main Street, Watertown,MA 02472(the`"Town"). WHEREAS,Massachusetts voters approved the legal cultivation,processing, distribution, sale and use of marijuana for medical purposes through Chapter 369 of the Acts of 2012,An Act for Humanitarian Medical Use of Marijuana;and WHEREAS,Massachusetts, acting through the Commonwealth of Massachusetts Department of Public Health(the"DPH") implemented regulatory framework for the regulation of the use of marijuana for medical purposes through 105 CMR 725,000 et. seq. (the"Regulations"); and WHEREAS,Operator wishes to locate and operate a Medical Marijuana Treatment Center at 23 Elm Sheet, Watertown, MA 02472 in accordance with the Regulations (the"Facility"); and WHEREAS,A Medical Marijuana Treatment Center is defined by the DPH as a not-for-profit entity registered under 105 CMR 725.100,to be known as a registered marijuana dispensary(an "RMD"),that acquires,cultivates, possesses, processes(including development of related products such as edible MIPs,tinctures,aerosols,oils,or ointments), transfers, transports,sells, distributes,dispenses, or administers marijuana,products containing marijuana, related supplies, or educational materials to registered qualifying patients or their personal caregivers. Unless otherwise specified, RMD refers to the site(s)of dispensing,cultivatioin, and preparation of marijuana; and WHEREAS,Operator will serve its non-profit purpose of providing marijuana for medical use, educational materials,and related products, to medical use of marijuana patients in Town and throughout the Commonwealth of Massachusetts; WHEREAS,The Town enacted Ordinance 459 (0-59-2014),an ordinance amending the Town's Zoning Ordinance regarding Medical Marijuana Treatment Centers and related uses for patients with a debilitating medical condition to allow a Medical Marijuana Treatment Center by Special Permit in the I-1, I-2, 1-3 and RMUD Zoning Districts, HOST COMMUNITY AGREEMENT I—TOWN OF WATERTOWN,MA l ge WHEREAS,The Facility is located in the RMUD Zoning District and as such is permitted by Special Permit; WHEREAS,The Facility complies with the buffer requirements set forth in 105 CMR 725.110(A)(14);and WHEREAS,Operator intends to provide certain benefits to the Town in the event that it obtains a Certificate of Registration to operate an RMD in'rown and has received all required local approvals. WHEREAS, notwithstanding the anticipated benefits to certain members of the community, the facility may impact town resources in ways unique to the business of the facility and draw upon town resources in a manner not shared by the general population; NOW,THEREFORE, in consideration of the above, the Operator and the Town agree as follows: 1. Community hnnact Fee: the parties anticipate that the Town could incur extended expenses and draws upon the town's road system, law enforcement, fire protection services, inspectional services and permitting services,public health services and potential additional unforeseen impacts upon the Town.Accordingly, in order to mitigate the financial impact upon the Town and use of Town resources,the Operator will pay to the Town a community impact fee(the"Community Impact Fee") in the amounts and payable at such times as described in Section 2 hereof; 2. Payments: Subject to adjustment or modification as set forth in the fourth paragraph of this section,Operator shall pay to the Town the greater ofeither(a) an annual total of Two Hundred Thousand Dollars and 00/100 ($200,000.00) in the aggregate, annually, or (b)6%of the Gross Sales generated annually at the Facility. For the purposes hereof, "Gross Sales"shall mean the total ofall sales of Medical Marijuana or products containing Medical Marijaana,transactions conducted at the Facility, less any sales taxes collected. In either case, beginning on the first day of the thirteenth month following the date of commencement of sales in the Town (the"Sales Commencement Date") and each year on the same date thereafter, through the end of the fifth(5°i) year following the Sales Commencement Date plus a five(5)year extension to be mutually agreed upon by the parties hereto based on good faith negotiations(each an "Annual Payment",and collectively the"Annual Payments"), unless earlier terminated pursuant to the terms of Section 19 hereof, Operator shall notify the Town when Operator commences sales within the Town, Operator will provide the Town with copies of its periodic financial filings to the DPH documenting Gross Sales,and also a copy of its annual filing as a non-profit, if any,to the Massachusetts Office of the Attorney General. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 21pagc I Notwithstanding anything to the contrary herein, every three(3) years after the Sales Commencement Date the Town and Operator shall jointly review the Community Impact Fee and, to the extent that the impact of the Facility on the Town is lower than originally expected,shall decrease the Annual Payment based on the actual overall impact of the Facility on the Town. Any decrease in the Annual Payment shall be proportional to the identified impact. The Operator shall evaluate and monitor crime statistics,fire protection services, public health statistics, inspectional services and permitting services in conjunction with and with the reasonable cooperation of the appropriate municipal office before and after the Sales Commencement Date. The Operator shall provide this information to the Town and any decrease in the Community Impact Fee shall be based on the de-escalation of the aforementioned services in the area itmnediately Surrounding the Facility, at a rate in excess of town-wide de-escalation, unless mutually agreed upon by the Operator and the'fown. 3. Taxes: The Operator will pay all local, state and federal taxes as required by applicable law, as now existing or as hereafter may from time to time be enacted,repealed or modified. 4. Community Impact Fee as Comnensatorv: The Community Impact Fee refc•enced herein shall be compensatory to the Town of all impacts of the Facility's operation in the Town including all reasonable indirect cost.Nothing herein shall be construed to exempt the Facility from payment of local, state and federal taxes as contemplated in Section 3 hereinabove. 5. Local Hirina: The Operator agrees that jobs created at the Facility will be made available to Watertown residents.Town residency will be a positive factor in hiring decisions at the Facility,but this does not prevent the Operator from hiring the most qualified candidates and complying with all employment laws and other legal requirements. 6. Anoroval of ManaEer: If requested by the Town, Operator shall provide to the Town, for review and approval,the name and relevant information, including but not limited to the information set forth in 105 CMR 725.030,of the person proposed to act as on-site manager of the RMD. Town shall consider such request for approval within thirty(30) days following submittal to determine, in consultation with the Police Chief, if the person proposed is of suitable character to act as on-site manager. Such approval shall not be unreasonably denied,conditioned or delayed. Said approval shall be considered unreasonably denied, conditioned or delayed if the Town denies such approval and the DPH has approved said manager pursuant to the Regulations. Notwithstanding the foregoing, in the event that the Town does not provide confirmation or rejection of the proposed on-site manager within thirty(30)days,that manager shall be deemed approved by the Town. This approval process shall also apply to any change of on-site manager. 7. Prevention of Diversion: To the extent requested by the Town's Police Department, and consistent with the Regulations,Operator shall work with the Town's Police Department to implement a comprehensive diversion prevention plan to prevent diversion,such plan HOST COMMUNITY AGREEMENT I—TOWN OF WATERTOWN,MA 3111agc I I to be in place prior to the Sales Commencement Date, Such plan will include, but is not limited to, (i) training RMD employees to be aware of,observe, and report any unusual behavior in patients, caregivers, authorized visitors or other RMD employees that may indicate the potential for diversion;(H)strictly adhering to certification amounts and time periods(per DPH guidelines); (ill)rigorous patient identification and verification procedures through the DPH Online System;(iv) utilizing seed-to-sale tracking software to closely track all inventory at the RMD; and (v)refusing to complete a transaction if the patient or caregiver appears to be under the influence of drugs or alcohol. B. Security: To the extent requested by the Town's Police Department, and consistent with the Regulations, Operator shall work with the Town's Police Department iu determining the placement of interior and exterior security cameras,so that at least two cameras are . located to provide an unobstructed view in each direction of the public way(s)on which the Facility is located. Operator will maintain a cooperative relationship with the Police Department, including but not limited to periodic meetings to review operational concerns, cooperation in investigations,and communication to the Police Department of any suspicious activities at the Facility. Such camera(s) may be altered by the DPH during their security and architectural review process. 9. Reeistation and Aoorovals Required: Anything contained herein to the contrary notwithstanding,the obligations of the Operator and the Town recited herein are specifically contingent upon the Operator obtaining a Certificate of Registration for the operation of a RMD from the DPH to operate the Facility in the Town, and the Operator's receipt of all necessary local permits and approvals. 10, Cooperation; The Town shall work cooperatively and in good faith with the Operator in securing the prompt and efficient siting,planning, permitting and preparation for opening of the Facility, provided that nothing herein shall require the Town to waive any review and approval rights set forth in applicable statutes or regulations, and provided further that the Town shall retain the right to provide comments and recommendations regarding design and security, It. Stmoort fa•Regstration: The Town shall support the Operator's application for registration of its RMD by the DPH, and work with Operator to assist in securing such registration. 12. Assignment: Operator shall not assign,sublet or otherwise transfer this Agreement, in whole or in part, without the prior written consent of the Town,which consent shall not be unreasonably withheld; provided,however,that such consent shall not be required in the event such transfer or assignment is between the Operator and another affiliated entity Which will utilize the Facility for the purposes allowed herein and which is duly authorized by the DPH or other authorizing entity, or if such assignment at,transfer is the result of a merger or acquisition of the Operator. HOST COMMUNITY AGREEMENT —TOWN OF WAT$RTOWN, MA A1hage l I 13. Coin fiance: Operator shall comply with all laws,rules, regulations and orders applicable to the operation of an RMD, such provisions being incorporated herein by reference, and shall be responsible for obtaining all necessary licenses, permits,and approvals required for the operation of an RMD. 14, Retention of Reeulatory Authority:By entering into this Agreement,the Town does not waive any enforcement rights or regulatory authority it currently fields over any business in the Town, 15. Notices: Any and all notices, or other communications required or permitted under this Agreement,shall be in writing and delivered by hand or mailed postage prepaid, return receipt requested, by registered or certified mail or by other reputable delivery service, to the parties at the addresses set forth on Page 1 of this Agreement or furnished from time to time in writing hereafter by one party to the other party. Any such notice or correspondence shall be deemed given when so delivered by hand, if so mailed,when deposited with the U.S. Postal Service or, if sent by private overnight or other delivery service,when deposited with such delivery service. 16. Severability: If any term or condition of this Agreement or any application thereof shall to any extent be held invalid, illegal or unenforceable by a court of competent jurisdiction,the validity, legality, and enforceability of the remaining terms and conditions of this Agreement shall not be deemed affected thereby unless one or both parties would be substantially or materially prejudiced. 17. Governing Law:This Agreement shall be governed by,construed and enforced in accordance with the laws of the Commonwealth of Massachusetts and the parties hereto submit to the jurisdiction of any of its appropriate courts for the adjudication of disputes arising out of this Agreement. 18, Entire Agreement:This Agreement,including all documents incorporated herein by reference,constitutes the entire integrated agreement between the parties with respect to the matters described. This Agreement supersedes all prior agreements,negotiations and representations,either written or oral,and it shall not be modified or amended except by it written document executed by the parties hereto. 19. Termination:This Agreement shall terminate at the time that either of the following occur: a. The Town notifies Operator of the Town's termination of this Agreement;or b. Operator ceases to operate a RMD in the Town. In the event of termination of this Agreement pursuant to sub-sections a)or b)of this section, this Agreement shall have no farther force and effect and neither of the parties shall have any further rights, obligations or liabilities to the other party, provided that Section 22 hereof shall remain in full force and effect. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 51page i 20, Term:This Agreement shall have an initial term of five(5)years at which point the parties may in good faith renegotiate the terms of this Agreement for an additional five (5)year term, Operator shall not be required to cease operations at the termination of this Agreement. 21. Aonromriation.The purpose of this Agreement is to assist the Town in addressing any public safety and health effects the Facility may have on the Town,as deemed appropriate by the[Town Manager/Town Council] .The Town shall determine use of all Annual Payments consistent with the purposes of this Agreement. 22. Confidentiality: Operator may provide to the Town certain financial information, investment materials, products, plans,documents,details of company history, know-how, trade secrets,and other nonpublic information related to Operator, its affiliates and operations(collectively,the "Confidential Information").Town (inclusive of its employees, agents, representatives or any other of its affiliated persons)shall not, at any time during the term of this Agreement or at any time thereafter, disclose to any person or entity,any Confidential Information,except as may be required by court order or law. 23. Waiver:The obligations and conditions set forth in this Agreement may be waived only by a writing signed by the party waiving such obligation or condition, Forbearance or indulgence by a party shall not be construed as a waiver, nor limit the remedies that would otherwise be available to that party under this Agreement or applicable law.No waiver of any breach or default shall constitute or be deemed evidence of a waiver of any subsequent breach or default, 24. Amendment:This Agreement may only be amended by a written document duly executed by both of the parties hereto. No modification or waiver of any provision of this Agreement shall be,valid unless duly authorized as an amendment hereof and duly executed by the Town and the Operator. 25. Modifications. Modifications to this Agreement may only be effective if made in writing and signed by both of the parties hereto. 26. Headings:The article, section,and paragraph headings in this Agreement are for convenience only, are no part of this Agreement and shall not affect the interpretation of this Agreement, 27. Counterparts:This Agreement may be signed in any number of counterparts,all of which taken together shall constitute one and the same instrument, and any party hereto may execute this Agreement by signing one or more counterparts. 28. Signatures. Facsimile signatures affixed to this Agreement shall have the same weight and authority as an original signature. [SIGNATURES TO FOLLOW] HOST COMMUNITY AGREEMENT I—TOWN OF WATERTOWN, MA 61Page The following signature indicate that the parties hereby agree to the terms set forth in this Agreement as of the date set forth on page I of this Agreement. For the Town of Watertown, Massachusetts: For NS AJO Holdings, Inc.; By: Aidan O'Donovan Title: COO,NS AJO holdings,Inc, i I HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 7113agc TOWN OF WATERTOWN AND NS AJO HOLDINGS, INC. HOST COMMUNITY AGREEMENT FOR TILE SITING OF A REGISTERED MARIJUANA DISPENSARY IN THE TOWN OF WATERTOWN This Host Community Agreement("Agreement") is entered into pursuant to M.G.L, 44, §53A this day of December,2016 by and between NS AJO Holdings, Inc, a Massachusetts not- for-profit corporation with a principal office address of 67-Dana,Street,41, Cambridge,MA 02138 (the"Operator") and the Town of Watertown,aMassachusetts municipal corporation with a principal address of 149 Main Street, Waterfown, MA 0202 (the"Town"). WHEREAS,Massachusetts voters approved the legal cultivation,processing, distribution, sale and use of marijuana for medical purposes lhrough Chapter 369 of the Acts'Of 2012,An Act for Humanitarian Medical Use of Marijuana; and WHEREAS,Massachusetts,acting' gli the Commonwealth of Massachusetts Department of Public Health (the"DPH") implemented regulatory frameviork for the regulation of the use of marijuana for medical purposes througli'I05 CivIR 725.000 et:'seq, (the"Regulations");and WHEREAS,Operator wishes`to locate and`operata a Medical Marijuana Treatment Center at 23 Elm Street, Watertown, MA 02472 in accordance with the Regulations (the"Facility"); and WHEREAS,A Medical Marijuana Treatment Center is defined by the DPH as a not-for-profit entity registered under 105 CMR 725"1 00,{o be known as a registered marijuana dispensary(an thaf acgahcs,cultivates;possesses,processes (including development of related products such as edible MIIPs,tinctures, aerosols,oils,or ointments),transfers,transports, sells, distributes:dispenses,or administers-marijuana,products containing marijuana,related supplies, or educational materials to registered qualifying patients or their personal caregivers.Unless otherwise specified,RMD refers to the site(s)of dispensing, cultivation,and preparation of marijuana;and WHEREAS,Operator will serve its non-profit purpose of providing marijuana for medical use, educational materials,and related products,to medical use of marijuana patients in Town and throughout the Commonwealth of Massachusetts; WHEREAS,The Town enacted Ordinance 459 (0-59-2014), an ordinance amending the Town's Zoning Ordinance regarding Medical Marijuana Treatment Centers and related uses for patients with a debilitating medical condition to allow a Medical Marijuana Treatment Center by Special Permit in the 1-1,I-2,I-3 and RMUD Zoning Districts. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN,MA IIPage WHEREAS,The Facility is located in the RMUD Zoning District and as such is permitted by Special Permit; WHEREAS,The Facility complies with the buffer requirements set forth in 105 CMR 725,110(A)(14); and WHEREAS, Operator intends to provide certain benefits to the Town in the event that it obtains a Certificate of Registration to operate an RMD in Town and has received all required local approvals. WHEREAS,notwithstanding the anticipated benefits to certain.,members of the community, the facility may impact town resources in ways unique to tlne business of the facility and draw upon town resources in a manner not shared by the general population;. NOW,THEREFORE,in consideration of the above,the Operator and-the Town agree as follows: 1. Community Imnact Fee: the parties anticipafe"that the-Town could iifctir extended expenses and draws upon the town's road systeiu5 law enforcement, fire'protection services, inspectional servieds'and permitting seibices,public health services and potential additional unforeseen hnpacts upon the Town, Accordingly, in order to mitigate the financial impact upon the Town and use of Town resoufces,the Operator will pay to the Town a conununity-impact fee(the"Cominpii ty Imjiact Fee")in the amounts and payable at such times as described in Section 2 hereof: . " 2. Payments: SubjecIt_to adjustni-eni or modification as set forth in the fourth paragraph of this section, Operator_shall pay_to.the Town'the greater of either(a) an annual total of Two;Hundred.Thousaitd-Dollars'and 00/100,($200,000.00)in the aggregate, annually, or (b)6%of the Gross Sales-.generated"annually-at the Facility. For the purposes hereof, "'Gross Sales"shall mean the total of all sales of Medical Marijuana or products containing Medical Marijauna,transactions conducted at the Facility,less any sales taxes collected. In either case; ,begimung on the first day of the thirteenth month following the date of commencement of sales in(lie Town(the "Sates Comnrencernent Date")and each year on the same date thereafter,through the end of the fifth(5"') year following the Sales Commencement Date plus a five (5)year extension to be mutually agreed upon by the parties hereto.based on good faith negotiations(each an "Annual Payment", and collectively the"Annual Payments"), unless earlier terminated pursuant to the terms of Section 19 hereof. Operator shall notify the Town when Operator commences sales within the Town. Operator will provide the Town with copies of its periodic financial filings to the DPH documenting Gross Sales, and also a copy of its annual filing as a non-profit,if any, to the Massachusetts Office of the Attorney General. HOST COMMUNYTY AGREEMENT I—TOWN OF WATERTOWN,MA 21Page Notwithstanding anything to the contrary herein,every three (3)years after the Sales Commencement Date the Town and Operator shall jointly review the Community Impact Fee and, to the extent that the impact of the Facility on the Town is lower than originally expected, shall decrease the Annual Payment based on the actual overall impact of the Facility on the Town. Any decrease in the Annual Payment shall be proportional to the identified impact. The Operator shall evaluate and monitor crime statistics, fire protection services,public health statistics, inspectional services and permitting services in conjunction with and with the reasonable cooperation of the appropriate municipal office before and after the Sales Commencement Date, The Operator shall provide this information to the Town and any decrease in the Community Impact Fee shall be based on the de-escalation of the aforementioned services inth6area immediately surrounding the Facility, at a rate in excess of town-wide de-esca,14tion, unless mutually agreed upon by the Operator and the Town. 3, Taxes: The Operator will pay all local, state and federal taxes as required by applicable law,as now existing or as hereafter may from time to time be enacted,repealed or modified. 4. Conununity hnnact Fee as Compensatorv: The Community Impact Fee'i•eferenced herein shall be compensatory to the Towii of all impact's of the Facility's operation in the Town including all reasonable indirce(post,Nothing herein shall be construed to exempt the Facility from payment of local,state_and federal taxes'as contemplated in Section 3 hereinabove. 5. Local Hirinat The Operator'agrees that jobs`created at the Facility will be made available to Watertown residents. Town residencywill be a positive factor in hiring decisions at the Facility,but this doss not prevent the Operator from hiring the most qualified candidates and complying with all employment laws and other legal requirements. 6, Approval of Manaeer: If requested by the Town, Operator shall provide to the Town, for review and approval;the panic and relevant information, including but not limited to the infoim'ation set forth in-105 CMR 725A30,of the person proposed to act as on-site manager of the RMD. Town shall consider such request for approval within thirty(30) clays following submittal to determine, in consultation with the Police Chief, if the person proposed is of suitable.character to act as on-site manager. Such approval shall not be unreasonably donied,;conaltioned or delayed. Said approval shall be considered unreasonably denied;conditioned or delayed if the Town denies such approval and the DPH has approved said manager pursuant to the Regulations. Notwithstanding the foregoing, in the event that the Town does not provide confirmation or rejection of the proposed on-site manager within thirty(30) days,that manager shall be deemed approved by the Town. This approval process shall also apply to any change of on-site manager. 7. Prevention of Diversion: To the extent requested by the Town's Police Department, and consistent with the Regulations, Operator shall work with the Town's Police Department to implement a comprehensive diversion prevention plan to prevent diversion,such plan HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN,MA 31Pargc i to be in place prior to the Sales Cormnencement Date. Such plan will include, but is not limited to, (i)training RMD employees to be aware of, observe, and report any unusual behavior in patients,caregivers, authorized visitors or other RMD employees that may indicate the potential for diversion; (ii) strictly adhering to certification amounts and time periods(per DPH guidelines); (iii)rigorous patient identification and verification procedures through the DPH Online System; (iv)utilizing seed-to-sale tracking software to closely track all inventory at the RMD;and(v) refusing to complete a transaction if the patient or caregiver appears to be under the influence of drugs or alcohol. 8. Security: To the extent requested by the Town's Police Department, and consistent with the Regulations, Operator shall work with the Town's Police Department in determining the placement of interior and exterior security camer*-so that at least two cameras are located to provide an unobstructed view in cacti direction of the public way(s)on which the Facility is located. Operator will maintain a cooperative relationship with the Police Department, including but not limited to periodic meetings fo'review operational concerns, cooperation in investigations,and communication to the Police Department of any suspicious activities at the Facility.'Such camera(s)may be altered by the DPH during their security and architectural review process, 9, Reeistr'ation and ADDrovals Regitired: Anything"contained herein to the contrary notwithstanding,the obligatioris:of the Operator and tale Town recited herein are specifically contingent upon the'oPeratorebtaiuing a Certificate of Registration for the operation of a RMD from the DPH:to operate"the Tacilityin Are Town, and the Operator's receipt of atlpecessary local permits,64d approvals. 10. CooDeration: The Town shall work cooperatively and in good faith with the Operator in securing the prompt and efficient siting,planning, permitting and preparation for opening of the Facility,provided,that nothing herein shall require the Town to waive any review and approval rights set forth in applicable statutes or regulations, and provided further that the Town shall retain!lie right to provide comments and recommendations regarding design and security., 11, .S'UDUDrt'for Registration: The Town shall support the Operator's application for registration of its RMD by the DPH, and work with Operator to assist in securing such registration. 12. Assignment; OperafWshall not assign, sublet or otherwise transfer this Agreement, in whole or in pant,without the prior written consent of the Town, which consent shall not be unreasonably withheld; provided, however, that such consent shall not be required in the event such transfer or assigmncnt is between the Operator and another affiliated entity which will utilize the Facility for the purposes allowed herein and which is duly authorized by the DPH or other authorizing entity, or if such assignment or transfer is the result of a merger or acquisition of the Operator,, HOST COMMUNITY AGREEMENT J TOWN OF WATERTOWN,MA 4111age i 13, Compliance: Operator shall comply with all laws, rules,regulations and orders applicable to the operation of an RMD, such provisions being incorporated herein by reference,and shall be responsible for obtaining all necessary licenses,permits,and approvals required for the operation of an RMD. 14. Retention of Reaalatory Authoritv: By entering into this Agreement, the Town does not waive any enforcement rights or regulatory authority it currently holds over any business in the Town. 15, Notices: Any and all notices, or other communications required or permitted under this Agreement, shall be in writing and delivered by hand or.mailed postage prepaid,return receipt requested,by registered or certified mail or by other reputable delivery service, to the parties at the addresses set forth on Page 1 of this Agreement or furnished from time to time in writing hereafter by one party to the other party.Any such notice or correspondence shall be deemed given when so delivered by hand, if so mailed,when deposited with the U.S, Postal Service;or,if sent by private overnight or other delivery service, when deposited with such delivery service, 16. Severability: If any term or condition of this Agreement or any application thereof shall to any extent be held invalid;illegal or unenforceable,by a court of competent jurisdiction, the validity, legality, and enforceability of the remaining terms and conditions of this Agreement shall not be dcenred affected thereby unless one or both patties would be substantially or materially prejudiced, 17. Governine Larv:'This Agreement shall be.governed by,.construed and enforced in accordance with the laws of the Commonwealth of Massachusetts and the parties hereto submit to the jurisdiction of aiiy,of its appropriate courts for the adjudication of disputes arising:Put of this Agreement 19. Entire Agreement: This Agreement, including all documents incorporated herein by reference, constitutes the entire integrated agreement between the parties with respect to the matters described.This Agreement supersedes all prior agreements,negotiations and representations, either written or oral, and it shall not be modified or amended except by a written document executed by the parties hereto. 19, Termination: This Agreement shall terminate at the time that either of the following occur: a. The Town notifies Operator of the Town's termination of this Agreement; or b. Operator ceases to operate a RMD in the Town. In the event of termination of this Agreement pursuant to sub-sections a) or b)of this section,this Agreement shall have no further force and effect and neither of the parties shall have any further rights,obligations or liabilities to the other party,provided that Section 22 hereof shall remain in full force and effect. HOST COMMUNITY AGREEMENT!—TOWN OF WATERTOWN,MA 5 1 P a g e i 20. Term: This Agreement shall have an initial term of five(5)years at which point the parties may in good faith renegotiate the terms of this Agreement for an additional five (5) year term, Operator shall not be required to cease operations at the termination of this Agreement. 21. Annronrration. The purpose of this Agreement is to assist the Town in addressing any public safety and health effects the Facility may have on the Town,as deemed appropriate by the [Town Manager/Town Council] . The Town shall determine use of all Annual Payments consistent with the purposes of this Agreement. 22. Confidentiality: Operator may provide to the Towtr:certain financial information, investracnt materials,products,plans, documentsi:details of company history,know-how, trade secrets,and other nonpublic infornnation'related fo Operator, its affiliates and operations(collectively,the "Confidential,Iiifoniratimn"). Town (inclusive of its employees, agents,representatives or any other of its affiliated persons) shall not, at any time during the term of this Agreement or at any time thereafter;disclose to any person or entity, any Confidential Information,except as may be required by court order or law. 23. Waiver:The obligations and conditions set forth in,this Agreement may be waived only by a writing signed by the party waiving such obligation or condition.Forbearance or indulgence by a party shall not be.construed as a waiver, nor limit the remedies that would otherwise be available to that party under this Agreement or applicable law. No waiver of any breach or default shall constitute or be.deeh.ied evidence of a waiver of any subsequent breach or default. 24, Amendment:This Agreement may onlybe'amended by a written document duly executed by both of the patties hereto.No modification or waiver of any provision of this Agreement shall be-�alidiinless dilly authorized as an amendment hereof and duly executed by the Town and*the Operator,-. 25. Modifications. Modifications to.this Agreement may only be effective if made in writing and signed by both of the parties hereto. 26, Headings:The article, section, and paragraph headings in this Agreement are for convenience only,are no part of this Agreement and shall not affect the interpretation of this Agreement. 27, Counterparts: This Agreement may be signed in any number of counerparts,all of which taken together shall constitute one and the same instrument,and any party hereto may execute this Agreement by signing one or more counterparts. i 28, Signatures. Facsimile signatures affixed to this Agreement shall have the same weight and authority as an original signature. f [SIGNATURES TO FOLLOW] i 140ST COMMUNITY AGREEMENT 1—TOWN OF WATERTOWN,MA 61Pagc The following signature indicate that the parties hereby agree to the terms set forth in this Agreement as of the date set forth on page I of this Agreement. For the Town of Watertown,Massachusetts: For NS AJO Holdings, Inc.: By: Aidan O'Donovan Title: COO,NS AJO Holdings, Inc. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN,MA Jj 71Pagc I I i PRince LOBeL December 12, 2016 Rev. December 21, 2016 VIA US MAIL AND EMAIL Steven Magoon Community Development& Planning, Director Town of Watertown 149 Main Street Watertown, MA 02472 Re: 23 Elm Street Dear Director Magoon: As you are aware, this office represents NS AJO Holdings, Inc. ("NS AJO"), in connection with the siting of a Medical Marijuana Treatment Center at 23 Elm Street In Watertown, Please allow this letter to serve as a supplement to our previous filing, As previously attached to my December 12, 2016 letter, you will find a draft Community Host Agreement(the "Community Host Agreement') proposal from NS AJO. We are prepared to discuss this in greater detail at your earliest convenience, ' With regard to your question regarding the potential for recreational distribution in the future, NS AJO wishes to make clear that this application is for a Medical Marijuana Treatment Center only. NS AJO has made no determination as to whether It Intends to operate recreationally in the future. To the extent that NS AJO chooses to pursue recreational operations In Watertown, NS AJO agrees to fully comply with any and all permitting and licensing requirements. Moreover, NS AJO commits that in no way will the Value of the Community Host Agreement be reduced or diminished in any way; more likely it will Increase in the future. Please do not hesitate to contact me if you have any comments, questions, or concerns. E s egords, �, V' ichael P, Ro Direct: 617-456-8149 Email: mrossO.orincelobel.com i Prince Lobel Tye uN One International Place Suite 3700 Boston, MA 02110 TEL:617 456 8000 FAX:617 456 8100 2594960.0 www.princelobel.com City of Watertown Proposal Medical w � F � *-� ( AHIKAL .4. aLVCTII W E}p Prepared by NS • / Holdings, Submittedi ' ( f Executive Summary NS A70 Holdings,Inc.,d/b/a(Natural Selections)(`Natural Selections,"or"the applicant")is a Massachusetts-based non-profit company committed to serving registered patients within the city of Watertown and the surrounding community. The applicant has set forth the following objectives in establishing its organization: 1) A compliant operation in good standing with regulators and 105 CMR 725.000, 2) Safe,consistent,and effective cannabis and cannabis products of the highest quality, 3) Commhment to serving atnd educating patients and caregivers,and 4) Commitment to scientific research and development, Market Overview Natural Selections is committed to serving patients with debilitating medical conditions as defined under 105 CMR 725.000. These conditions include cancer, glaucoma, positive status for human Immunodeficiency virus (HIV), acquired immune deficiency syndrome (AIDS),hepatitis C, amyotrophic lateral sclerosis (ALS), Cretin's disease, Parkinson's disease, and multiple sclerosis (MS), The Department of Health projects that 2% of the resident population in Massachusetts will qualify for and benefit from medical cannabis, Capturing this segment of the patient population will take time to ramp up. Based on a ramp-up analysis of patient populations in Colorado,Arizona,and Oregon,Natural Selections anticipates that there will be approximately 4,500 registered patients living within a five-mile radius of the applicant's proposed MMTC by 2019. ( Proiect Proposal Natural Selection is planning to develop a Medical Marijuana Treatment Center("MMTC") located at 23 Elm Street in Watertown,.Massachusetts.This location is located within the Regional Mixed Use District(RMUD),which allows Medical Marijuana Treatment Centers by Special Permit,The MMTC will be a safe and inviting space for registered patients and caregivers to purchase medical cannabis flower and manufactured infused products("MIPS"), while also receiving education and training in regard to responsible use of cannabis,Natural Selections has studied the medical conditions eligible for treatment under 105 CMR 725.000 and intends to provide an array of cannabis products best suited to treat the symptoms of these conditions. Structure&rxperlence Natural Selections is highly committed to serving registered patients in Watertown and the surrounding community, As a non-profit organization, the applicant's proceeds are reinvested directly into patient services, community activism, and its subsidized distribution network, Natural Selections is uniquely qualified to operate a cannabis cultivation and dispensary facility, in Massachusetts, Members of the applicant's team have been operating a dispensary and cultivation facility in Colorado for the past two years and have the skills and knowledge to develop the best cannabis products for registered patients in Massachusetts. Chief Executive Officer Isador Mitzner brings extensive retail and business operating experience to the team. He founded a clothing company, LAT Sportswear in 1978 in Atlanta, As the CEO and Owner of LAT sportswear,lie spent three decades growing and expanding the ( t l - business until Its sale In 2012. Chief Operating Offcer Aldan O'Donovan will lead the team throughout all stages of the cultivation,processing,and dispensing process,O'Donovan founded the Natural Selections, Colorado facility in 2014 and has extensive experience in developing,implementing,and maintaining standard operating procedures related to environmental control, lighting mechanisms, media and nutrient additives,post harvest processing and quality control,and optimal strain selection. Chief Financial Officer Bob Aldworth brings experience in finance and operations from public and private companies,ranging from a stint-up to multi-national companies Dan Linskey,the former Superintendent-in-Chief of the Boston Police Department and current Managing Director of Kroll Investigations,will serve as Natural Selections' security director. Linskey led the Boston Police Department through some of the most tragic and contentious events in the city's history,including the Boston Marathon Bombings and the Occupy Movement. He has strong relationships with local law enforcement agencies in Watertown and Boston, Massachusetts and will uphold Natural Selection's commitment to security as well as a seamless integration into the Watertown community. David R. Goodman, MD,will serve as Medical Director for the business. Dr. Goodman Is an Anesthesiology Specialist based In Newton, Massachusetts. He has more than 14 years of medical experience and is affiliated with Newton-Wellesley Hospital. Goodman will be responsible for developing, organizing, and facilitating education programs for patients, caregivers, board members, mud the community at large concerning methods of consumption, / cannabinoid profiles,regulation updates,as well as the applicant's services and programs. Operational Overview Natural Selections understands the responsibilities and risks associated with establishing a MMTC In the City of Watertown.The applicant is highly committed to safety for patients, caregivers,staff,and the general public and will work closely with the City of Watertown, local law enforcement agencies,and the Department of Public Health to ensure that Natural Selections integrates seamlessly into the community that it serves.The applicant has designed a number of Standard Operating Procedures and best practices related to security,cultivation, manufacturing/processing,chain of custody,waste disposal,quality control,and secure transportation.The applicant is also committed to building a strong employee culture and establishing a shared responsibility among its employees,patients,and caregivers to prevent diversion,theft,or any other illegal behavior. Benefits to the City of Watertown Natural Selections is committed to benefiting the City of Watertown through community and fiscal impact.Natural Selections is willing to offer up the greater amount of$200,000 or 6%of the gross revenue generated annually from the MMTC to the City in the form of a Community Host Agreement.The applicant has also set aside$100,000 amorally to offset any additional or unfareseemissues that may affect the city,such as additional demands on local law enforcement agencies, Increased use of City infrastructure,or the need for additional City infrastructure, employees and equipment. i ( The applicant will be committed to providing residents of Watertown with full-time jobs with competitive salaries,healthcare,and benefits.A true non-profit,Natural Selections is committed to philanthropy and plans to partner with local civic and community based organizations that promote public health within the Watertown community.Additionally,the applicant will establish ongoing community dialogues and seminars in order to provide transparency about its operations and education about the responsible medical use of cannabis,Natural Selections will also sponsor community health programs geared towards preventing substance abuse and HIV/AIDS. { 1 � ( i Table of Contents Section I: Natural Selections Overview ExecutiveSummary.................................................................................2 Introduction to Team.................................................................................3 Descriptionof Project................................................................................7 Project Timeline.............................. ..........................8 Section II: Security Plan Oeneral Security Overview........................................................................II Secure Transportation Plan........................................................................18 Anti-Diversion Plan....................................................................................20 Anti-Loiterbng Plan..................................................................................31 Section III: Business Operations &Marketing Plan Business Operations&Marketing Plan.........................................................37 Section IV: Financials CapitalExpenditure .................................................................................44 Revenue&Operating Expense Projections......................................................47 Section V: Benefits &Effects on the City of Watertown Fiscal &Community Impact................................................................'........51 Subsidized Cannabis Distribution Network......................................................52 Job Creation for the City of Watertown......................................................53 Section VI:Mitigation and Prevention of Potential Adverse Effects Preventing Increased Crime ......................................................................57 r , I I i lPreventing Drugged Driving......................................................................57 Preventing Distribution to Minors................................................... ............59 Preventing Public Consumption...................................................................64 Preventing Health Issues.........................................................................64 Other Potential Effects on City..................................................................65 Section VIE Best Practices & Standard Operating Procedures Cultivation Best Practices,................. ...... ................................................68 Manufacturing("MIPS")Best Practices..........................................................70 Quality Control &Testing Best Practices.........................................................72 WasteDisposal Plan...............................................................................73 Section VIII: Appendix r t Financial Statements.................................................................................78 Original Submission Packet to City of Watertown..............................................82 I i i i Section I Natural Selections Overview r i Executive Summary NS AID Holdings,Inc.,d/h/a(Natural Selection)("Natural Selections,"or"the applicant")is a Massachusetts-based non-profit committed to serving medical cannabis patients in Watertown, Massachusetts.Natural Selections is an established organization committed to providing access to quality natural medicine on the basis of scientific research and development.Previous to incorporating in Massachusetts,members of the Natural Selections'team have successfully owned and operated a dispensary in Colorado C Nawral Selections, Colorado"),which has emerged as a leading camrabis organization with a strong reputation for its commitment to scientific research and development,community involvement,and high-quality,safe,and consistent products.The applicant has set forth the following objectives in establishing its organization: 1) A compliant operation in good standing with regulators and 105 CMR 725.000, 2) Safe,consistent and effective products of the highest quality, 3) Commitment to serving and educating patients and caregivers,and 4) Connnitment to scientific research and development, Natural Selections has assembled a team of experienced professionals excited to dedicate their business and cultivation expertise to produce medical cannabis in Massachusetts.The team is led by Isador Mitzner,an experienced entrepreneur with decades of experience in the retail business, Aidan O'Donovan,an experienced cultivator and cannabis business owner,and Bob Aldwmth,a financial professional with extensive experience in finance and operations from public and private companies.David R Goodman,a board-certified physician from Newton,Massachusetts, will serve as the applicant's medical director and provide oversight and support to the Registered Marijuana Dispensary(the"RMD")to help maintain and continuously improve tite quality of care provided to qualified and registered patients and caregivers. The applicant plans to build collaborative relationships with state and local governments to ensure a seamless integration into the community it serves.Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local civic and community organizations that promote public health within the Watertown community.Additionally,Natural Selections will establish ongoing community dialogues and seminars in order to provide transparency about its operations and education about the responsible medical use of cannabis. The team has extensive experience in treating and servicing medical cannabis patients, Chief Operating Officer Aldan O'Donovan is the founder of a dispensary in Northglenn,Colorado.The business, which opened upon receipt of its license in 2014,specializes in cultivating and dispensing cannabis to Colorado patients suffering from a variety of illnesses, O'Donovan will lead the team in all elements of developing,implementing,and maintaining a cannabis operation. With regard to cultivation,he has extensive knowledge related to environmental control, indoor agricultural lighting mechanisms,media and nutrient additives,post harvest processing and quality control,and optimal strain selection.O'Donovan will be responsible for matching the needs of patients with the most effective health solutions,while ensuring that the operation is in compliance with regulators and 105 CMR 725.000,O'Donovan's experience will also be critical to establish the business operations in a timely fashion to ensure that patients are provided with j the treatments they need as quickly as possible, i Natural Selections is committed to operating a highly secure and compliant RMD in Watertown, ( Massachusetts,To this effect,the applicant has engaged Dan Linskey,the former Superintendent- 2 i { in-Chief of the Boston Police Department and current Managing Director of Kroll Investigations and Disputes,to serve as its Security Director.Linskey led the Boston Police Department through some of the most tragic and contentious events in the city's history,including the Boston Marathon Bombings and the Occupy Movement.He has strong relationships with local law enforcement agencies in Watertown and Boston,Massachusetts and will uphold Natural Selection's commitment to security as well as a seamless integration into the Watertown community. Natural Selections is committed to serving registered patients in Watertown and will assemble a board of advisors to ensure that its business is meeting the expectations of the community and operating In a true non-profit fashion.The team believes that Natural Selections will be instrumental in helping to create a strong cannabis industry in Massachusetts,where patients are guaranteed safe and secure access to medication in a manner compliant with all regulations outlined in 105 CMR 725.000. Introduction to Team Experise in Design&Development Co-founders Isador Mitzner,Aidan O'Donovan,and Bob Aldworth have certain qualifications as it relates to designing and developing cannabis dispensary/cultivation facility that will be Invaluable to the operation.They have assembled a team of architectural,engineering,and security professionals to help bolster their own areas of expertise.Natural Selections intends to design and develop the RMD while prioritizing efficiency,safety,community,and future r development. Aldan O'Donovan,COO,is originally from Newton,Massachusetts.He has waked in the medical cannabis industry since 2009.In 2014,O'Donovan spearheaded the design and development of Natural Selections,Colorado's dispensary facility(2,700 square feet)and cultivation facility(8,000 square feet)in Colorado.He also assisted in the build-out of Spoonful of Sugar, a cannabis manufacturing/processing lab and kitchen in Denver,Colorado in 2011. Natural Selections is committed to creating a sense of community through its RMD,which will create a shared sense of responsibility among patients,caregivers,and employees.To this effect, the applicant will invest in a spacious and inviting design to ensure that patients feel comfortable within the MMTC and have sufficient tune to discuss all questions and concerns with dispensary agents.O'Donovan will oversee the establishment of the facility,All flooring,lighting,and colors schemes will be selected to create a natural,spacious feel. In addition to creating an inviting establishment for its patients, the applicant is committed to implementing extensive security measures that will comply with all regulations outlined under 105 CMR 725.110.Natural Selections operates in a high-risk environment and understands the high-risk level for theft and robbery.Natural Selections is committed to designing a space where prevention and deterrence will be achieved by means of physical security prevention measures, electronic security measures,and operational security measures.The applicant is committed to providing extensive training,information,and resources to its employees so they are prepared to prevent,report,deter,and when appropriate,respond to any violence that could occur on the promises. 1 3 Dan Linskey will lead the Natural Selections team in designing and developing a secure Medical Marijuana Treatment Center(the"MMTC")and cultivation facility.Linskey serves clients in diverse industries with uncommon experience in investigations,crisis response,and risk management,as well as personal,physical,and operational security strategies,Widely respected for his knowledge of the complexities inherent in law enforcement and homeland security,Dan has also consulted with numerous national and international government agencies on a broad range of challenges,including large-scale event management,crisis leadership,and preparedness and community engagement strategies.Linskey has extensive experience designing and implementing security systems rooted in Crime Prevention Through Environmental Design ("CP'1'ED"),Concentric Circles of Protection,and Integrated Design. Expertise in Operations Natural Selections is uniquely qualified to operate a cannabis cultivation and dispensary facility in Massachusetts. Members of the applicant's team have been operating a dispensary and cultivation facility in Colorado for the past two years and have the skills and knowledge to develop the best cannabis products for registered patients in Massachusetts. Isador Mitzner,CEO, brings extensive.retail and business operating experience to the team. He founded a clothing company, LAT Sportswear in 1978 in Atlanta.As the CEO and Owner of LAT sportswear, he spent three decades growing and expanding the business until its sale in 2012. Bob Aldworth,CFO, brings experience in finance and operations from public and private companies,ranging from a start-up to multi-national companies with annual revenues exceeding S2,2 billion.Aldworth has most recently held the position of CFO at Phobic,LLC,Shatix Corporation,Jacada,Ltd.and Infer Global Solutions.Aldworth has also served as an advisor to nonprofit organizations including a sizable Property Owner's Association in Florida and a Montessori school in New Hampshire. Chief Operating Officer Aidan O'Donovan will lead the team throughout all stages of the cultivation and dispensing process,O'Donovan has operated the Natural Selections,Colorado facility since 2014 and has extensive experience in in developing,implementing,and maintaining standard operating procedures related to environmental control,lighting mechanisms,media and nutrient additives,post harvest processing and quality control,and optimal strain selection. Based on this experience, Natural Selections has developed its business plan based on three commitments: high-quality products tailored for medical conditions,product transparency, and high standards for cannabis cultivation,and processing. 1) High Quality Products Tailored for•Medical Conditions Natural Selections is committed to providing its patients with high quality cannabis that offers palliative care and pain relief, while reducing the side effbets and symptoms of certain disorders. While the applicant acknowledges the lack of double-blind placebo-controlled tests Illustrating the efficacy of cannabis in treating certain medical conditions, the compuny has taken a scientific approach to strain development, aggregating data based on patient feedback and carefully studying plant and terpenoid profiles, i David R. Goodman, MD, will serve as Medical Director for the business. Dr. Goodman is an 4 { Anesthesiology Specialist based in Newton, Massachusetts. He has more than 14 years of medical experience and is affiliated with Newton-Wellesley Hospital. Goodman will be responsible for developing, organizing, and facilitating education programs for patients, caregivers, board members, and the community at large concerning methods of consumption, camnabimoid profiles,regulation updates,as well as the applicant's services and programs. The company has studied the medical conditions eligible for treatment under 105 CM12 725.000 and intends to provide an array of cannabis products best suited to treat these conditions.Natural Selections will initially introduce an array of strains that have demonstrated success in alleviating symptoms of HIV, AIDS, multiple sclerosis, cancer, epilepsy, and Crohn's disease,and Parkinson's disease, While the following list is not comprehensive, it provides an overview of strains that the company expects to provide in order to offer the best medication for its patients.The company will adjust its product line based on available data and science,regulations,and market demand as the business evolves. Otto#1 Otto#1 Is sativa-doninaut CBD-rich stain popular among patients suffering with Multiple Sclerosis.Patients have noted that this stain was helpfid in mitigating symptoms such as pain, nmscle spasms,lack of motor control,and general fatigue.Anecdotal evidence suggested that patients with Multiple Sclerosis were able to obtain relief very quickly,frequently in under 12 hours after the first use.In addition to Its high level of CBD,laboratory tests revealed that the Natural Selection,Colorado's Otto#1 strain had significant levels of pinene,which is clinically proven to have anti-inflammatory properties. Harlequin Harlequin is a high CBD/lowJHC strain;it is ideal for patients who wish to treat seizures and muscle spasms without experiencing a euphoric THC-induced high.Natural Selections,Colorado has been carrying this strain since 2014.Patients have noted that this strain significantly reduces inflammation and greatly reduces the number of attacks brought forth by Crohn's disease. Blue Dream Blue Dream is a sativa-dominant hybrid that has proven popular among patients suffering from the effects of chernotherapy—chronic pain,nausea, and loss of appetite. It delivers high levels of THC without sedative effects,making it ideal for daytime pain management.The plant has a flowering period of 58 days. Smectrunt#12 Spectrum#12 contains the caturahiuoid THC•V(typically found in African landrace strains like Durban Poison)and has made a dramatic effect in the lives of many epilepsy patients.This strain � was highly effective with a number of children and adults,who In the past were suffering from j over 100 elliptic attacks per day.Many of these same patients have tried the"Charlottes Web" strain,and did not experience nearly as much relief,if any,compared to Natural Selections, Colorado's Spectrum#12 and THC-V combination. f ! t 5 II f " ( 2) Product Transparency The founders of Natural Selections are committed to transparent and ethical business practices and understand that these practices are particularly essential within the medical cannabis industry. Natural Selections will only offer quality,lab tested products. The applicant guarantees that all batches of medical cannabis are tested at a certified laboratory for potency,terpenes,metals, pesticides,and microbials,as well as THClCBD content.The results of these tests will be displayed on the packaging of all products.As per the regulations outlined under 105 CMR 725.105(E),information is placed describing our nutrients,pesticides,ingredients,and recommendations on methods of intake,dosing,batch information and contact information. See Section VII "Best Practices"for more information regarding the Natural Selections' Standard Operating Procedures Regarding Quality Control and laboratory testing. Dispensary agents will be trained to explain the significance of laboratory testing results,so they can make accurate recommendations based on a patient's specific ailments and needs. The applicant will provide extensive educational materials in its RMD as well as on its wcbsite. Its website will have an extensive R&D section that posts information on all strains produced along with current testing results.Natural Selections'wcbsite will also have a research portal that shares reliable medical journal articles from high profile entities such as GW Pharmaceuticals,so qualifying patients and dispensary agents are able to conduct their own research concerning the medicinal benefits of medical cannabis. ti3) Best Practices for Cultivation,Processing,&Manufacturing Natural Selections is committed to maintaining high standards of production throughout all elements of the cultivation and processing medical cannabis.Chief Operating Officer Aldan O'Donovan will lead the team in managing,tending,and cultivating the plants throughout all stages of the cultivation and dispensing process, O'Donovan has extensive experience in in developing,implementing,and maintaining standard operating procedures for cannabis cultivation and dispensing facilities.Natural Selections'Standard Operating Procedures are explained in detail in Section VII"Best Practices&Standard Operating Procedures." The applicant intends to emulate its cultivation strategies at is cultivation facility in Colorado.In contrast to a perpetual harvest cycle,Natural Selections uses a 4-week cycle in which a different flower room is cut down every week.The applicant separates flowering rooms based on the unique needs of each strain group.This strategy prevents the early harvest of immature plants and mitigates many common problems that are associated with stains growing in non-ideal environments.Cannabis grown at the cultivation facilities will be inspected thoroughly to ensure the medicine is free of pathogens and contaminants.Plants will be cultivated with the highest quality,lab tested,state approved fertilizer and pesticides to prevent potential carcinogens and residual contaminants from being consumed.Natural Selections strives to have nninimal impact on the environment and on plants.The applicant utilizes as few chemicals as possible and uses clean salt-based nutrients that are extremely low in heavy metal content.These practices ensure j the overall quality of finished product. Description of project b I Natural Selections identified 23 Elm Street,Watertown,as an ideal location in which to establish its Medical Marijuana Treatment Center. 23 Elm Street is located within the Regional Mixed Use District(RMUD)which allows Medical Marijuana Treatment Centers by Special Permit(Please see the Appendix for the Ordinance Amending the Town's Zoning Ordinance re;Medical Marijuana,Relevant Sections of the Watertown Zoning Ordinance,and Watertown Zoning Map.) This facility is located near a centrally located shopping district in Watertown,on the outskirts of Cambridge,Allston,Brighton,Belmont,and Newton.There are approximately 450,000 residents living within a five-mile radius of the facility,which translates to roughly 2,061 registered patients eligible for medical marijuana based on a proportional ration of total patients currently registered with the Massachusetts Department of Health. 23 Elm Sheet itself operates as 3 standalone buildings,Building 1,Building 2,and Building 3. NS AID has a binding letter of intent with the property owner(Christopher Lucy,Trustee,of 23 Elnr Street Trust)for Building 2,Rear,2,755 square feet of space located within Building 2(the "Project")(Attached _ see Property Photographs/Plan in Tab 3).The Project is set back and almost T _ -y-- completely shrouded from public view, from the right of way f for both pedestrian 1: and vehicular traffic on Elm Street.It sits tucked behind Building 1,which VIEW FROM ELM STREET fronts Elm Street,thus blocking it from direct view.The project is not directly visible from Arsenal or Arlington Street. i The Project contains 8 units of off-street parking to allow patients direct access to services. Deliveries will occur through the rear of the building,with secure off-street loading(which will be staggered and staged with secure unmarked vehicles). The location will be made safe and secure through reinforced construction materials and technology,cameras and remote monitoring,and on-site security personnel.The Project will j include various security and safety equipment and technology,including but not limited to secure sally part,or access control vestibules,computer verified patient or caregiver entrance protocols, and redundant security alarms and controls.In addition all personnel will be trained extensively, i and the operation will frilly comply with Massachusetts guidelines. I Please see the appendix for the proposed site plan for the facility. I Project Timeline 1 7 Natural Selections is highly confident in its ability to exceed the criteria for obtaining a DPH license under Chapter 369 of the Acts of 2012,An Act for the humanitarian Medical Use of Marijuana.Natural Selections has heeded closely to all regulations established under 105 CMR 725.000 and subsequent guidelines published by the Department of Health.Natural Selections understands that it is responsible for remaining in compliance with"Guidance for Registered Marijuana Dispensaries Regarding Non-Profit Compliance"and"Guidance for Registered Marijuana Dispensaries Regarding Background Checks"and has taken every measure to do so. The applicant has been in communication with the Department of Health since June 29,2015 after submitting its initial Application of Intent.Natural Selections has proven its ability to provide additional follow-up information and materiais to the Department of Health in a timely fashion upon request. On July 26,2016,the applicant was invited to submit a Siting Profile to the Department of Health. Natural Selections is prepared to submit its Siting Profile to the Department of Health immediately after receiving a letter of support or non-opposition from the city of Watertown. After its Siting Profile has been reviewed,Natural Selections will expect to receive approval for its Provisional Certificate of Registration.The applicant will then work diligently to provide any additional requested information the DPH requires to issue a Final Certificate of Registration. The applicant is confident that all elements of its business plan are in compliance with the Act and 105 CMR 725,000 and is committed to working with the DPH to receive its Final Certificate as quickly as possible, Natural Selections has allocated 90 days for the construction period.Major construction milestones have been outlined below. When appropriate,these construction processes will occur concurrently.The applicant will work diligently with its Watertown-based team of architects, engineers,and construction workers to ensure that the development of the facility is completed as iquickly a possible. I MIIBstohe> >. ', ;. . •;;; ;;:: : ;l zpect dSttiftDate ;Tiipel?rame(1)ays) Completioti:Dafc Exterior Construction Refurbishing to parking lot 3/1/17 30 3/31/17 Building exterior/facade 3/1/17 30 3/31/17 improvements New construction of loading 3/31/17 60 5/30/17 docks + ( Landscaping and vegetation 3/1/17 60 4/30/17 perimeter Security camera installation 3131/17 I 30 4/30/17 Hrfee•io•Construction: i, i Interior demolition I 3/1/17 7 I 3/8/17 Interior framing I 3/8/17 , 14 I 3/22/17 8 i +i I Drywall 3/8/17 7 3/15/17 HVAC I 3/15/17 ' 30 I 4/14/17 Plumbing and electrical 3/15/17 30 I 4/14/17 Finishing work 4/14/17 14 4/28/17 Installation of furniture& ( 4/14/17 7 4/21/17 fixtures Installation of security systems, + 4114/17 7 I 4/21/17 alarms systems,doors vaults, I I! and cameras t .. i I E 9 Section 11 Security Plan 10 II ( General Security Plan Natural Selections operates in a high-risk security environment and is committed to implementing extensive security measures to protect patients,caregivers,employees,and the general public. Natural Selections has designed an extensive security plan that will comply with all regulations outlined under 105 CMR 725.110,Prevention and deterrence will be achieved by means of physical security prevention measures,electronic security measures,and operational security measures.The applicant is committed to providing extensive training,information,and resources to its employees so they are prepared to prevent,report,deter,and when appropriate,respond to any threat to security that could occur on the premises. This security plan outlines three major tenants of security: • General Security Platt(architectural,electronic,and operational) • Secure Transportation Plan • Anti-Diversion Plan • Anti-Loitering Plan Dan Linskey will lead the Natural Selections team in designing and developing a secure MMTC and cultivation facility. Widely respected for his knowledge of the complexities inherent in law enforcement and homeland security,Dan has also consulted with numerous national and International government agencies on a broad range of challenges, including large-scale event management,crisis leadership,and preparedness and community engagement strategies. Natural Selections intends to design its MMTC based on the security principles of Crime Prevention Through Environmental Design("CPTED"),Concentric Circles of Protection,and Integrated Design.Collaboratively,these security prevention measures focus on evaluating opportunities to deter a threat from entering and circulating within the building envelope.CPTED is a concept that utilizes planned passive resources such as architectural barriers,landscaping,and lighting to reduce the necessity of traditional technical and operational security elements to reduce vulnerability to crime.The key concepts of CPTED include: • Natural Access Control: Use of doors, fences,landscaping,and other man-made and natural obstacles to limit access into the building or other defined interior space • Natural Surveillance:Increasing visibility by occupants and observers (security and staft)to increase the detection of unauthorized individuals or misconduct within a facility. • Natural Boundary Definition:Establishing a sense of ownership by occupants to increase vigilance in identifying intruders.This sends the message that would-be-offenders will be identified. The concept of"Concentric Circles of Protection"is based on varying levels of protection ioriginating at the site perimeter,building perimeter,lobby areas,and interior areas with special control requirements,becoming increasingly more stringent as one proceeds through each level to reach the most critical areas. Intervention zones between each layer of the circle provide opportunities for control,detection,evaluation,and response to undesired activity,intruders or otberunautlnorized individuals. I1 The Integrated Design Philosophy establishes effective security through the integration of electronic systems with architectural elements,enhanced by security staff and procedures.When the integration of these elements is effectively executed,a synergy is created that meets the desired security objective.The premise for using this concept is that architectural,operational and electronic elements must be implemented to complement one another;thereby creating collaboration between them that results in a strong security program.No one element of the group can stand-alone or operate independently and provide adequate protection. Specifics of the elements used include: • Architectural Security measures address items such as perimeter barriers, lighting, critical building services,spatial adjacencies,and control barriers. • Operational Security measures address items such as staff and public access control, staffing,monitoring and administration of systems. • Electronic Security measures address items such as access control and alarm monitoring, video surveillance,and security communications. Security measures for the Natural Selections dispensary consist of both physical barriers and electronic systems that work In concert to provide a robust security program.These measures include: • Secure Door and Window Hardware • Security Mesh • Primary Intrusion Alarm System • Backup intrusion Alarm System • Video Surveillance System i • Access Control System `. • Entry&Exit Door Interlock System Architectural Security Prevention Measures To prevent armed violence, the applicant will focus on implementing measures aligned with 105 CMR 725.110,minimizing undue attention and implementing a redundant system of barriers, perimeter intrusion detection systems,surveillance,and active patrolling, Natural Selections will install security mesh that extends from atop tare tenant partition walls to the roof deck,which will mitigate climbing over the wall from the adjacent tenant space.To minimize perimeter entry points,NS will be wailing over two single metal doors,one double metal door and four metal-fianred windows that exist along the building perimeter,Doors concealed in walls will be securely bolted from the interior side. Security mesh fastened to surrounding nmsomy will secure concealed windows. Security mesh will also be utilized to iharden the perimeter walls of the LAA to deter penetration through its walls. Accessible perimeter doors into the tenant space will be provided with secure locking hardware which will remain secure at all times except when being accessed by authorized persons. One operable perimeter window will remain securely latched at all times.Two fixed windows at i ground level will be frosted or opaque to prevent visibility inside the dispensary from the exterior. All doors will be 18-gauge hollow metal with connnercial-grade I,non-residential locks. Additionally,exterior locks and limited access area entries must be equipped with electric shrike and biometric access hardware and be automatically locking. 1 Electronic Security Prevention Measures 12 i The applicant will implement a number of electronic security measures designed to prevent, deter,and detect unauthorized intrusion,violence,and the use of firearms at the MMTC or related facilities.As per the regulations outlined under 105 CMR 725.110(D),the applicant will implement access control and alarm monitoring,video surveillance,and security conmmanications,utilizing commercial grade equipment. The applicant will ensure all security system equipment and recordings are maintained in a secure location so as to prevent theft, loss, destruction,and alterations,as per the regulations outlined under 105 CMR 725,110(D)(2). Alarm Monitoring Intrusion detection for the Natural Selections dispensary is comprised of"vo independent commercial-grade alarm systems—a primary and a backup—to ensure an intrusion will be detected and reported should it failure of either system occur.The primary alarm system(PAS) and the backup alarm system (BAS)will be installed,serviced and monitored by separate and unrelated security vendors to ensure redundancy. Perimeter detection of an intrusion is provided using door contacts on all operable perimeter doors and windows and glass break detection for all exposed perimeter glass,Interior intrusion detection is provided by motion detection in the sales area,an office and the LAA,In addition to intrusion devices,hold-up/panic alarms are provided at each point of sale register location within the sales area,in each office and in the LAA. Fixed panic alarms are located in areas where incidents would more likely to take place including reception areas,sales areas,storage rooms and staging areas.Employees will be trained at the { location points of these alarm systems. i The intrusion alarm systems will be controlled by noneric keypad arming stations located inside the entry and exit dogs.Keypads will display system armed/disarmed status,status of security devices and any trouble notifications,Authorized users will be issued unique arm/disarm codes to identify which employee armed or disarmed the systems at a given time. As per the regulations outlined tender 105 CMR 725.1I0(D)(1 c),a duress alarm function will be provided at each PAS and BAS arming station to notify law-enforcennent that an authorized user has been forced by an intruder to disarm an alarm system. The PAS and BAS are provided separate detection of intrusion for all perimeter door and window contacts,glass break detectors and motion detector to ensure a device failure on one system will not compromise inclusion detection by the other.Both systems will have backup batteries for continued operation during power failures. Access Control In an effort to mitigate theft and unauthorized intrusion,Natural Selections will keep all cannabis and cannabis products in a limited access area inaccessible to any persons other than dispensary agents,with the exception of displays allowable under 105 CMR 725.105(L)(10).During non- business hours all cannabis will be stored in a locked,access-controlled space in a limited access area within the RMD.The applicant's safe and vault for cash will be located In a restricted access area t i As per 1105 CMR 725,a Limited Access Area means it building,room,or other indoor or 13 Q outdoor area on the registered premises of a RMD where marijuana,MIPs,or marijuana by- products are cultivated,stored,weighed,packaged,processed,or disposed,under control of a RMD,with access limited to only those dispensary agents designated by the RMD. These limited access areas will only be accessible only to specifically authorized personnel, which shall include only the minimum number of employees essential for efficient operation. All limited access areas within the dispensary must be clearly identified with a sign no smaller than 12"x 12"which states:"Do Not Enter—Limited Access Area—Access Limited to Authorized Personnel Only"in lettering no smaller than I inch in height.Each facility must prominently display security system and time-lock safe notification signage. A numeric keypad access control system(ACS)will be provided at the LAA door to limit access those issued a keypad code.Each person authorized to enter the LAA will be issued a unique personally identifiable muneric code,which when used,will be logged by the ACS by user code. The keypad will be managed by a separate controller such that damaging or tampering with titre keypad will not unlock the LAA door.The ACS controller will be located in the LAA and be provided with backup power supply to ensure operation during a power failure. Only limited authorized personnel have access to keys.Only specifically authorized personnel have access to security measures,such as passwords and combinations. Video SurveUlance System The video surveillance system(VSS)is comprised of network-based video cameras and nehvark- based head-end equipment for viewing,recording and playback of video.VSS head-end equipment will be located in the LAA to ensure access is highly restricted.Cameras will be located around the exterior perimeter of the applicant's tenant space to record activity in nearby driveways,parking areas and the building perimeter;at entry and exit doors to record and identify all who enter or exit the dispensary;and areas where controlled products will be stored, processed,handled and sold, The VSS will record cameras for a minimum of 90 days and retain(at minimum)the last 24 hours for imrnediate retrieval and playback.The VSS will to save or-archive video relating to a particular incident under investigation or pending legal/administrative action for as long as necessary and export still images to Industry standard formats.Additionally,the VSS will be provided with all uninterruptible power source for continued operation during a power failure. Door Interlock System An inner and outer door set form a vestibule at the entry and exit points of the dispensary,which are configured similar as a mantrap to ensure authorized persons entering or exiting cannot allow an unauthorized person into the dispensary.The vestibule doors are controlled such that only one door can be unlocked at a time.Doors are controlled by a door interlock controller located in the LAA.Door release buttons are provided at the reception desk for the entry doers and at the sales counter for tire exit doors. To enter,a person must check in at the reception desk. Once properly vetted,the receptionist releases the outer entry door to allow them to enter the entry vestibule. Once inside the entry vestibule and the outer entry door is closed and secure,the inner entry door will unlock to allow them into the sales area.The entry vestibule doors are typically locked when not in use to prevent 1 unauthorized entry or exiting through the entry vestibule. ` 14 I I {f For exiting,a person can press on the exit bar to unlock the inner exit door.Once inside the exit vestibule and the inner exit door is closed and secure,the outer exit door will unlock to allow them out of the building.While the outer exit door is open,the inner door is locked to prevent it from being opened until the outer exit door is closed and secure. Note:These door controls can be overridden as required by life-safety code. The outer entry door is unlocked from the dispensary reception desk to allowing an authorized person to outer the vestibule.Once the outer door is closed, the inner door can be unlocked to allow entry into the sales area.For exiting,the,inner exit door can be opened. Once Electrified locking hardware on each door provides independent control of each door such that when one door is open,the other is comprised of network-based video cameras and network-based head-end equipment for viewing,recording and playback of video.VSS head-end equipment will be located in the LAA to ensure access is highly restricted, Cameras will be located around the exterior perimeter of the Natural Selections'tenant space to record activity in nearby driveways, parking areas and the building perimeter;at entry and exit doors to record and identify all who enter or exit the dispensary;and areas where controlled products will be stored,processed, handled and sold. Operational Security Prevention Measures It is imperative that all employees and departments are committed to upholding the applicant's security policies.The most effective way to ensure the safety and security of employees,patients, and caregivers is utilizing preventative methods. t Natural Selections understands the importance of training dispensary agents to ensure that the they are able to perform tine following: I)execute a])necessary security protocols designed to prevent,detect,and deter violence or armed robbery,2)report suspicious behavior or threats to security,and 3)respond appropriately,utilizing security alarms and notification systems,in an energeney situation. 1) Dispensary agents will be trained to execute all necessary security protocols designed to prevent,detect,and deter violence or armed robbery. Closing& OpeningProeedures The opening and closing periods of the day present high-risk times for armed robbery or unauthorized intrusions.To ensure that all employees and dispensary agents are safe,the applicant will implement the following procedures to be followed at the opening and the ending of each day: • The applicant will ensure that there are two employees present for the opening,closing, and during the operation of the RMD,Upon opening,employees will inspect the business for forcible entry and survey the premises, • Security equipment will be inspected each day,after opening and prior to closing the RMD.This will ensure that the security equipment maintains proper surveillance of the RMD. • After closing,employees will Inspect the premises for persons hiding in the business, near the building's entrance or in the parking lot.One employee will enter the parking lot first,while the other watches the employee enter his or her vehicle before entering his or f her own vehicle, 15 1 Cash Management security Each dispensary agent employee bandling cash must be familiar with the types of related incidents related to cash management and is required to handle cash in accordance with Cash Management and Accounting procedures.Cash must be secured in a biomet is money safe separate from cannabis product.The vault will be kept in a limited access area. 2) Dispensary agents will be trained to repotting suspicious activity,incidents of diversion,or•security failures to the department manager. First and foremost,dispensary agents will only allow registered qualifying patients and personal caregivers authorized by 105 CMR 725,015 and 105 CMR 725,020,and,subject to the requirements of 105 CMR 725.110(C)(4),outside vendors,contractors,and visitors,access to the RMD,Any other individuals will not be allowed within the premises. Department managers shall notify law enforcement when a potential risk is identified.Dispensary agents will be trained to identify suspicious activity from coworkers,patients,caregivers, vendors,as well as unidentified persons.Suspicious behavior could include; 1) Any question regarding cash reserves,closing times,volume in business or sales,the amount of money kept in the RMD, 2) Loitering in the vicinity of the RMD or cultivation facility,or 3) Any questions regarding location of cash or internal security measures. ( Employees will be required to report all security system failures,incidents of diversion,o• infractions to their direct managers hn a ediately upon occurrence.Security system failures could include any alarm activation that requires response by local law enfocemem,video failure,any acts of diversion,any destruction of cannabis in a manner that is not compliant with Natural Selections'waste disposal plan. 3)Cmployees will be trained to respond in any situations involved witb armed robbery at- violence. Employees will be trained to respond appropriately in all emergency situation,specifically in a � situation 1.Upon discovery of a crime,incident of diversion,or breach of security,authorities will be immediately notified with as much information and details as possible. 2.Natural Selections'Management will work with and cooperate with authorities providing any requested information or documentation as soon as possible. 3.An official repot will be provided to the Department of Public Health identifying all marijuana and marijuana product that has been damaged or taken during the event. The report will be given no later than 10 days after the crime transpired,but all efforts will be made to make it as soon as practicable. 4,All documentation related to incident that is reportable pursuant to Massachusetts laws will be maintained by the facility for no less than one year and made available to all relevant authorities upon request. 5.The facility will obtain,at its own expense,a security system audit by a vendor 16 k t approved by the Department of Public Health,on an annual basis.Audit report will be submitted to the Department of Public Health no later than 30 days after the audit is conducted.If issues are identified,the facility will submit a plan to mitigate the concerns within 10 business days of submitting the audit report. Seeuve Transportation Plan The applicant understands the risks presented by transporting medical cannabis and has designed an extensive security plan to ensure the safety of its employees and the City of Watertown. Natural Selections,Colorado has extensive experience transporting cannabis products from its cultivation facility in Boulder,Colorado to its dispensary in Northglenn,Colorado.Natural Selections,Colorado strictly enforces all of its security protocols and procedures and to-date has had no instances of theft,diversion,or armed robbery.Chief Operating Officer,Aidan O'Donovan will work closely with the management and security teams to develop,implement, and enforce all elements of this secure transportation plan. The applicant has designed secure transportation procedures that are highly compliant with all regulations established under 105 CMR.725.110(E), 105 CMR.725.110(1,),and all other relevant regulations.Transportation will only occur between tine following: • Natural Selections' cultivation facility in Fitchburg to its MMTC in Watertown • Natural Selections' cultivation facility in Fitchburg,MA to an ISO-certified, registered lab. • Natural Selections' cultivation facility in Fitchburg,MA to a disposal facility. Cannabis will only be transported from the cultivation facility to the MMTC in secure vehicles. Only DPH-certified dispensary agents will be eligible to transport medical marijuana from the cultivation facility to the dispensary. The agents will receive extensive training to ensure that they are highly familiar with 105 CMR.725.110(E), 105 CMR.725.110(F)and all ofNatural Selections' Standard Operating Procedures regarding transportation. Natural Selections will ensure that each transport vehicle is staffed with a minimum of two dispensary agents.At least one dispensary agent shall remain with the vehicle at all times that the vehicle contains marijuana.Transportation vehicles will be non-descript white vacs with no labels or symbols related to possession or ownership of cannabis or the applicant's business name.Secure transport vehicles will be equipped with file following:a GPS system,heat and all- conditioning suitable for medical marijuana and marijuana products,an alarm system,a dashboard camera,and a video surveillance camera.Each vehicle will also have a Bluetooth phone and a two-way digital radio to ensure that the transportation agent shall have access to a secure form of communication with personnel at the sending site at all times that the vehicle contains marijuana. As per CMR.725.1 I O(E)(6),transport routes will be randomized.The Security Director and Chief Operating Officer must check current road conditions(including weather,traffic,and road closures)and approve the route prior to the transportation.The Security Director will be responsible for monitoring"security risk geographies"by monitoring local crime rates and political and legal conditions that could cause additional risks for cargo theft.Any vehicle accidents,diversions,losses,or other reputable incidents that occur during transport will be reported to the Department and local law enforcement within 24 hours,pursuant to 105 CMR 725.110(F). t 17 Guldellnes for ShippbigID'ansport Manifests Prior to transporting any cannabis or cannabis products,an authorized agent must perform the following steps: a. Weigh, inventory,and account for on-video all marijuana to be transported prior to its leaving the origination location; b. After products have been released for transport,an authorized agent at the cultivation facility will log into MJ Freeway to develop an electronic manifest connected to the transport for retention by the origination location.The transportation agent will carry a copy Of this manifest with the products being transported.When developing the manifest,the agent will select the packages that are being shipped from the"Inventory Control"option.Once the items are selected,the agent will record all the following information: • Names and registration information for transportation agent. • Receiving licensed entity's name,address,and registration number. • Date and timcstamps related to the transport. • Description of the marijuana or MIPS being transported, • Weight of marijuana or MIPS being transported. • Mileage of the transporting vehicle at origination,at its destination,and(ire mileage back to its original destination. • Signature from the cultivation agent creating the package as well as the transportation agent.The transportation agent must sign a disclaimer starting that he or she is not authorized to handle cannabis or cannabis-infused products beyond the secured transport, o Upon arrival at the Natural Selections MMTC,an authorized dispensary agent must re-weigh,re-inventory,and account for on video all marijuana transported, within eight hours nfter arrival at the destination RMD, The agent will log into MJ Freeway and compare the electronic manifest to the manifest presented by the transportation agent.The following infomation will be checked and confirmed: • Names and registration information for transportation agent. • Receiving licensed entity's name,address,and registration number. • Date and timestamps related to the transport. • Description of the marijuana or MIPS being transported. Weight of marijuana o•MIPS being transported. Mileage of the transporting vehicle at origination,at its destination,and 'tlre mileage back to its original destination. • Signature from the cultivation agent creating the package as well as the transportation agent. i The agents will be responsible for documenting and reputing any unusual discrepancy in weight or inventory to the Department and local law enforcement within 24 hours. Upon arrival at mr ISO registered lab, an authorized laboratory employee agent will sign the manifest produced to the manifest delivered by the transportation agent to acknowledge receipt. Natmnl Selections will retain all shipping manifests for no less than one year and make them s available to the Department upon request. 18 The applicant will also Implement and enforce the following secure transportation procedures: • Any vehicle used to transport marijuana most have a secure, locked storage compartment that is part of the vehicle. The transportation manager must ensure all transportation vehicles are compliant prior to authorizing a transfer to the vehicle. • All products shall be suitably packaged in accordance with 105 CMR 725,105(G)to protect it from alteration,contamination,damage during storage,and handling and shipping.All products will be packaged in tight,light-resistant containers and stored at controlled room temperature(unless otherwise indicated).All medical camrabis products will be separated based on the specific product and placed in a secure,tamper evident bag.Each tamper evident product bag is placed in a commercial grade bin,which is then closed with a lid that is secured on all four comers with tamper evident zip ties.The secure bin ensures that no product is handled or tampered with during the delivery: Cannabis products will be not visible from outside the vehicle. • Once the shipping bin is inside the vehicle for transport,the bin is strapped down using commercial grade straps to ensure the bin experiences no movement during transport. Before the transportation agent leaves the licensed premise with the medical cannabis product,a member of management inspects the transportation vehicle for proper security of the bin. • Any vehicle transporting marijuana shall travel directly to the receiving RMD and shall not make any stops.In case of an emergency stop,a detailed log must he maintained describing the reason for the event,the duration,the location,and any activities of personnel exiting the vehicle. • Natural Selections will inform the appropriate law enforcement authorities and the Department within 24 hours if any of the following incidents occur during transportation of cannabis, (a)Discrepancies identified during inventory, diversion,theft, loss, and any criminal action involving the RMD or a dispensary agent; (b)Any suspicious act involving the sale,cultivation,distribution,processing,or production of marijuana by any person, (c)Unauthorized destruction of marijuana; (d)Any loss or unauthorized alteration of records related to marijuana,registered qualifying patients,personal caregivers,or dispensary agents; (a)An alarm activation or other event that requires response by public safety personnel; (f)The failure of any security alarm system due to a loss of electrical power or mechanical malfunction that is expected to last longer than eight hours;and (g)Any other breach of security. The applicant will implement the following policies for its transportation agents: Each dispensary agent shall carry his or her Department-issued registration card at all ! times when transporting madjuana and shall produce it to the Department's authorized I � i 19 I representative or law enforcement official upon request in compliance with 105 CMR.725.110(12)(9). • Each transportation agent is required to double check for forms of identification approved by the Department before transporting any medical cannabis, • All authorized transport agents arc required to have a current,valid government-issued driver's license.Prior to transport,a copy of the driver's license is made and filed under the shipping licensee's folder in the inventory control system for compliance.Valid means the license is not expired,revoked or voided in anyway,Temporary identification is not an acceptable form of identification. • All transportation agents will be required to wen plain clothing with no reference or symbols related to possession or ownership of cannabis.The applicant will provide each transport agent with a plain white t-shirt to wear as a uniform after he or she has completed the training process. Natural Selections will also implement and enforce the following security procedures related to secure transportation: • All transport vehicles are registered with the state as required by law.Prior to transpmt,a photocopy of the registration is attached with the electronic manifest for proof of registered authorized transport in the event the driver is pulled over by a governing authority.hi addition to photocopying the registration,it is scanned into the file of registered drivers related to the associated licensed entity's profile on the applicant's inventory control network,or if it is a driver employed directly by the applicant,in their employee file for compliance.In addition to having the registration,all license plates display the required sticker identifying the vehicle as properly registered.Management confirms the stickers are in place on the license before releasing items for transport. • All vehicles that are used for transport are required to be insured by law.To ensure this happens,before all transports,a photocopy of all required paperwork is exchanged between the dispensing and receiving licensed entity.In addition,that copy is scanned into the associated licensed entity's profile on the applicant's inventory control network for reference for each transport.Management verifies that a copy has been inade and filed for compliance.This includes calling the company providing insurance to confirm that the vehicle owner,has kept up with all necessary payments for the insurance to remain valid. All of these documents are available for the Department to review upon request, • All vehicles will be well maintained and serviced regularly. Anti-Diversion Plan Natural Selections understands the high risk associated with cultivating and dispensing medical cannabis,which is a controlled substance with many incentives for diversion.The applicant intends to implement extensive security measures to prevent cannabis from being diverted to non- registered patients. The applicant is committed to curbing diversion and the distribution of cannabis and cannabis products to other states by implementing the following procedures and protocols: 20 f t • Preventing employee theft,diversion,and pilferage by enforcing strict chain of custody and inventory control procedures,building a strong employee culture with a shared sense of responsibility,and implementing and patrolling a state-of-the-art security and surveillance system. • Preventing patient diversion by means of enforcing purchasing limits, educating patients on the dangers of illegal distribution,and maintaining extensive inventory distribution records. • Preventing theft via negligent or improper waste disposal.The applicant is committed to monitoring,recording,and securing the destruction of all cannabis,cannabis products, and cannabis plant material in an adequate manner pursuant to 105 CMR 725,105(J). Preventing employee theft,diversion,and pllferage Natural Selections understands that the majority of financial and product loss in the cannabis industry occurs due to employee theft.There are many ways employees could divert cash or product from a cannabis business that could lead to revenue from the snle of marijuana going to criminal enterprises,gangs,and cartels, e Pilferage.Employees can report lower harvests and steal cannabis flower. • Theft.Employees can steal cash or finished products from the vault. • Sales manipulations.Employees can provide unauthorized discounts or manipulate the Point of Sale database • Assisted Robben•fes.Dispensary employees could provide internal security protocols and infomntion to assist in robberies of cannabis businesses. f The applicant is committed to curbing diversion and preventing revenue from the sale of cannabis from going to criminal enterprises,gangs,and cartels trafficking through the following procedures: I • Building a strong employee culture with a shared commitment to anti-diversion policies. • Enforcing strict chain of custody and inventory control procedures,and • implementing and patrolling state-of-the-art surveillance system. Strung Employee Culture The applicant understands the Importance of creating a culture in which employees have a shared commitment to preventing diversion and are strongly incentivized to report any incidents of diversion or suspicions behavior.Key personnel will be responsible for training all staff and will encourage a culture of responsibility in all efforts to prohibit improper diversion of cannabis products. At its current facility in Colorado,Natural Selections has allocated substantial resources towards implementing a strong business culture with clearly defined expectations and guidelines for employees.The Natural Selections'executive management team strives to build a personal relationship with every employee and create a transparent environment with a shared feeling of responsibility towards the applicant's core values.The applicant prioritizes the following strategies in creating a strong employee culture,so employees feel woven into the business's culture and highly committed to the future of the organization: 21 l i s Transparency.Employees will be encouraged to offer feedback and strategic feedback, regardless of their level or position in the applicant. • Benefits,trailing,and paid-time off.The applicant will offer each employee benefits, paining,and opportunities for career advancement. • Employee Empowerment, Natural Selections is committed to building a culture centered around employee development and education.Employees will be encouraged to solve problems,ask questions, manage tasks,and provide input and suggest new policies and processes • Organizational design,The applicant will design thoughtful strategies for communication,performance indicates,performance evaluations,and division of responsibilities that will be Implemented at all levels of tine business. Implementing business practices to create a strong culture and empowering environment for employees is highly correlated with the prevention of turnover and in tarn,reduces theft and diversion.Industry security experts suggest that employees who are able to view their position as a career,rather than a short term retail job will be more invested in ensuring the success of the applicant and less willing to risk being terminated and losing their benefits,Natural Selections, Colorado has had great success with these practices at its current facility in Colorado,The applicant has been extremely successful at encouraging employees to report incidents of diversion,as well as combatting theft and pilferage. The applicant is committed to establishing a culture of responsibility among its employees regarding the diversion of medical cannabis and cannabis products.Natural Selections believes that it is imperative that all departments and managers partake in some elements of supply chain management and anti-diversion tasks.All administration,dispensary,cultivation,manufacturing, . . r and operations personnel will be encouraged to offer recommendations to the Chief Operating Officer regarding anti-diversion policies and other strategies. Employee Screelling Natural Selections has extensive experience in building a strong business culture and understands that it begins with the initial hiring process.The Director of Human Resources will develop and implement the procedures to recruit,screen, interview,hire,in-process and integrate new employees. i Human Resources will develop and implement the procedures to recruit,screen,interview,hire, in-process and integrate new employees.Such procedures will include,but are not limited to: 1) Reviewing resumes and requiredjob applications for qualified candidates including those with relevant experience and those with complementary skills and a strong potential for growth. 2) Performing and recording reference checks on qualified candidates including: 1. Verification of address and education, 2. Verification of former and Current employment, 3) Recording information from forcer supervisors on the candidate's performance,if available. 4) Performing a criminal background check oil the selected candidate to determine eligibility and to identify any other possible disqualifying items. ( i 22 The Human Resources team will conduct background checks on all candidates prior to final hiring decision to verify the information provided by the candidate and identify any high-risk attributes.The team will ensure completed and signed releases are obtained to allow the applicant to conduct criminal and credit background checks As per CMR 725.030(A),dispensary agents must be overthe age of21 and must have not been convicted of a felony drug offense in the Commonwealth,or a like violation of the laws of another state,the United States or a military, territorial,or Indian tribal authority.Any dispensary agent that is discovered to have a history of theft or diversion based on a Criminal Offender Record Information report must not be given access to medical cannabis products. Management personnel will undergo more extensive screening and will be required to provide fingerprinting and submission for a Level It background check. The Human Resources team is responsible for archiving and safeguarding all employee data and confidential information.Additionally,all employees will sign a waiver advising them about the 24-hour surveillance program and that they will be video recorded in accordance milli state and local laws and regulations. L'nrployee 7t•aining Progrma The applicant has created an extensive training plan designed to prevent, deter,and detect theft and diversion from employees.This training program is also designed to foster a culture of responsibility and to encourage employees to report any suspicious behavior from patients, caregivers,and fellow employees.Each employee will be required to successfully complete this training prior to any specified job training.Managers will be required to complete additional training to understand more,specifically how,to uphold our anti-lbeft and anti-diversion plan as part of the initial grow agent training. 1) Identifying regions ofRMD and facility New employees will be given a tour of the facility and will be provided extensive training regarding the identification of areas of prevention throughout the RMD and cultivation facility. All employees will be expected to understand and identify limited access areas,restricted access areas,and storage areas located within the cultivation facility and RMD • Access control effectively limits the ability for employees to move freely throughout the facility. o As per 105 CMR 725.004,a Limited Access Area means a building,room,or other indoor or outdoor area on the registered premises of a RMD where marijuana,MIps,or marijuana by-products are cultivated,stored,weighed, packaged, processed,or disposed,under control of a RMD,with access limited to only those dispensary agents designated by the RMD.Restricted access areas o Limited access areas are for all licensed grow agents,whereas restricted access areas are for management personnel only. o 'these limited access areas will be accessible only to specifically authorized personnel,which shall include only the minimum number of employees essential for efficient operation. This aspect of the plan diminishes the capability of u wrongdoer to identify vulnerabilities and plan an illicit activity. The e rant entry alert feature that cues the Security Director of attempts at 23 unauthorized envy also serves to highlight potentially suspicious behavior on the part of individual employees and may prompt a follow-up interview and corrective paining. 2) Sest Practices The paining will also cover operational practices designed to prevent and deter diversion and prevent the sale of cannabis from going to criminal enterprises,gangs,and cattels.All employees will be required to understand that these methods of preventing diversion will boa shared responsibility among all departments. Given their close contact with the cannabis plants,grow agents going through management training are expected to receive additional anti-diversion training.During this training program, employees will spend throe days learning about chain of custody and the inventory management system(described in detail under"Inventory Management&Chain of Custody"), filling out internal documents to make the proper citations,how to properly record every transition of the plant growth,and how to report incidents to a manager. Managers are held to higher standards than other employees due to their responsibilities related to security checks.Managers are shadowed fbr a one-month period as they perform anti-diversion activities,such as performing internal document audits,checking the video surveillance system for suspicious activity,and proper enforcement of all anti-dfversion practices.At the end of the month,based on observation and evaluation of duties,all members of upper management decide on the new manager's qualifications,Any new manager who does not meet all qualifications is assigned to another member of management for additional shadowing or kept as a standard grow agent. f The following outlines general best security practices that the applicant will implement to prevent diversion,which could lead to the cannabis products or revenue going to criminal enterprises, gangs,and cartels: • Operating,opening,and closing procedures are strictly enforced,Two employees are required for opening,closing,and operation of all RMD facilities. o An employee must inspect the business for forcible entry before entering the business and survey the premises before admitting others. o Security equipment mnst be inspected after opening and prior to closing to ensure the necessary surveillance of all operating activities. o At closing,employees must survey the premises for someone hiding in the business,near the building enhance,or parking lot. o At closing,one employee must enter the parking lot first while the other watches and enter their vehicle before the other employee enters their vehicle. • Grow agents train as a group on inventory audits.Each agent rotates from a previous section to ensure the validity of numbers during every count.For example,weekly plant i checks are expected to maintain records and ensure compliance,During this time,a grow agent Is assigned to a room in the warehouse to record each plant tag,stage of growth and location,in order to audit against the electronic inventory system.The following week,a different grow agent is assigned to that room and does inventory.Similarly,with daily vault/safe checks,a grow agent takes inventory of all weights with a different grower auditing the vault/safe the following day.This method of taking inventory prevents opportunity and motivation for diversion. 24 t • Employees will abide by restricted use of electronic devices(cell phones,music players, cameras,etc.)within the MMTC and the cultivation facility.Personal cell phone use will be limited to the break area and if carried,kept in an applicant issued,enclosed pouch, suspended on a neck lanyard that will also display the employee I.D. • Employee bags will be restricted in size and subject to random security checks by on site security personnel. • The general manager shall regularly review information from external sources including law enforcement,trade and patient associations,advocacy groups,and patients and caregivers related to factors that may impact the incentive for diversion(i.e.system-wide marijuana shortages,changes in law,rapidly increasing patient registrations,etc.). If the general manager concludes a change in diversion risk based on environmental factors,a risk mitigation plan must be developed and implemented. • Each day,the security team will review security footage from the previous shift to ensure theft has not taken place.Employees will be informed that they are accountable for every aspect of production that they are involved in,and that it is recorded by the video surveillance system. 3) ReporlingDfvension All employees will be trained to report any diversions,theft,or suspicious behavior to their supervising manager.Grow agents will have additional responsibilities regarding auti-diverslon - , practices.I9n addition to maintaining the chain-of-custody as previously outlined,grow agents will be responsible to identify and report any diversions or infractions related to chain of custody, improper storage,or misuse of equipment. These employees will be trained extensively in regards to identifying diversion issues in a classroom setting,During the initial training,all prospective grow agents will be given a demonstration and tested to identify the following infractions: • Cannabis or cannabis product in an open access area, • A break in the chain of custody • A missing element to production documentation, • An unlabeled door sign, • An uncetifred scale. To pass this exam,grow agents are expected to correct all of these errors.This training will ensure that employees understand how to identify how and where to properly secure cannabis, what needs to be completed with documentation,what type of access should be.identified using the door sign,and how to check if a scale is certified. After receiving this training,employees will be instructed regarding how to repot a diversion. Reporting incidences against other employees as they occur is expected to ensure that the applicant's anti-diversion plan is working effectively. • If a grow agent has committed an act of diversion or infraction in the chain of custody,fie or she will be expected to report the incident report directly to his or her manager and , reconcile the error. 25 ( • If a grow agent discovers that a fellow employee has committed an act of diversion or infraction in the chain of custody,the grow agent shall be expected to report to the manager on duty.The grow agent will be responsible for reporting all aspects of diversion applicable to the situation,such as lack of documentation,theft,lack of secured storage,etc. The manager will then proceed to communicate with the negligent employee and take the necessary action. • If a grow agent recognizes that there is any discrepancy in inventory in the cultivation, harvest,or phase,he or she will be expected to report to a manager as soon as it has been identified,as well as docnment the miscount on any internal inventory documents. • If a grower agent notices cannabis or cannabis-infused product improperly stored,the grower agent is expected reconcile the error,store the product safely,and notify his or her manager, During this course,grow agents are informed of potential possible consequences related to not following standard operating procedures that can contribute to diversion. o A grow agent who has committed a first time offense for breaking the chain of custody or not reporting an incident of diversion will be issued a strike,His or her respective manager shall be required to complete a write-up citing the details of the infraction,the time and date of the occurred infraction,and the necessary actions taken to correct the error.The grow agent will also be expected to recomplete the initial employee training program. o An employee with three write-ups for the same reason is terminated based on lack of understanding of compliance. The following infractions will provide grounds for immediate termination: o Proven theft via video surveillance o improper storage that results in au infraction against the business license, o Using a fellow grow agent's identification on any internal documents. i Chain of Custody&Inventory Management Natural Selections will emulate its current inventory control system at the Natural Selections, Colorado facility in Colorado,which entails a series of comprehensive policies and procedures to ensure a clear chain of custody and accountability for all aspects of inventory and recordkeeping. All plants, raw materials, finished products, and byproducts will be tracked and properly stored throughout the course of cultivation,processing,and dispensing. i The applicant will use MJ Freeway's inventory control system that tracks plants from seed to final product via a chain-of-command barcode system. This system is highly compliant with the regulations defined under 105 CMR 725.105(G)(3) and (4) and incorporates technology to provide tracking mechanisms for each plant in a harvest, raw materials, finished products and byproducts as well as policies and protocols for chain of custody. This inventory system will i chronicle every step, ingredient, activity, transaction, and dispensary agent, registered qualifying patient,or personal caregiver who handles,obtains,or possesses the product. 26 Chain ofCustwly Procedures • Chain of Custody tracking begins as soon as a seed or cutting is planted, When the seed or cutting is planted,a grow agent is responsible for taking a count of the physical inventory and will record the strain,date, count,and the grow agent who completed the task. • Upon determination of viability as a seedling,each plant will have a plastic,tamper- evident tag with an individual Radio Frequency Identification Device tag with a unique barcode. a. Each Radio Frequency Identification Device tag comes with the ability to scan or input the unique code into the inventory control system and view all associated activity and employee specific identification.The tag allows strain-specific plants with the same harvest date to be grouped to create a batch. b. After the initial tag is assigned, the plant will always be identified with its barcode, strain name and associated grower agent. Once a tag is assigned, that code cannot be reassigned to a different plant or package. If the tag becomes unattached or misplaced in any way, it is replaced Immediately. Additionally, when the plant is created, a grow agent will be responsible for inputting genetic lineage,variety of cannabis and projected potency. c. All tags are attached at the base of the principal stem to the vegetative plants in a way that enables fixture growth but is not able to be removed without cutting.The zip ties used to attach tags to plants have a locking mechanism that grower agents are required to inspect and confirm secure as part of the standard operating procedure for'assigning plants a code, • As the plant moves throughout the growth phase,the grow agents will be responsible for recording all transitions.The tracking system must reflect the exact plant count and composition of the facility at all times,Transitions are any step in the growth at- production process where a trackable item(plant,raw material,product)is physically moved from one controlled area to another. In addition to tracking movements via the barcode,a floor supervisor from the initiating point must escort the trackable item and notify the Security Director prior to initiating movement. Security personnel will cue surveillance systems to monitor the transition until the floor supervisor at the destination point receives it. • Each plant that is scheduled to be harvested on the same day is assigned to a stain- specific batch.For example,all Blue Dream plants,planning to be harvested on 10.15.17 are grouped together with a harvest batch identification,which includes a 3-letter code followed by the date(BLDI0.15.17).Other plants being harvested that day that are not Blue Dream will be coded according to their strain. • All RFID tags are to remain with tine plants,at all times during the harvest and drying process.All tags shall be grouped together by stain and hung on a hanger at the front of each batch in the dry roon.Afierward,all tags should then be placed In a 1-gallon zip- lock bag and stored with the"Pre-Processing"buckets. As soon as the physical harvesting is complete,the grow agent will enter this information into the inventory management system and include the measurements of plant weights. I � 27 f ( • Grow agents will be responsible for all of the plants selected following data entered under the plant's RFID tag number in the inventory management system: I) Harvest Name: A six digit date,Location,Tray number/letter,and the strain. 2) Weight:Using the information recorded oil the Harvest Info sheets during the harvest,add the total sum of"Wet Weights"to the total sum of"Waste Weights"to find the total son of all plant weight for each strain. Take the total stun of all plant weight(for that given strain)and divide that number by the total number of plants harvested(for,that given strain)to generate the weight of each individual plant. 3) Drying Room: Select the dry room that they are to be moved to. 4) Harvest Date: The actual date the plants were harvested(should match the date designated in the Harvest name). • Creating Packages After Harvest:After the plants have been harvested,processed,and consolidated into one(1)pound increments for the material,packages need to be created prim to the transfer procedare.The grow agent will be responsible for inputting the following information. I) Open tile"Harvested"tab. 2) Click the"Create Packages"located on the left. 3) Once this tab is open,select the batch associated with the plants being packaged within the"Batch"drop down menu. 4) Select the item to be packaged within the"Item"drop down menu. Select the name of the strain, 5) Enter the weight of the package being created.Packages should never exceed 450 grams, G) Select"Grams"in the unit of measure drop down menu located to the right. 7) Select the"Package Tag"that will be issued to the package. Once the tag is printed,tear the tag at the seams and place the bigger portion of the tag on the outside of the package and the smaller potion(Retail Tag)of tag inside the package. 8) Enter the date the package Is being created.Click the green"Create Packages"icon. • Reporting Waste and Finishing a Batch: Once all product within the batch has been processed and all packages are created click the"Report Waste"tab to enter and record all the appropriate weight by entering the following: • Select the"Batch"that the waste is associated with. • Enter the total sum of"Waste Weight"associated with that strain which was recorded or the day of the harvest. • Select"Grams"in the unit of measure drop down menu on the right. • Enter the date that the weight is being reported • Click tine"Report Waste"icon. • Select and highlight the batch that is complete. Click the"Finish Batell" icon located under the"Harvested"tab. ( t 28 ( Natural Selections will stay up-to-date on all developments within the cannabis industry that could affect the incentive for diversion, (Le,system-wide cannabis shortages,changes in law, rapidly increasing patient registrations,etc,)Based oil these developments, the applicant will evaluate and revise its security policies to mitigate the risk for specific incidents of diversion, Natural Selections is also committed to building strong relationships with local law enforcement agencies to combat trafficking both interstate and internationally.The applicant will take its status as an RMD seriously and will be committed to reporting any diversions or other reportable incidents to the Watertown Police Department within 24 hours of occurrence. Preventing Patient Diversion The Applicant is committed to preventing the diversion of cannabis products from the registered patients of its RMD.Each patient or caregiver who has received a registration card has already endured a process to determine that they are fit to purchase products sold at Natural Selections' dispensary.Prior to obtaining a registration card,each registered patient must submit all attestation that he or she will not engage in the diversion of cannabis and that the patient understands that protections conferred by the Act for possession of cannabis for medical use are applicable only within Massachusetts in accordance with105 CMR 725.015(A).Natural Selections will apply a number of additional measures to prevent the risk of diversion of cannabis products by registered patients, Dispensing Limits Nahum Selections will also work to ensure patients do not divert cannabis obtained through its RMD by ensuring that patients only procure the amount of cannabis legally prescribed.This will ensure that patients do not have access to more cannabis than necessary based on the diagnosis provided by registered physicians and that patients do not have access to additional cannabis that could be sold or distributed to minors or other non-registered users.Natural Selections is aware that cannabis is more likely to be diverted if the patient has more medication than necessary to treat his or her medical condition.The applicant will limit the amount of cannabis dispensed to each patient as per the regulations defined underl05 CMR 725.105(F)(2); • For a registered qualifying patient certified for less than 60 days,the amount of cannabis dispensed,including cannabis contained in MIPs,shall be no more than the appropriate proportion of a 60-day supply,as defined in 105 CMR 725,004(e,g.,a patient certified for 15 days may receive up to 2.5 ounces of cannabis). 9 For a registered qualifying patient certified for 60 days or longer,the amount of cannabis dispensed,including cannabis contained in MIPs,shall be no more than a 60-day supply in each 60-day period as defined in 105 CMR 725,004(e.g.a patient certified for 90 days may receive up to ten ounces in the first 60 days and five ounces in the remaining 30 days,while a patient certified for 180 days may receive up to ten ounces in each 60-day period). e For a registered qualifying patient whose certifying physician has determined that he or she requires a 60-day supply in excess of 10 ounces in accordance with 105 CMR 725.010(1),the amount of cannabis dispensed,including cannabis contained in MIPs, pursuant to 105 CMR 725.105(F)(2)(a)or(b)shall be adjusted accordingly. { 29 i The Department of Public Health has defined a 60-day supply of cannabis to be, 10 ounces,or the equivalent in other forms(such as edible cannabis-infused products).To determine what the equivalent amount of a 60 day supply is for cannabis concentrate(oil)and resin(hash)DPH has determined that cannabis plant material will,on average,yield 15%of its weight in concentrate or resin.Thus,to determine the equivalent weight of a concentrate or resin,multiply the weight of the oil/resin by 6.7 to determine the dry weight equivalent. Education Natural Selections will implement policies informing and educating its clients related to the risks of diverting and distributing cannabis to non-registered patients. Fach patient will be required to complete a training orientation session before purchasing medical cannabis from Natural Selections' MMTC. This orientation will help patients understand how cannabis affects the human body and the risks associated with use. The orientation will also cover potential legal and financial risks for not abiding by Massachusetts state law. During this orientation,each patient will be given educational materials with information regarding the criminal dangers that are associated with distributing,selling,or diverting medical cannabis purchased at tile RMD.These educational materials will be designed to create a shared sense of responsibility among employees,patients,and caregivers to prevent the diversion of the RMD's products to other states.Patients must understand that their registration as a patient may be impacted by any incident of diversion;they will also be subject to legal consequences. Dispensary agents will also ensure that patients are informed of the risks of disposing cannabis or cannabis products through traditional waste disposal methods.Patients will be informed that should they need to dispose of unused,excess,or contaminated cannabis,they should return it to the Natural Selections RMD,Natural Selections shall destroy it and maintain a written record of such disposal,which shall include the name of the supplying registered qualifying patient or personal caregiver if applicable as per 105 CMR 725.105(1). Distribution Inventory Tracking Natural Selections will retain and maintain detailed records of patients and caregivers who procure medical cannabis at its dispensary,Despite previously stated security measures,the applicant understands that it cannot control the behavior of its patients outside of the RMD and will implement thorough tracking measures to provide an additional layer of security to prevent diversion fi-on patients,which could potentially lead to the diversion of cannabis to other states, The applicant will utilize its distribution inventory tracking system to track all distribution, including the quantity,name,potency,batch number,and lot number of each cannabis product delivered.Searchable patient records are tied to their certifying physician in the point of sale system to ensure that upon request,all records can be quickly located and delivered to certifying physicians.'fhe following procedures provide an outline of distribution inventory practices that the applicant will implement: • All distribution records include the name and address of the recipient of medical cannabis product. 1 , 30 ( • All distribution records include the quantity delivered to the qualifying patient. Once a week, key personnel of the licensed business audit all distribution records for the previous week. The audit assures that the quantity delivered is recorded on each distribution record. All quantities delivered to the qualified patient are secured, tamper evident and easily searchable through digital and physical distribution records. Each employee uses his or her own login to assure accountability. • All distribution records include product name,potency, batch number and lot number of medical cannabis product. Once a week, key personnel of the licensed business audit all distribution records for the previous week. The audit assures that the product name, potency, batch number and lot number are properly recorded on each distribution record. All product names, potency, batch and lot numbers are secure and searchable t1n'ough digital and physical formats. • The applicant will retain all production and distribution records of each batch and lot,and daily checklists to maintain proper uniformity. Records of production and distribution of medical cannabis product are gathered from the inventory tracking system and are stored on premise in a locked filing entity only accessible by key employees. Daily checklists are completed each day nod stored on premise in a secure filing entity only accessible by key employees. If Natural Selections begins to suspect that a physician,patient or caregiver Is distributing cannabis to non-registered users,the applicant will immediately inform the Watertown Police Department and other low enforcenent if necessary.Natural Selections will take Its role as a RMD seriously and will work to ensure that the products sold in their dispensary do end up being diverted to other states. Secure Waste Disposal Methods The applicant understands the risk associated with negligent waste disposal methods,which can potentially lead to diversion and distribution to non-registered patients outside of the state.The applicant will emulate its waste disposal strategies at its current facility in Colorado,which have been designed to prevent theft from occurring after the necessary disposal of cannabis plant material,damaged plants,and contaminated cannabis products.The applicant is committed to monitoring,recording,and securing the destruction of all cannabis,cannabis products,and cannabis plant material in an adequate manner compliant with 105 CMR 725.105(J). The applicant is committed to educating all grow agents on the importance of proper waste disposal methods and the risks and dangers associated with not following these procedures.The cultivation manager will be responsible for upholding all waste management politics and performing regular checks to that no incidents of diversion have occurred.Grow agents will receive extensive training regarding waste disposal methods and will be expected to uphold these j policies as well. All medical cannabis waste will be processed at the cultivation facility. See Waste Disposal Plan in Section VII:'Best Practices&Standard Operating Procedures" for a detailed discussion on the waste disposal polices that the applicant plans to implement to prevent the risk of waste theft and diversion. Anti-Loitering Plan Natural Selections understands the risks presented by minors loitering outside of its prenises, especially in regard to law enforcement's first priority of safety related to cannabis.The applicant 31 i ( is committed to preventing the illegal distribution of cannabis to minors and intends to implement a number of preventative design,surveillance,and operational strategies to deter loitering.The applicant is committed to forming partnerships with surrounding businesses,members of the community,and local government officials to create an environment surrounding its MMTC and ancillary facilities in which loitering problems do not arise. Natural Selections will implement security measures in regard to the following categories that will identify and prevent the loitering of minors in a legal and non-11nrcatening manner: 1) The Location of the Premises 2) The Design of the Premises 3) Video Surveillance and Anti-Loitering Techniques 4) Marketing and Advertising The applicant understands that even the strongest preventative methods may not deter certain types of individuals from loitering.To this effect,the applicant is committed to forming partnerships with the Watertown Police Department as well as other local agencies and organizations to implement strategies to solve any potential loitering or security issues that arise. Security personnel will be on the site of the RMD at all times to remove individuals not complying with Act 105 CMR 725.000,or other offending behavior. The Location of the Premises The applicant has chosen a location for its MMTC that is highly compliant with 105 CMR } 725.11 O(A)(14).The MMTC,which Is located at 23 Elm Street, is not situated within 500 feet of a school,daycare center or any facility in which minors commonly congregate.Its neighbors will be industrial or commercial businesses and food establishments seeking to serve the employees of these industrial businesses.Natural Selections specifically chose this location,as it is a significant distance from any area that would be considered to be at risk for the congregation of minors. • The applicant will work closely with surrounding businesses to ensure that they are informed of all preventative design and surveillance systems that the applicant will need to implement for security and anti-loitering purposes. • Currently,there are no benches,chairs or other areas of"rest"that may attract loiterers or cause minors to congregate within the immediate vicinity of the RMD.The applicant understands the increased risk of loitering and congregating around structures,such us benches,awnings that offer protection from weather,and public ashtrays.The Applicant will work closely with local government officials to ensure that no such objects will be added to the immediate premises surrounding the RMD, • The applicant will also ensure that there is no litter or garbage in the area surrounding its storefront.All of its waste will be securely disposed in an adequate manner compliant with 105 CMR 725.105(J).The Applicant's Waste Disposal Plan is described in detail in Section VII:"Best Practices&Standard Operating Procedures." The Design of the Premises The applicant will implement appropriate design strategies and surveillance systems that will identify and prevent loitering among minors.The Applicant intends to integrate semnlessly into 1 32 its surrounding area and is aware that loitering or security issues could Impact other local businesses as well. The applicant understands that many of the most common issues with loitering around retailers are caused by a lack of defined boundaries.! When designing the premises of its MMTC,the Applicant will ensue that its dispensary has proper boundaries and borders in order to minimize the potential of loiterers.Natural Selections is committed to creating natural vegetative boundaries around the perimeter and if necessary,will entertain the idea of installing a fence or secure perimeter to limit access. Lighting is a critical design measure to prevent loitering.The surrounding streets around the MMTC have sufficient lighting to illuminate the MMTC's parking lot and surrounding area,'file MMTC itself will be illuminated with motion-sensor lights,as indicated on the Site Plan. Lighting will be consistent to reduce contrast between shadows and illuminated areas.The lighting system will use timers or photoelectric cells to turn lights on at dusk and off at dawn.The system will also use motion sensors to turn lights on when motion is detected but will avoid lighting areas surrounding the MMTC so that people should not use at night.If the loitering of minors becomes an issue,the applicant will consider installing"pink lighting,"which has been utilized by police departments across the world to deter minds from congregating. Natural Selections is committed to complying with regulations set by 105 CMR 725.105(L) in regard to creating a safe,neutral exterior that in no way promotes or advertises the sale of medical cannabis. • The Applicant will create and maintain a neutral design for its exterior,logo,and signage. s The signage outside of the dispensary will only be illuminated 30 minutes prior to the i. dispensary's closing and there will be no neon signage that may attract potential loiterers. Landscape Design Natural Selections has consulted an architectural landscape designer to determine how to best create an external environment that is inviting to patients but is a deterrent to loiterers and minors. The applicant understands that loiterers commonly seek out overgrown foliage,vegetation, bushes or other points that obstruct them from view in order to engage in illicit activities.Natural Selections will consider planting"hostile vegetation"in the landscape areas surround theRMD to create all unreceptive atmosphere that does not interfere with a client's experience."Hostile vegetation"refers to plants such as crown of thorns,Russian olive,red barberry,or Siberian pea shrub.The applicant will also plant vegetation,with prickly leaves or thorns like bougainvillea in areas immediately surround the MMTC. The applicant will be committed to eliminating any existing vegetation that blocks a loiterer from the dispensary's video surveillance cameras. Video Surveillance&Anti-Loitering Techniques Natural Selections will implement an extensive security surveillance camera system to detect and deter loiterers.Many security experts claim that the presence of a camera is often sufficient to r t Penton,Mike.CPP,PSP,Paragon Securih,in Toronto.ASIS baemational. 33 deter loiterers;however,the applicant will also consider implementing a number of other creative design efforts to detect and deter minas from surrounding the RMA. Yideo Surveillance System Natural Selections will utilize its security system to identify minors and prohibit loitering in the area.The video surveillance system("VSS")will record outside of the dispensary in addition to Inside the premises,Natural Selections will ensure that potential loiterers are aware that a video surveillance system is recording their actions and will eliminate any foliage or other coverings that could conceal a person from the surveillance system. The video surveillance system is comprised of network-based video cameras and network-based liead-end equipment for viewing,recording and playback of video.VSS head-end equipment will be located in the Limited Access Area(the"LAA")to ensure access is highly restricted.Cameras will be located around the exterior perimeter of the NS tenant space to record activity in nearby driveways,parking areas and the building perimeter;at entry and exit doors to record and identify all who enter or exit the dispensary;and areas where controlled products will be stored, processed,handled and sold. The VSS will record cameras for a minimum of 90 days and retain(at minimum)the last 24 hours for immediate retrieval and playback.The VSS will to save or archive video relating to a particular incident under investigation or pending legal/administrative action for as long as necessary and export still images to industry standard formats.Additionally,the VSS will be provided with an unintert uptible power source for continued operation during a power failure. i The applicant will employ a contracted security service.These security personnel will be responsible for to detecting, observing,recognize,identify,deter,report,and when appropriate, reputing,loitering to the local law enforcement agencies, siguage Posting"no loitering"signs has also been shown to have the desired effect in preventing minors from loitering in an area.While businesses or private residences may not always be able to remove persons loitering in an area,placing clear"no loitering"signs can often have the desired effect of minimizing loitering.In general,most minds are not aware of loitering laws and therefore simply installing these signs or having an employee regularly walk around a building's exterior can deter minors or other from residing in an area. An i-LoiteringAevlees Natural Selections took great precautions when considering the location for its MMTC to prevent loitering.However,the applicant will consider implementing additional preventative measures should loitering become an issue around the premises of the MMTC.Natural Selections understands that creating an atmosphere that is unappealing to minors will also assist in efforts to prevent the illegal distribution of medical cannabis to minors.Therefore,the applicant will do everything to ensue that loitering does not occur. ( i 34 f" { • Playing classical music,'Security officials have reported that classical music can be a strong deterrent for the loitering of minors in a particular area.If the Applicant notices that minors have begun to loiter around the dispensary, they will consider installing a protected speaker that will be mounted at least 10 feet above grade.These speakers will Play elassienl music or other sounds that have been shown to discourage minors from loitering in mr at ea. • The Mosquito'Natural Selections will stay abreast on new developments and devices designed to discourage loitering.If the applicant faces challenges with minors loitering outside of its MMTC or in the surrounding premises,they will consider purchasing a security device known as"The Mosquito,"which schools and other spaces use in areas where minors tend to congregate after hours.The Mosquito is a sound device emits an unpleasant but benign high-pitched sound that only young people can hear.This noise is not audible to older people due to presbycusis:an age related hearing loss,which gradually prevents people from hearing high frequencies as they get older.This device has been used to both keep young people safe and to prevent minors from congregating in unsafe areas. 7 . 2 Journal of Popular Musio Studies,Volurne 19,Issue A,Pages 342-358 s The Mosquito Th,Copyright©2012.Moving Sound'fech. 35 f Section III Business & Marketing Plan 36 I i Business Operations and Marketing Plan Natural Selections is an established organization committed to providing access to quality natural medicine on the basis of science research and development.Natural Selections,Colorado has emerged as a leading cannabis organization in Colorado with a strong reputation for its commitment to utmost quality care for its clients,Natural Selections has set forth the following objectives in establishing its organization: 1) A compliant operation in good standing with regulators, 2) Safe,consistent,and effective products of the highest quality, 3) Commitment to serving and educating patients and caregivers,and 4) Commitment to scientific research and development. Natural Selections will emulate Natural Selections, Colorado's marketing strategy and build a strong brand rooted in education, community involvement and participation, and a rigorous commitment to scientific research and development. The applicant is committed to utilizing logos, signage, and packaging that are compliant with 105 CMR 725,105(L) and reflect its commitment to natural,quality products.Natural Selections intends to integrate seamlessly into the Watertown,Massachusetts community and has identified charitable partners to partner with to support the community and improve the surrounding areas. Logo,Signage,&Packaging The applicant is committed to avoiding any images or branding strategies that would seek to influence or attract consumers from the general public.Natural Selections will only target medical patients with the conditions eligible for treatment under the current Massachusetts legislation.The applicant is committed to utilizing tasteful branding strategies that are aligned with its values and compliant with 105 CMR 725.105(L).The applicant has chosen Its name, "Natural Selections,"to reflect its commitment to providing high quality,natural plant-based medicine to its patients.The Natural Selections brand reflects the medicinal chemical compounds found in cannabis plants,rather than the cannabis plant itself,As per the regulations cited under 105 CMR 725.105(L)the applicant will not utilize medical symbols,images of marijuana,related paraphernalia,and colloquial references to cannabis and nnarijuann in any of its branding materials.The company also will never produce any items for sale or promotional gifts,such as T-shirts or novelty items,hearing a symbol of or references to marijuana or Mips,including the logo of the RMD. Signage The applicant will ensure that external signage will only display the registered company name to assist qualifying patients in locating the business. As per 105 CMR 725.1OS(L),the cultivation facility will not display Natural Selections' name.The applicant will ensure that all medical marijuana,products,and associated products are not visible to a person front the exterior of the RMD facility and all external signage is in compliance with 105 CMR 725.105(L). Packaging Natural Selections will invest in packaging based on brand reliability,transparency and quality that is In compliance with the regulations outlined under 105 CMR 725.105(B).Each product will 37 i f` { be contained in simple packaging that is opaque and child proof.Ito the interior,there will be a label describing nutrients,pesticides, ingredients,and recommendations on methods of intake, dosing, batch information and contact information.All products also musthave labels on them, detailing the potency,the types of chemicals used in cultivation and other information. Bdrrcallon In lieu of traditional business marketing and advertising strategies,the applicant will utilize extensive educational materials,seminars,and campaigns to educate patients regarding the use of medical cannabis.Natural Selections will begin its marketing efforts with a grassroots campaign to educate patients about the effects of medicinal cannabis,methods of consumption,as well as caunabinoids and their associated benefits. The applicant's website will have extensive information about Natural Selections'mission, research,strains,and testing results from registered labs.Registered patients and caregivers will be able to access a list of current cannabis stains and products available at the MMTC.In compliance with 105 CMR 725.105(L)(5),the list will not include prices. Prices will be available on a secure website or on printed menus to]'registered patients and caregivers,The company will also provide an extensive database with links to articles from trusted sources such as PubMed and GW Pharmaceuticals about scientific development in the cannabis field.The team has strong relationships with cannabis-related research groups throughout the country and will stay abreast regarding developments in the field. Natural Selections' website will also contain specific information about cannabinoids and their associated benefits.Natural Selections acknowledges the lack of double-blind placebo-controlled tests illustrating the efficacy of cannabis in treating medical conditions.However,the applicant is aggregating data based on patient feedback and carefully studying plant and terpenold profiles to provide its patients with as much information as passible.Natural Selections will refrain from making any statement, design,representation,picture, or illustration related to the safety or efficacy of marijuana unless supported by substantial evidence or clinical data with reasonable scientific rigor,which shall be made available upon the request of a registrant or the Department. Natural Selections has allocated a sufficient budget to invest in Search Engine Optimization to ensure that qualified patients are able to access their content on the web.The applicant will also invest in written materials and handouts to educate employees and patients on methods of consumption,dosage,and types of cannabinoids and their associated effects.The applicant is committed to providing the tunics(quality care to its patients and educating employees and patients on all potential side effects. The educational materials will provide information on the following: 1) Methods of cannabis consumption rithaling cammbGs Patients may elect to Inhale cannabis by packing a small amount of dried flower into a pipe or rolling paper or utilizing a vaporizer. Patients will be advised to begin with a portion of the prescribed dose of cannabis and then, if necessary, increase the amount while taking note of how the medication affects their body, Patients should note that they may experience side effects such as coughing and irritation of the throat. Patients will be informed to use caution 38 f fF { when inhaling cannabis and to try a different product or strain of cannabis if they experience any negative side effects. When inhaling cannabis • Take short,shallow breaths • Slowly increase dosage and keep note of how the product interacts with the body Orallj,Atlndrtistered Ctttnt(tbls-hefttsed Products Consuming cannabis-infused products affects patients differently than inhaling cannabis. These products can affect patients differently depending on their weight, metabolism, diet/nutrition, and experience or history of cannabis use, The applicant will recommend that when consuming food-based cannabis, tinctures, or capsules,patients begin by coisuming '/4 of their recommended dosage.Beginning with a portion of the recommended dose Is the best way for a patient to learn how a strain of cannabis or a specific food-based product interacts with their body, After an hour, the patient can increase their dosage in increments remaining aware of the effects.If a patient feels any negative side effects they can try a different product or strain of cannabis that may result in less side effects.Employees will make this information clear and available to each patient. Topical& Transdertnal 7),eatmeut of Cannabis Topicals and transdermal methods are often chosen by patients who want the therapeutic benefits of marijuana without the cerebral euphoria associated with other delivery methods, Cannabis- . . ' infused lotions,salves,oils,sprays,and other transdermal methods of relief work by binding to a network of receptors called C132,These topical and transdermal treatments can be applied directly to the skin. 2) Dosage The employees will help the patient determine the correct dosage based on the prescription from the patient's medical pmetitioner and the patient's experience with cannabis,Tine employees will provide the following general recommendations to each patient: • Start slowly. It is recommended to begin by consuming a small portion of the prescribed dosage and to monitor how cannabis interacts with the body. • fnnhaling Cannabis.Wait between short inhalations for a few minutes to observe the strength of the product.Begin with of prescribed dose and note how the product . affects the body. • Edible products.When caring cannabis or consuming camrabis-infused products, allow the product an hour to interact with the body before it begins to take effect.Wait four hours before taking a second dose.Patients who are new to edible products should begin with a dose that is less than 0.5 till to gauge how the product affects their body. • Determine dosage amount based on prescription and the nrg of THC in each product, Divide the product up accordingly to tine prescribed dose.If it is your first time using the product divide the dosage into of the prescribed amount in order to gauge its effects, t ` 39 ! e Self titration.Self-titration is the best way to determine the best product and dosage. When using a new product begin with a low dosage,less than the prescribed amount, and see how it interacts with the body.Always take note of the environment,method of consumption,and amount consumed in order to determine side effects and how cannabis affects the body. The applicant will also offer educational materials on the following subjects:cannabinoids and their associated benefits,cannabis side effects&safety,biochemistry and physiology,and nutrition/diet Commitment to Rigorous Scientific Research The medicinal uses for cannabis plants remains largely undiscovered. While Natural Selections acknowledges the lack of double-blind placebo-controlled tests illustrating the efficacy of cannabis in heating certain medical conditions,the applicant has taken a scientific approach to strain development, aggregating data based on patient feedback and carefully studying plant and terpenoid profiles.Natural Selections believes that rigorous scientific testing should be the base formula for all future development.The applicant is commitment to producing strains with the presence of cammbinoids including THC,CBD,CBG,CBC,and THC-V.' Natural Selections is committed to a rigorous testing policy and has established partnerships with certified laboratories to gain an understanding of the catmabiimid profiles and terpene levels in all produced strains and cannabis-infused products.Additionally,the applicant utilizes an IIPLC to isolate cannabinoids to produce ratio-specific products. Natural Selections understands that each individual's body physiology is unique and certain products and strains l affect patients' in different ways.There is little known research behind CBG, CBC and several other compounds that could lead to treatment for other ailments. Similar to the unknown cannabinoids,terpenes,which are unsaturated hydrocarbons, are found within the essential oils of the plant and vary depending on strain, have been associated with medical benefits.The applicant will not restrict its research to cannabinoids and is committed to performing extensive research and testing on terpene profiles as well. Natural Selections is committed to sharing its scientific research with its patients, caregivers, and all members of the community. The research team will work closely with the Community Outreach Director to coordinate the publishing of its research through its website, blog, and printed materials. The research teann and Community Outreach Director will also organize ongoing community events and dialogues to provide transparency and knowledge about cannabis with the community. Commitment to Quality Care The applicant understands that a strong brand begins in providing utmost quality care to its patients.The team hopes that Natural Selections can be instrumental in building a strong cannabis industry in Massachusetts,where patients are guaranteed safe access to medication and education. The core of the applicant's branding strategy lies in building strong relationships with patients and caregivers.The applicant believes in personally interacting with all of its patients and caregivers and helping design treatment plans that are uniquely catered to them, 40 Natural Selections has considered its commitment to Its patients through the design process of the MMTC.The applicant will invest in a spacious and inviting design to ensure that patients will have sufficient time and space to make their decisions. The applicant will employ enough dispensary agents to ensure that each patient leaves the dispensary after a positive personal encounter and a strong plan to utilize the cannabis and cannabis infused products safely.Each dispensary agent will be trained to ask certain questions to understand the patient's objectives and experience in previously using cannabis. Dispensary agents will offer each patient a wealth of information regarding the available cannabis strains and cannabis-Infused products,camnabinoids and their associated benefits,risks and adverse side effects associated with cannabis,and various methods of consumption.The dispensary agents will also inquire about patients' nutrition,diet,and lifestyle to ensure that the recommended consumption method and dosage is appropriate.All dispensary agents will be trained to explain the potency of different products and recommend that the smallest amount possible should be tested initially and increased conservatively until the desired effect is achieved. In an effort to execute its commitment to quality care,the applicant will hire a Director of Patient Affairs to interact with patients and caregivers The Director of Patient Affairs will oversee all employees working in the RMD and be responsible to maintain accurate records of patients identification and registration documents,manage scheduling patient t•affie flow,answer phones and respond to patient and caregiver inquiries. Natural Selections has an open policy with all clients and will welcome constructive criticism to encourage positive change throughout the cultivation facility. t Community Involvement Natural Selections plans to build collaborative relationships with state and local governments to ensure a seamless integration into the community it serves.Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local organizations and non-profits that promote public health within Watertown,Massachusetts. Natural Selections takes a compassionate approach to providing medical cannabis, and is specifically committed to serving the veterans, elderly people, and low-income patients suffering from medical conditions. the applicant intends to establish a subsidized distribution network for low-income patients in Watertown,Massachusetts.Natural Selections will provide medical marijuana at reduced cost, or free, when an individual is a recipient of MassIlealth, or Supplemental Security Income,or the individual's income does not exceed 300%of the federal poverty level, adjusted for family size. Patients who demonstrate verified financial hardship will fill out an application and be marked in our patient database as eligible for reduced cost marijuana for medical use. The business's team members will also organize community outreach efforts to create a safer, cleaner city as well as provide transparency about their operations and education about the responsible use of medical cannabis. i • Educational Seminars.The applicant has spent a substantial amount of time in Watertown and understands the public health challenges that the community faces. Natural Selections is committed to ethical and transparent business practices and will work closely with the community to provide education on the benefits and risks f associated with cannabis use,Natural Selections will hold regular seminars about 41 ( scientific research related to cannabinoids and their associated benefits,as well as proper and responsible use of cannabis.Natural Selections is also committed to working with city of Watertown to provide public health educational programs geared towards education and prevention of HIV/AIDS and substance abuse: o IIIV/AIDS Educational Prevention Workshops, In the past few decades, medical marijuana has become an increasingly common prescription for HIV/AIDS patients as they attempt to manage their symptoms.Nearly one in three HIV/AIDS patients turn to cannabis to ward off pain,nausea,appetite loss,cachexia,and emotional decline.Natural Selections,Colorado has worked with many I-IIV/AIDS patients at its current facility in Denver,Colorado and understands the devastating impact that this disease can have on families and communities.Natural Selections will hold regular community educational seminars for HIV/AIDS patients and community members to discuss prevention techniques.This educational seminar will be designed to significantly reduce risk behaviors among people who have been diagnosed with HIV to help ensure they do not transmit the virus to others. o Substance Abuse.Natural Selections is committed to implementing a public health program to prevent and beat substance abuse.This substance abuse educational program will be closely linked to the aforementioned program geared towards HIV/AIDS prevention.The applicant hopes that substance abuse education programs will be helpful to individuals and decrease the public health threat to the community. 42 Section IV Financials 43 Capital Expenditure &Project Costs Natural Selections estimates that it will require approximately $3,601,373 in funds to secure final licensing from the Department of Public Health, build out and equip its facilities, and cover the operation's pre-operating expenses and burn rate. First,the applicant has incurred a number of pre-operating expenses associated with the City of Watertown RFP process and the Deportment of Public Health licensing process.The applicant also expects to spend an additional$50,000 in fees to the Department of Public Health after its Siting Profile is approved and it moves towards its Provisional Certificate of Registration.These fees and expenses will total approximately$81,500. The applicant has worked closely with a number of Watertown-based architects,engineers,and land surveyors to create site plans,floors plans,and land surveys to ensure that the operation is feasible and will be,compliant with all zoning regulations. The applicant has also hired a legal team, security team, and a cannabis application/compliance regulation expert to assist with the RFP process.These professional services will total approximately$63,500, Natural Selections has secured a lease on a warehouse at 23 Elm Street in Watertown, Massachusetts, to use for its MMTC. To date, the applicant has paid$24,810 on rent and option payments for the facility. The applicant will continue to make a monthly rental payment of $8,270 on the facility to maintain the lease. This will amount to approximately$57,890 until the applicant begins occupying the building. Once occupancy begins, the monthly rental payment will be accounted for under"Working Capital to Cover Burn Rate."This payment is illustrated on Schedule B: "Pre-Operating Cash Flow.' Natural Selections does not intend to build out the whole facility immediately,but will make a number of leasehold improvements to ensure that it is a safe, secure and inviting space for registered patients and compliant with all regulations outlined wider 105 CMR 725.000. Based on estimates from local architects and construction j teams, these leasehold improvements will come to approximately $440,000, Tine applicant will !, also incur insurance costs for the construction period,totaling approximately$6,000 over a three- month period. Once Natural Selections is occupying the building, insurance costs will be accounted for under Working Capital Costs. The company has also secured a lease on a warehouse based in Fitchburg,Massachusetts to use as its cultivation facility and manufacturing/processing lab. The applicant will need to make a 10% down payment of$300,000 to be able to purchase the facility. Once the facility has been purchased,the applicant will build out approximately 8,000 square feet of plant canopy space; based on the market analysis, Natural Selections anticipates that this will be sufficient plant canopy to meet the demand of medical patients for the first three years of operation. The approximate costs for the first phase of the build out, which encompasses electrical upgrades, HVAC architectural drawings and designs, construction and building costs, fire suppression, plumbing, electronic safety and security, and contractor's fees and insurance, will conic to $1,042,948. Although the bulk of the capital required will be allocated for build out costs, the company also anticipates spending a large portion of its budget($450,013)to equip the first phnse of its entire cultivation facility.The applicant intends to replicate its cultivation techniques and strategies utilized at its facilities in Denver,Colorado.While the following list is not exhaustive,it provides an overview of the equipment and supplies that the company will need to purchase in order to launch its initial cultivation operations: t 44 i =CrtirlY�rroNrsQr�l�biCnr - _ TOTez gasz' Growing Equipun cut --- DE 1000w $72,000 8 Bulb T5 $6,667 CO2 Titan Burner $2,667 Dehumidifiers $26,667 10 Ton HVAC $80,000 14"Vortex Fan/Filter $4,667 8"Vortex Fan/Filter $6,667 Exterior HEPA Filter $833 16"Oscillating Fan $5,333 Light Hangers $13,333 Clone Equipment Clore Trays $267 Clone Dome $200 Water Equipment 10 Gallon Pots $3,333 2 Gallon Pots $1,333 .25 Gallon Pots $667 Hydrologic RO system $17,333 1000 Gallon Reservoir $2,533 100 Gallon Reservoir $1,667 50 Gallon Reservoir $833 Drip Lines/Hosing/Water Supplies(including installation fees) $14,000 Other i Flood Tables $37,000 Drying Room $3,333 Ali,Dueling $6,667 Environmental Controllers $16,000 Sanitation Supplies $2,667 Trimming Equipment Trim Pals-Trim Machine $7,680 Trimming Scissors $11,960 Trim trays&work station $8,000 Paclmging Equipment Cordless Burcode Scanner $3,232 Straight Razor Blades&Holder $400 NTEP Certifled Scale with O.lg Precision $7,600 Berkley Tee Tool 50 lb Digital Fish Scale $1,600 Security Equipment Security System $30,000 Vault/Safe $20,000 Office Equipment TV $600 PC or Mae Work Station $1,000 Zebra Label Printer $499 Workstation Chairs with Casters $75 Work Tables&Desks $200 Office Supplies $500 Secure Transport Vehicle $30,000 TOTAL $450,013 d � 45 t The applicant will also purchase furniture,fixtures, n safe, a vault,and security cameras for the MMTC, which will come to around $70,000. The applicant will also purchase equipment to establish its manufacturing/processing lab, including a Supercritical CO2 extraction machine and other processing/lab equipment,which will come to$107,914. Lastly, the company has also allocated fiords to cover pre-operating expenses, which include pre-operating marketing expenses, pre-operating payroll, and working capital to cover the applicant's burn for the first few months of operations before the company turns profitable. Based on the applicant's extensive design/development experience, these pre-operating expenses will total roughly$962,799, For a detailed list of Capital Uses,please see Schedule A"Watertown RMD Project Costs"and Schedule B"Watertown RMD Pre-Operating Cash Flow"in the Appendix. 46 Revenue& Operating Expense Pmjee ions Natural Selections has utilized data from other medical cannabis markets to estimate how many patients will sign up for the medical cannabis program over the course of the next five years. According to reports from the Massachusetts Department of Public Health, there are currently 31,116 qualified and registered cannabis patients within the state of Massachusetts. There are 32,966 people currently living in Watertown, which translates to roughly 1S1 registered patients based on a proportional ratio. Natural Selections does not anticipate that its entire patient base will come from the City of Watertown. The applicant has secured it lease on a facility near a centrally located shopping district in Watertown, on the outskirts of Cambridge,Allston,Brighton, Belmont, and Newton. There are approximately 450,000 residents living within a five-mile radius of the facility,which translates to roughly 2,061 registered patients. The Department of Public Health projects that 2% of the resident population in Massachusetts will qualify for and benefit from medical cannabis. Capturing tills segment of the patient population will take time to ramp up. Based on a ramp-up analysis of patient populations in Colorado, 'Arizona, s and Oregon, 6 Natural Selections anticipates that there will be approximately 9,000 registered patients living within a five mile radius of the facility by 2019. The applicant estimates that approximately half of these patients will choose to purchase cannabis from a Medical Marijuana Treatment Center in their respective cities,which decreases Natural Selections'potential patient base to 4,500. The applicant is preparing to develop its business operations under the assumption that approximately 90% of medical patients will demand raw cannabis flower, while 10% of patients will demand concentrates or infused products, based on capture rates from other states.'As per (tie regulations, infused products will include infused oils, waxes, ointments, salves,tinctures,capsules,suppositories,dermal patches,cartridges,and edibles. Monthly Demand in Watertown,Massachusetts 4W, -- -! ,I Active Cardholders in Region of I 2,679 3,600 4,500 6,578 7,549 MMTC Monthly Flower Demand(Pounds) I 151 203 I 253 370 425 MmuhlyConcenhateDemand 1,076 1,446 1,807 2,642 3,032 (Groans) i 4"Medical Marijuana Registry Program Statistics May 31,2015."Colorado Department of Public Health ? and Eavironnnenl.May 2015. 5"Medical Marijuana Annual Report A.R.S§36-2809."Arizona Department of Health Services.January 201 G 6"Oregon Economic and Revenue Porecast."Office of Economic Analysis Department of Administrative Services.Volume XXXVI,No.2.June 2016. ,( 7"Colorado Department of Revenue Annual Report."Colorado Deparhnent of Revenue.June 2015, i 47 Naarvl Selections Market Capture 33,33% I 28.57% 25.00% I 20.00% I 20.00% Note: These assumptions are based on the assumption that the average medical patient demands 28.3495 grams of ranv flower or 4.016 grams of concentrate per month. This is based on comparative consumption numbers from Colorado. The applicant has prepared forward-looking financial statements, basing its projected revenue on its this market analysis and its projected operating expenses and payroll on data points gathered from Natural Selections,Colorado's facility in Denver, Colorado. Natural Selections understands that the City of Watertown and surrounding municipalities are undecided in regards to how many letters of support/non-opposition they will issue.Further,the applicant is still unsure as to how many Registered Medical Dispensaries will received approval from the Department of Public Health.The applicant wants to ensure that all registered patients will have access to sufficient cannabis and that there will be no market shortages, especially in the first year of operations. Therefore, the applicant has created its projections under the assumption that they will be the only licensed facility In Watertown for the first year of operations, In subsequent years, the applicant anticipates that the DPH will issue additional licenses and its business's market capture rate will decline. The applicant will be prepared to expand or scale back its operations based on the presence of other dispensaries as well as the evolution of patient registration and demand. Based on this current market analysis,after the cultivation facility has been established and the plants have moved through vegetative and flowering cycles, Natural Selections will produce approximately 50 pounds of raw flower per month for its first year of operations.The applicant will also produce 11 pounds of trim (or small bud)from its harvest that will be utilized to make cannabis-infused products. Based on these assumptions, the applicant expects to net$303,824 in Gross Revenue per month in Year I for all of its products, including accessories. Natural Selections estimates that market demand will ramp up in Year 2; even though the market may be more saturated and the wholesale price will decrease, the applicant's gross revenue will jump tip to $333,586. As previously stated, Natural Selections is a non-profit entity and is highly committed to contributing to the Watertown economy. The applicant intends to allocate 2% of its gross revenue for charitable contributions and to subsidize cannabis products and up to 6% of the MMTC In a Community Host Agreement for the City of Watertown to use at its discretion. Based on current financial projections, the subsidized income distribution network and community host agreement total approximately$24,306 per month in Year I. If the annual Community Host agreement payment does not exceed $200,000, Natural Selections will provide the city with an additional year-end payment as per tine proposed Community Host Agreement. The applicant is budgeting for Cost of Goods Sold associated with cultivating cannabis,such as the mortgage for its cultivation and production facility soil and medium, CO2 equipment, growing supplies, nutrients, power/electricity, and direct wages associated with production. These costs will increase as a function of the applicant's plant canopy and harvest and will begin to accumulate more revenue. Once the facility has begun harvesting, Cost of Goods Sold will total around$79,420 per month in Year I and will jump tip to$87,505 in Year 2. The applicant will incur a number of fixed operating expenses including dispensary rent, a monthly payment to the City of Watertown to offset any social issues presented by the project, property management fees, liability and property insurance, point of sale system, security monitoring,and interact and cable;these expenses will be subject to inflation but will otherwise 48 remain fairly flat as the business expands, The business will also incur monthly fees for professional services, including legal, lobbying, and marketing and advertising,that will come to approximately S55,000 per month witli slight variances. Additionally, the applicant has considered its fixed payroll schedule for executive management, administrative, and operating staff members when calculating its projected EBITDA. Payroll and benefits, which include social security, Medicare, worker's compensation, and health insurance,will amount to$68,142 per month, The applicant expects to hicur a burn rate in its fist three months of operations while the first cycle of plants are moving through the vegetative, flowering, and curing phase, The applicant will be responsible for operating expenses, like rent, consonables, and payroll before it has harvested its first crop.The burn fate will annount to around$487,312 for the first three months of operations, After the applicant is harvesting a crop of flowering plant each month, Natural Selections will be earning approximately $70,990 in EBITDA per month for the remainder of operational Year 1. This will vary slightly month-to-month as inflation calculations will cause operating costs to rise. Given that Natural Selections is a non-profit, the applicant will recycle all profits back into the business to increase its charitable contributions or scale the operations. For a full overview of the RMD's projected financials, please see Schedule C: Monthly Income Statement and Schedule D: Annual Intone Statement in the Appendix. ! i 49 1 Section V Benefits & Effects on the City of Watertown i 50 { Fiscal& Community Hmpact on the City of Watertown Natural Selections is committed to benefiting the City of Watertown through community and fiscal impact.The applicant's COO,Aldan O'Donovan,grew up in Massachusetts,and understands firsthand the economic hardships the state has experienced as a result of deindustrialization and the financial crisis.The applicant will be committed to contributing to the Watertown economy by providing residents of Watertown with full-time jobs with competitive salaries,healthcare,and benefits.'rhe applicant is also willing to offer up to 6%of annual revenue from the MMTC for the City in the form of a community host agreement. Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local civic and community organizations that promote public health within the Watertown community.Additionally,Natural Selections will establish ongoing community dialogues and seminars in order to provide transparency about its operations and education about the responsible medical use of cannabis.Natural Selections will also sponsor community health programs geared towards preventing substance abuse and HIV/AIDS. • Employment:Natural Selections seeks a seamless integration into the Watertown community and intends to hire local residents with a proven work ethic and interest in educational development, as well as experience and skills relevant to the required duties of each position.Initially,the applicant will hire 41 full-time employees to fully staff its cultivation,dispensary,and processing/manufacturing operations.Direct wages for i employees involved in the direct production of cannabis and cannabis-Infinsed products will conic to$257,079 in the first year,this will include cultivation and processing managers,as well as 10 grow agents.Fixed salaries and benefits for the executive f t management,administrative,and operating teams will come to$817,700 in Year 1.These wages and salaries will increase as the business grows.Nahnral Selections will offer Its employees competitive salaries and will provide benefits,such as healthcare,social security,workers' compensation,life insurance,and a 401IC plan. • Community Host Agreement: The applicant is committed to improving the economy of Watertown and is willing to negotiate a community host agreement with the City,Natural Selections will be willing to offer up the greater amount of$200,000 or 6%of the gross revenue generated annually from the MMTC to be used at the City's discretion.The applicant has also set aside$100,000 annually to offset any additional or unforeseen issues that may affect the city,such as additional demands on local law enforcement agencies,increased use of City infrastructure,orthe need for additional City infrastructure,employees and equipment.This agreement could provide the city with an additional$1.1MM in income over the course of Natural Selections' first three years of operations. • Community Charitable Contributions:Natural Selections plans to build collaborative relationships with state and local governments in order to ensure a seamless integration into tine community it will serve,Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local organizations and non-profits that promote public health within Watertown,Massachusetts.Team members will also organize community outreach efforts,such as trash pick-up events,to create a safer,cleaner city as well as provide b ansparency about their operations and education about the responsible use of medical cannabis. 51 i i • Subsidized Distribution Network:Natural Selections' values are aligned with the initial principles outlined under Chapter 369,An Act for the Humanitarian Medical Use of Marijuana.Natural Selections takes a compassionate approach to providing medical cannabis and is specifically committed to serving veterans,elderly people,and low- income patients suffering from medical conditions.The applicant understands that many patients suffering from medical conditions are burdened with physician and hospital bills and are unable to pay market rates for medical cannabis.This network is outlined in detail below. o Educational Seminars.Natural Selections is committed to ethical and transparent business practices and will work closely with the community to provide education on the benefits and risks associated with cannabis use.Natural Selections will hold regular seminars about scientific research related to cannabinoids and their associated benefits,as well as proper and responsible use of cannabis.Natural Selections is also committed to working with city of Watertown to provide public health educational programs geared towards education and prevention of HIV/AIDS and substance abuse: • HIV/AIDS Educational Prevention Workshops, In the past few decades,medical marijuana has become an increasingly common . prescription for HIV/AIDS patients as they attempt to manage their symptoms.Nearly one in three HIV/AIDS patients turn to cannabis to ward off pain,nausea,appetite loss,eachexia,and emotional decline. Natural Selections,Colorado has worked with many HIV/AIDS patients at its current facility in Denver,Colorado and understands the devastating impact that this disease can have on families and j communities,Natural Selections will hold regular community educational seminars for HIV/AIDS patients and community members to discuss prevention techniques.This educational seminar will be designed to significantly reduce risk behavior among people who have been diagnosed with HIV to help ensure they do not transmit the virus to others 8 • Substance Abuse.Natural Selections is committed to implementing a public health program to prevent and treat substance abuse.Substance abuse is considered a public health risk in the city of Watertown.This substance abuse educational program will be closely linked to the aforementioned program geared towards HIV/AIDS prevention. Effective substance abuse treatment has been linked to help users stop injecting with needles,which eliminates the risk of HIV transmission through injected drug use,The applicant hopes that substance abuse education programs will be helpful to individuals and decrease public health threats to the community. Subsidized Distribution Network m"High-Impact HIV Prevention:CDC's Approach to Reducing 1-11V Infections In the United States. { Centers for Disease Control and Prevention:August 2011. 52 i ( Natural Selections is deeply committed to ensuring access to medical cannabis to patients that will benefit the most.As a non-profit organization,the applicant's proceeds are reinvested directly into patient services, community activists,and Its subsidized distribution network, First and foremost,Natural Selections understands that patients are seeking treatment for medical conditions and need to have access to consistent,high-quality cannabis oil a sustainable basis in order to experience the associated benefits.Natural Selections,Colorado has earned a reputation among patients and clients in the Denver metro area for providing high-quality cannabis and cannabis products at its dispensary at extremely reasonable rates.The applicant will draw oil this extensive cultivation experience to ensure that production practices are cost-effective without sacrificing quality.Natural Selections is confident its experience in cannabis cultivation will be invaluable in its first few years of operations to ensure best practices,while minimizing common errors associated with environmental control,lighting mechanisms,soil and nutrient additives, and post harvest processing.Inexperience with these processes frequently contributes to the loss of crops and subsequent higher costs for consumers.Understanding and taking measures to prevent common pitfalls associated with cannabis cultivation will allow the applicant to pass substantial cost-savings along to their patients. Natural Selections' values are aligned with the initial principles outlined under Chapter 369,An Act for the Humanitarian Medical Use of Marijuana.The applicant understands that many patients suffering from medical conditions are burdened with physician and hospital bills and are unable to pay market rates for medical cannabis.In order to address this gap,the applicant intends to establish a subsidized distribution network for low-income patients in Watertown, Massachusetts,Natural Selections will provide medical marijuana at reduced cost,or free,when an individual is a recipient of MassHealth,or Supplemental Security Income,o•the individual's income does not exceed 300%of the federal poverty level,adjusted for family size. Patients who demonstrate verified financial hardship will fill out an application and be marked in our patient database as eligible for reduced cost marijuana for medical rise. The application will be used to determine the degree of discount for qualified patients. It is our intention in most cases to have the discounted product sold at cost. In cases of exceptional need,marijuana for medical use will be provided for free,All dispensary agents will be trained to provide the discounts in accordance with 105 CMR 725 and relevant MA statutes. Job Creation for the City of Watertown Natural Selections is an equal opportunity employer and seeks candidates aligned with its core mission of building a compliant operation in good standing with regulates and producing safe, consistent cannabis products of the highest quality.The applicant seeks it seamless integration into the Watertown,Massachusetts community and Intends to hire local residents with a proven work ethic and interest in educational development,as well as experience and skills relevant to the required duties of each position. Tine applicant is committed to ensuring that cultivation and dispensary operations are staffed appropriately to remain in compliance with state law and deportment regulations,while simultaneously providing the highest quality of care to its patients, Initially,Natural Selections will hire 41 full-time employees.The applicant will also employ a contract security service to ensure redundancy in staffing and to partially segregate the security staff from the overall employee population.The applicant will be seeking candidates to fill the following positions: 53 Executive Office General Manager 1 Compliance Director I Community Outreach Manager 1 Quality Assurance,Manager 1 Human Resources Directors 1 IT Manager I Bookkeeper I Dispensary Director of Patient Affairs I Patient Coordinator 1 Dispensary Manager 2 Dispensary Agent 10 Security Personnel 4 Cultivation &Processing Cultivation Manager 2 Grow Agent 8 ff Processing Manager 2 t_ I Processing Agent 4 Natural Selections is committed to building a culture centered around employee development and education.The applicant strives to provide an environment that encourages employees to learn, ask questions,and provide input and suggest new policies and processes.In order to ensure that employees'needs are met,employees and consultants are assigned to a department for oversight. The manager of the assigned department is responsible for oversight of each employee. Department managers oversee personnel assigned to their department,and the Chief Operating Officer is responsible for overseeing all department managers.This structure allows for better communication,cohesion,and clarity among employees and superiors.During monthly team meetings with all personnel,the executive team will provide an opportunity for further discussion between all channels of communication. The following presents the detailed organizational chart,which outlines tite organizational flow between connection between executive leadership,directors,and managers in the various departments, f 54 i Director of Compliance j Compliance Malinger i CWoI'Irinnncial Husincas . ! Dlrectorof Hamm� Officer Dovolopmmn- Human Resources Resources n Managor Coitrollea• I Bookkeeper Dispensat'y l Dlsppvrasor-y f Director of Manager Agort Patients -- Affnlyds_ ' ` Patient --.----.—.--- Dispensary � i Coodhmtor CpiofExecutivc - '- - - _-__..._. oH7cer Medical Assistant Medical Director Researcher i Director of .� Qdtiv all oi' Cultivation Grow Agent Trimmer Extraction Exh actiat E Manager Assistant 1 Director of Infused Infused Manufacturiog I Procculug Products Products iChief Operating _ ., _ Mannger_- Assistant__ l Officer '.- -- _--. .. .. Packaging Packaging ; Manager Assistant Transportation;; Manager ; Dpeatlmrs ITMarage•' Malntetance hall, 'all Malinger i Operations .—.- . ,,,' DirectoP of Security Agent Security Directorof ( Social Media Community Manager Outreach 55 i I Section VI Mitigation & Prevention of Potential Adverse Effects r' l i i i i \ 56 i 1 I I Introduction Natural Selections has taken great precautions in creating Its security and safety plans,with the intention of protecting its employees,patients,and caregivers.The applicant does not expect to cause increased demands on the City's police,fire,emergency,or health-related services and does not expect to cause an adverse impact on the City of Watertown,However,Natural Selections is highly aware of the risks and social issues that could potentially be associated with this project and intends to implement a number of preventative security and educational processes to mitigate these.The applicant believes that if proper preventative measures are taken,the city of Watertown will have a similar experience to Denver, Colorado,where Natural Selections, Colorado operates its current facility.Since the first retail marijuana stores opened in Denver in 2014,Denver has benefitted from a decrease in crime rates,a decrease in traffic fatalities,and substantial additions ofjobs and economic development.' The applicant intends to implement the following procedures to mitigate issues associated with crime,drugged driving,distribution to minors,public consumption,and adverse health effects:. Natural Selections is committed to improving Watertown's economy and integrating seamlessly into its community and will take full responsibility for offseting any potential use of resources, while simultaneously bettering the economy. Preventing Increased Crime The applicant does not expect that the medical legalization of cannabis will result in an increase in crime.According to am independent study published by criminologists at the University of Texas at Dallas,medical marijuana legalization actually may be correlated with a reduction in homicide and assault rates.70 Despite these findings,the applicant is still committed to implementing intensive security measures to ensure that the legalization of cannabis does not result in Increased crime rates.The applicant believes that preventive security measures in e the best way to ensure that there is no illegal distribution or diversion of the products sold at their dispensary.The applicant has created these security measures—which are described in detail in the Security Plan in Section II based on the concept of"Concentric Circles of Protection,"which are compliant with l05 CMR 725.110 and based on varying levels of protection that work in conjunction with one another to create and maintain a secure and safe facility. The applicant intends to form a relationship with the city's police department and will meet an an annual basis to discuss concerns and effective security operations regarding the MMTC. While the applicant does not expect urn increase in crime rate or an increased demand on the city's police department,Natural Selections anticipates that its Community Host Agreement will mitigate any financial drain on the city's resources. Preventing Drugged DrivJug 9"Status Report:Marijuana Legalization in Colorado After One Year orRetail Sales and Two Years of Decriminalization.Drug Policy Alliance:2015. 10 Barnes,7.C.,Robert G.Morris,Michael TenEyck,and Tomislav V.Kovandzic,"The Effect of Medical Marijuana Laws on Crime:Evidence from Slate Panel Data,1990-2006."PLoS ONE 9(3):e92816.March 2014. I � 57 i Natural Selections will develop, implement, and maintain educational materials and seminars designed to prevent drugged driving and other adverse public health consequences associated with marijuana use. The applicant will design training procedures and policies to educate patients and employees about the risks associated with operating a motor vehicle after consuming medical cannabis. As stated in the previous section, each patient will be, required to complete an orientation session before purchasing medical cannabis from Natural Selections' RMD, This orientation will help patients understand how cannabis affects the human body and the risks associated with use. The orientation will also cover potential legal and financial risks for not abiding by Massachusetts state law. These educational materials are explained in detail in Section III: 'Business Operations&Marketing Plan.' The orientation will also provide extensive information about the dangers, risks, and adverse effects associated with tine consumption of cannabis,particularly the health,legal,and financial risks of driving under the influence of cannabis. The educational materials will outline Massachusetts law so that employees will be able to inform patients that Massachusetts law prohibits any driving under the impairment of cannabis: • According to Massachusetts General Laws Chapter 90, Section 24, it is a criminal offense to operate a motor vehicle"while under tite influence of intoxicating liquor, or 1 of marijuana, narcotic drugs, depressants or stimulant substances,as defined iu section one of chapter ninety-four C, o•the vapors of glue."Massachusetts has not determined the amount of cannabis in the blood stream allowing someone to legally operate a motor vehicle. Therefore, deciding if a driver is impaired by marijuana determined by the prosecutor in a case-by-case basis. • According to Massachusetts law, being legally entitled to medical cannabis is not an acceptable defense when charged with a drugged driving offense. Jn addition to this information, patients will also be provided with information about the penalties for driving under the influence of substances that impair driving abilities including cannabis.According to Massachusetts haw the maximum penalty for the first offense of driving under the influence is all to 30 months jail time, license suspension for up to one year,and the fines and penalties for driving under the influence range front$500 to $5,000, (State DUI Driving Laws). Patients will also likely lose their status as a registered patient, Cannabis and Driving I Each patient will receive an informational pamphlet specifically addressing the following questions regarding cannabis and drugged driving. All dispensary agents will be trained to provide more information and answer follow-up questions to any of these: Q.Does marijuana impair my ability to drive? l i 58 E A: Yes, any amount of marijuana can impair an individual's ability to drive. Therefore, individuals should find other options for transportation such as a designated driver, utilizing public transportation,taxis,or car companies such as Uber or Lyft. Q: What is the legal limit of marijuana impairment while operating a motor vehicle in Massachusetts? A: There is no legal limit of marijuana according to Massachusetts General Law. Medical marijuana is not considered to be an appropriate defense against the charge of driving under the influence. If a substance has impaired your ability to drive, even if it is medically prescribed and legally acquired,it is illegal to operate a vehicle. Q:How does law enforcement determtne impairment by the use ofmartyumra? A: Officers are becoming trained to look out for warning signs associated with driving under the impairment of madjumm. Additionally, while Massachusetts does not legally require that drivers submit to a drug test to determine impairment tite refusal to submit a drug test can be included in evidence If it person is charged with driving under the influence, Preventing Distribution to Minors The Department of Justice has stated that"preventing the distribution of marijuana to minors"is its first enforcement priority related to medical cannabis.' Natural Selections shares this concern and understands the potential risk of illegal cannabis distribution to minas.Natural Selections is committed to preventing distribution of the products sold at their Massachusetts dispensary to minors other than as allowed by state law and regulations. i Natural Selections will begin prevention on the premises with rigorous physical security measures that ensure only registered qualifying patients,personal caregivers,dispensary agents and other authorized individuals can access tine RMD.Natural Selections will also train employees to inspect photo identification and registration cards,which physicians,patients,and caregivers will present upon entering the dispensary.The dispensary will be designed in a neutral and secure fashion and it will not attract the attention of loiterers or minors nor encourage any congregating outside of the dispensary.Additionally,Natural Selections is aware of the dangers of"social distribution"and will provide extensive educational materials to inform patients and physicians about the dangers and risks associated with distributing medical cannabis to no-registered patients. iu the event that Natural Selections becomes aware of such activity,or is otherwise suspicious, it will take immediate action. Registration Card Inspection Natal al Selections strives to create a culture where employees have a shared commitment to curbing the potential distribution of medical cannabis products to minors.Inn compliance with CMR 725.030(A),all employees working in Natural Selections' dispensary will be 21 years of age or older.Key personnel will be responsible for training all staff and will require a culture of responsibility and compliance in order to prevent improper distribution. During employee training,all employees will be taught how to rigorously inspect registration cards and photo identification,Upon entering a dispensary,each individual's identification and 11 The Cole Memo. 59 registration card will be inspected by all employee.Natural Selections takes this responsibility very seriously and will relay the importance of this responsibility to each of their employees. Inspecting each physician,patient or caregiver's identification and registration card is essential to ensuring that the products sold at Natural Selections' dispensary are not illegally distributed or said to minors,The applicant will ensure that each employee receives extensive paining and is able to determine legitimate documents versus forged identification or falsified registration cards. Each patient or caregiver who has received a registration card has already endured a process to determine that they are fit to purchase products sold at Natural Selections' dispensary: As per the regulations outlined in 105 CMR 725.000,each qualifying patient diagnosed by one Massachusetts's licensed certifying physician must be at least 18 years of age.In certain instances,patients under the age of 18 will be granted a registration card if the patient has been diagnosed by two Massachusetts licensed physicians,at least one of whom is a board-certified pediatrician or board-certified pediatric subspecialist,as having a debilitating medical condition that is also a life-limiting illness,subject to 105 CMR 725.010(J), • As per 105 CMR 725,000,personal caregivers must be at least 21 years of age.A caregiver must submit their fill[name,date of bhth,address,telephone number,email address,and a statement certifying that the individual seeking a registration card is at least 21 years of age. Natural Selections will refuse to sell marijuana to any registered qualifying patient or personal caregiver who is unable to produce a registration card and valid proof of identification,or who does not have a valid certification in the Department-supported interoperable database,The identification must contain a name,photograph,and date of birth,and shall be limited to one of the following: 1. A driver's license; 2. A government-issued identification card; 3. A military identification card;or 4. A passport. Preventing the illegal sale of marijuana at the retail level will be aided by upholding strict identification laws and inspecting the registration cards provided by each physician,patient or caregiver that enters the dispensary.With strict inspection of identification and registration cards, Natural Selections will effectively guard against"undercover buying"arising at its dispensary, Any"undercover buying,"which is more common in the purchase of alcohol and tobacco,will be prevented by the rigorous inspection of all identification provided by each individual tint enters the MMTC. If individuals are not engaged in activity permitted by Chapter 369 of the Acts of 2012,An Act for the Humanitarian Medical Use of Marijuana("the Act"),they will immediately be removed from the premises.The applicant will have security personnel on the premises at all titres to enforce these measures. Branding&Packaging � 1 60 i The applicant is committed avoiding any images or branding strategies that would seek to influence or attract consumers from the general public,specifically minors.Natural Selections will only target medical patients with the conditions eligible for treatment under the current Massachusetts legislation,subject to 105 CMR 724.01(J).The applicant will only pursue advertisement opportunities in alternative medicine industry publications to promote the company in a responsible manner to an intended audience of qualifying patients. The applicant understands that packaging and labels is a critical part of preventing the distribution of cannabis to minors.The applicant will select packaging that is highly compliant with 105 CMR 725.105(E)and designed to prevent accidental ingestion by children.Products will be packaged in plain,opaque,tamper-proof,and childproof containers without depictions of the product, cartoons,or images other than the RMD's logo, Edible Marijuana Infused Products("MIPs")will not bear a reasonable resemblance to any product available for consumption as a commercially available candy.Any edible MIPs rescmbling a typical food or beverage product will be packaged in an opaque package and labeled in accordance with state regulations. All cannabis products sold by the dispensary will have labels that detail the potency,types of chemicals used in cultivation,and other necessary information.The Applicant will not utilize any statement,design,representation,picture or illustration that portrays anyone under 18 years of age. The RMD shall place a legible,firmly affixed label on which the wording is no less than 1/16 Inch in size on each MIP that it prepares for dispensing,containing at a minimum the following information: • The registered qualifying patient's name • The name and registration number of the RMD that produced the MIP,together with the RMD's telephone number and mailing address,and website information, if any • The name of the product • The quantity of usable marijuana contained within the product as measured in ounces • A list of ingredients, including the cannabiuoid profile of the marijuana contained within the product,including the THC level • The date of product creation and the recommended"use by"or expiration date • A batch number,sequential serial number,and bar code when used,to identify the batch associated will)manufacturing and processing • Directions for use of the product if relevant • A statement that the product has been tested for contaminants,that there were no adverse findings,and the date of testing in accordance with 105 CMR 725.105(C)(2) • A warning if nuns or other known allergens are contained in the product • This statement,including capitalization: "This product has rot been analyzed or approved by the FDA. There is 7inifled information on the side effects of using this i product, and there may be associated health risks.Do not drive or operate machinery when under the influence of this product. KEEP THIS PRODUCTAYYAYFROM CHILDREN." Preventing social Distribution while the applicant is aware that it cannot control the actions of those who purchase medical cannabis at its RMD,Natural Selections plans to implement policies informing its clients of the dangers of distributing cannabis to non-registered patients.Prior to obtaining a registration card, each registered patient must submit an attestation that he or she will not engage in the diversion 61 i.. of marijuana and that the patient understands that protections conferred by the Act for possession of marijuana for medical use are applicable only within Massachusetts in order,in accordance with 105 CMR 725.015(A), The Applicant plans to keep patients and clients informed of the dangers that are associated with distributing,selling,or diverting medical cannabis purchased at the RMD.The informational guide that the dispensary gives to each individual patient will include a section on the dangers of distribution.The guide will outline the legal consequences a patient faces if they distribute marijuana to a minor.Patients must understand that their registration as a patient may be impacted by any incident of diversion. The Applicant will be particularly diligent at educating its patients,caregivers,and employees regarding the risks of"social distribution."Social Distribution refers to the distribution of cannabis or other illegal substances to minors in which the source comes from a minor's hone, proxy buyers,or peer-to-peer exchange.In many cases,nninos are more likely to procure illegal substances,such as tobacco,alcohol or marijuana,through a"social source."According to a 2006 study,88%of minors who used cannabis obtained the drug from a friend or relative,12 In an effort to prevent social distribution,it is imperative that patients store their cannabis and cannabis products in a safe,storage place,preferably a lock box.The applicant will recommend a variety of secure lock boxes that come with keys and/or combination locks pads,such Wolffpak Lock Away and LockMed's Kevlar lockbag,designed to store cannabis.Dispensary agents will educate patients on the benefits of these boxes and will encourage new patients to buy one before bringing cannabis into their homes. The applicant will offer a number of free materials and resources links from "Tine Up and Away and Out of Sight"program to educate patients or keeping cannabis away from children and teenagers. A sample brochure will outline the following procedures regarding safety and security measures for storing cannabis inside one's home: 1) Store all cannabis or cannabis products hn a private place,out of reach from children. 2) Keep all medicine in their original packages cord containers. 3) Consider purchasing a medication lock box,Children,even young children,call easily access marijuana products hn their original packaging.A lock box provides a safe, convenient and affordable method for securing marijuana products in the hone or while traveling. 4) Return cannabis product to its storage place after each use.Never leave it out on a kitchen counter or at a bedside,even if you anticipate using it again in a few hours. Always put every marijuana product and other medicine away every time you use it, including those you use every day. 12 Washington Association for Substance Abuse&Violence Prevention. 62 5) Pick a storage place children cannot reach.Find a storage place too high for a child to reach or see.This is also important to remember when families are away from home and staying in hotels,or as guests in others' homes. 6) Talk to children and teenagers about medical cannabis.As with all medicines and marijuana products,teach your children about medicine safety.Explain what cannabis medicine is and why it is reserved for use of adults over the age of 18 with a medical prescription. 7) Tell guests about cannabis safety. Ask houseguests and visitors to keep purses,bags,or coats that have cannabis products in them up and away and out of sight when they are in your hone. 8) Ask other parents if they have cannabis products in their hone before sending your child to play at a neighbor or a classmate's house.If the answer is yes,make sure that all products are stored up and away and out of children's sight. Natural Selections will also work to ensure that minors cannot obtain cannabis through its RMD by ensuring that patients only procure the amount of cannabis legally prescribed.This will ensure that patients do not have access to more cannabis than necessary based or the diagnosis provided by a registered caregiver and that patients do not have access to additional marijuana that could be sold or distributed to minors or other non-registered users.Natural Selections is aware that a majority of minas who consume marijuana often obtain itthrough social situations and the applicant will ensure to the best of its efforts that the products sold at its dispensary do not end up in the hands of minas. t Natural Selection will retain and maintain detailed records of patients and caregivers who procure medical marijuana at their Massachusetts dispensary,The applicant will utilize its inventory tracking system to track all distribution, including the quantity,name,potency, batch number,and lot number of each cannabis product delivered.Searchable patient records are tied to their certifying physician in the point of sale system to ensure that upon request,all records can be quickly located and delivered to certifying physicians. If the applicant begins to suspect that a physician,patient or ca egiver is socially distributing marijuana to minors or other non-registered users,they will immediately inform the Watertown Police Department and other law enforcement as appropriate.Natural Selections takes its role as a RMD and MMTC seriously and will wok to ensure that the products sold in their dispensary do not illegally end up in the possession of minors or other non-registered users. Location,Security,&Surveillance Natural Selections understands that its location,security,and surveillance systems will also be critical in preventing the illegal distribution of medical marijuana to minors or other non- registered users.The applicant has chosen a location for its RMD that is highly compliant with 105 CMR 725.11 O(A)(14).The MMTC,which is located at 23 Elm Street, is not situated within 500 feet of a school,daycare center or any facility in which minors commonly congregate. Natural Selections specifically chose this location,as it is a significant distance from any area that would be considered to be at risk for the congregation of minds. The RMD will in no way reference the sale of marijuana through its logo,external signage or on 63 t the exterior of its premises abiding with Massachusetts's law.The signage outside of the dispensary will only be illuminated 30 minutes prior to the dispensary's closing and there will be no neon signage that may attract potential loiterers.The Applicant will also ensure that security treasures are taken if there appears to be loitering outside of the dispensary. Natural Selections will ensure that the dispensary premises are under video surveillance 24 hours a day and 7 days a week and will make the surveillance available for inspection by Department of Public Health and/or Watertown Police Department at all times.The following will be implemented at the premises to ensure that Natural Selections is secure and is designed to prevent the illegal distribution of marijuana, Security personnel will be on site at all times to remove individuals not complying with Act 105 CMR 725.000 Preventing Public Consumption There will be no public consumption permitted on the premises of the MMTC or any of its ancillary facilities:This policy will be strictly enforced among patients,caregivers, and employees.Prior to purchasing medical cannabis at the Natural Selections'RMD,patients will be required to undergo an orientation session where they will be educated on Medical Marijuana Law in Massachusetts,Patients will be instructed that they should only consume cannabis in a private residence.By signing the patient consent and agreement forms,the patient are confirming that they have completed the law and understand that public consumption is strictly prohibited under Massachusetts state law, ( Preventing Health Issues i Natural Selections is aware of the potential health concerns associated with cannabis consumption.To this effect,the applicant will be committed to offering a variety of products and methods of consumption that allow patients to benefit from camnabinoids while ingesting little to no carcinogenic plant material or residual toxins. o Smoking.While there is no scientific evidence linking smoking marijuana to lung cancer,Natural Selections is aware of the potential damage that regular smoking could have on the lungs.To this effect,Natural Selections will offer a wide variety of infused products, including tinctures,capsules,teas,and topicals for patients who do not wish to inhale burning plant vegetation.The applicant will also offer a selection of vaporizer pens that allow patients to inhale the vapor of cannabis concentrates and oils. o Butane Residuals.Natural Selections is also aware of the trace residual toxins found in cannabis-infused products and concentrates that are manufactured using butane-based solvents.In July of 2015,the state of Washington became the first state to ban the use of butane as an extraction solvent for medical patients, Boulder County,Colorado,has taken provisions to establish similar measures. Although there is limited research and data available on the effects of residuals, these legal measures have underscored the possibility of these trace residuals being a threat to patients with compromised immune systems seeking caumabis as medicine.The applicant is committed to purchasing a CO2 extraction machine for its manufacturing/processing lab and using CO2 as a processing method, 64 f Other Potential]affects on City The applicant has considered other potential effects that its operations could have on the city of Watertown and has outlined solutions and strategies to mitigate these. Increased Demands or Watertown Fire Department The applicant will not be cultivating medical marijuana on site at its MMTC.Therefore,the applicant does not expect that its operations will have any emergency incidents that will increase the burden on the city's fire department.The applicant will ensure that its MMTC is fully compliant with fire codes and fire prevention.The applicant will form a relationship with the city's fire department and ensure that all staff members receive training in regards to preventative fire techniques, as well as fire suppression and avoidance.Natural Selections is committed to ensuring that its MMTC is fully compliant with fire code and fire safety prevention techniques, thereby causing no additional demand on the city's emergency fire services.However,if emergency fire related services are required,the applicant expects that its$100,000 annual payment and its Community Host Agreement will lessen or cover the financial impact on the fire department. Increased Demands on Watertown's Erneraencv Services The applicant does not expect to require or impact the city's emergency services.However,in the event of an emergency,the applicant expects that its$100,000 annual payment and Community Host Agreement will cover any financial loss. i Increased Demands on Watertown's Health Services. While Natural Selections expects that its MMTC will have a positive impact on the community's health and education,the applicant does understand the potential health risks associated with medical marijuana.The applicant is committed to educating patients and caregivers about the potential risks of medical marijuana.The applicant will require that each patient undergo an orientation session so they understand all of the potential side effects and associated risks, including the dangers of drugged driving.The applicant also httends to hold educational seminars and programs in order to educate the community about responsible cannabis use,substance abuse, and HIV/AIDS prevention.Natural Selections intends to Ilse its position as a RMD to educate the community about substance abuse and the responsible rise of cannabis. htcluding its preventive measures,the applicant expects that its Community Host Agreement will mitigate any potential financial demand on the city's stealth services. Ltcreased Air,Noise,Liaht and/or Water oollutior The applicant intends to comply with all Federal,State,and local requirements regarding increased air,noise,light,and water pollution created by its proposed facility.While the applicant does not intend that its MMTC will have a negative impact on the community,should any problems arise regarding increased air,noise,light,or water pollution,the applicant will work with the community to ameliorate any negative impact. 65 1 Air Pollution:Natural Selections will not be cultivating medical marijuana on-site at its dispensary.Therefore,the applicant does not expect an increase in air pollution at its dispensary location. • Noise Pollution:The applicant does expect an lre ease in noise pollution.The applicant purposefully chose an industrial/commercial location to open its dispensary in order to avoid issues associated with noise pollution, • Light Pollution:The applicant's secoity system will utilize anotion-sensor lighting in order to prevent theft or breaches of security on the premises,especially at night These motion-sensor lights will illuminate all entrances and the parking lot and will be used to detect loitering or intrusion.However,the applicant does not intend to illuminate the parking lot during daylight hours or beyond hours of operation, barring any emergency circumstance.This should minimize potential lighting pollution.The applicant chose a commercial area for its location in order to avoid problems associated with light pollution.The applicant intends to work with its community in order to ensure that its additional lighting does not cause issues for surrounding businesses. • Water Pollution:Natural Selections will be cultivating medical marijuana off-site therefore the applicant does not anticipate an increase in water pollution at the dispensary. Increased Traffic and Traffic Mitieation I The applicant will expect all increase in traffic to its MMTC,which is located at 2313hn Street. i { The applicant chose this location because of its industrial neighborhood and its significant distance frown schools,locations where minors may congregate,and high-traffic regions. Based on its current Market Analysis,the applicant does not expect to have more than 15 patients at their dispensary at peak hours during the first year of operations.The applicant will be open for 12 hours per day, from 8 AM to 8 PM,which should offset some concerns regarding traffic. During a peak day,the applicant does not expect that there will be more than 200 trips to the MMTC.As the registered patient base increases in Year 2,Natural Selections will likely see an additional 100 trips per day.This will lead to a maximum of 300 trips per day by 2018. The applicant does not expect this increase in traffic to negatively impact the community it serves.However,the Community Host Agreement,in which Natural Selections has pledged to offer up to 6%of the gross revenue of the MMTC to the Watertown Community,should offset any impact of the city's financial resources.The applicant has also set aside additional funds of $100,000 to offset or mitigate any drain on the city's resources including,but not limited to,any additional traffic burdens placed on the city by the opening of the applicant's dispensary. Natural Selections intends to have a positive impact on the city of Watertown and its community. The applicant is committed to offsetting any potential negative impacts on the community with j educational programs,charitable donations,and through its Community Ilost Agreement. } i 1 i 66 Section VII Best Practices & Standard Operating Procedures 67 Cultivation Best Practices Natural Selections is committed to implementing best cultivation practices to ensure the production of high-quality,consistent and effective cannabis and cannabis products.Cultivation will occur in a designated cultivation facility in Fitchburg,Massachusetts.No cultivation will take place at Natural Selections'MMTC. COO Aidan O'Donovan will oversee the cultivation facility and ensure that operations are highly compliant with regulations outlined under 105 CMR 725.105(D)(1)(D). The applicant has extensive experience in cannabis cultivation and will emulate cultivation strategies and techniques at Natural Selections,Colorado's current facility.The applicant is committed to ensuring that all cultivation practices are consistent with U.S.Department of Agriculture organic requirements as per 7 CFR Pant 205. Natural Selections will use a peat-based soil medium that has met the U.S.Agency for Toxic Substances and Disease Registry's Environmental Media Evaluation Guidelines for residential soil levels.Natural Selections will use best practices to limit contamination,including but not limited to mold,fungus,bacterial diseases,rot,pests,non-organic pesticides,mildew,and any other contaminant identified as posing potential harm.In accordance with 105 CMR 725.105(C) (4)a RMD shall process the leaves and flowers of the female marijuana plant only,which shall be: (a)Well cured and free of seeds and steins; (b)Free of dirt,sand, debris,and other foreign matte; (c)Free of contamination by mold,rot,other fungus,and bacterial diseases; (d)Prepared and handled on food-grade stainless steel tables;and (e)Packaged in a secure area. Natural Selections will be committed to employing best practices at its cultivation facility.The following list outlines the phases of cannabis cultivation and the best practices that the applicant will implement at each point: Mother Stage Mothering plants are plants in the mature vegetative phase of plant development that are set aside and monitored for the purposes of providing identical genetic plantlet cuttings,These mother plants provide the plant tissue needed to form clones.Mothering plants must be under light for 18 to 24 continuous hours per day. Mother plants need regular maintenance in order to ensure they provide the highest quality cuttings.Employees must flush the soil of mother plants regularly and monitor the fertility or electrical conductivity daily. If during a flush,a grow agent observes that the c1cet•ical . conductivity measured value is too high,he or she will be responsible for flushing with pH water to balance the soil. Grow agents will also be responsible for pruning mother plants regularly and checking proper stem development. I All mothering plants will be kept in a rnon at an atmospheric temperature between 74-80 degrees Fahrenheit.Leaf temperatures will be kept between 76-80 Fahrenheit.The atmospheric humidity a should be kept between 50-60%relative humidity Cutting& Cloning t 68 F In order to propagate a cannabis plant, `mother stock plants'are used to provide cuttings to create new plants,or clones.It is critical to employ best practices during this process as careless technique may result in the injury of the plants.Grow agents will ensure that cuts are made at a 45' angle, to prevent water front seeping into the exposed area,which can encourage pathogen formation, Grow agents will also ensure to not leave excess stems while making cuts,which can promote the colonization of pathogens,Cuttings are maintained at cool temperatures and high humidity to reduce transpiration rates while the cutting forms roots.Bottom heat is applied to the root zone to increase rooting rate and success, Once the cuttings have been tooted,these clone plantlets are in an initial vegetative phase of plant development.In this stage the clones are grown in plug substrate in plastic trays.These clones are illuminated at a fairly low intensity using T-5 florescent bulbs for 18 to 24 hours per day.All cloning plants will be kept at an atmospheric temperature between 68-74 degrees Fahrenheit and atmospheric humidity of 80-90%relative humidity Vegetative Growth The period of growth after propagation and before the initiation of flowering is known as the vegetative phase of plant development.During the vegetative stage,plants carry out photosynthesis and accumulate the resources that will be needed for flowering and reproduction. Plants will be in the vegetative plant stage for 3-4 weeks,and will be kept under 1000 Watt Metal Halide bulbs for 18 to 24 hours per day. It is critical that the grow agents execute best practices and consistently monitor the plants' environment during this phase of vegetative growth. Grow agents will be responsible for controlling the environment of the plants by monitoring the following:watering/irrigation, nutrient uptake,carbon dioxide treatment,pesticide treatment,printing,slid trellising. Vegetative plants will be kept at an atmospheric temperature between 74-80 degrees Fahrenheit,a leaf temperature between 76-80 Fahrenheit,and an atmospheric humidity between 50-60% relative humidity. Flowering Period During the flowering period,cannabis plants begin final maturation,While calyxes and trichomes ripen,all tine flowers are fully connected into inflorescences(groups of flowers).Daring the flowering phase,plants will be kept under 1000 Watt High Pressure Sodium bulbs fo'12 hours per day.Natural Selections will choose cannabis strains with a flowering cycle of approximately 8 weeks. Flowering plants will be kept at an atmospheric temperature of 73 to 78 degrees Fahrenheit,a leaf { temperature of 72 to 77 Fahrenheit, and an atmospheric humidity of 45.55%relative humidity. The applicant intends to implement good air circulation techniques to strengthen plants'stems and prevent fungal disease. Two weeks prior to harvest,the nutrients are flushed from the plant through the watering process to help ripen flowers slid aid in the removal of excess mineral fertilizers in plant tissues. Harvest Process 69 t When cannabis plants finish their reproductive phase,as indicated by trichonte coloration,they are ready for harvest.This phase minks the end of plant and the beginning of the processing phase. The day before harvest,plants are inspected and categorized based on their quality.Plants with powdery mildew,mold,or other defects are destroyed.Plants with small,buds are repurposed for processing and do not need to be trimmed.Plants with healthy growth and no known issues are categorized as flower. On the day of the harvest,the Harvest Manager will inform the grow team of the order of strains to cut down first and maintain all written documentation of the harvest. In addition,the manager organizes drying racks according to strain and harvest time.After one week,the manager pulls plants,starting with the first group of plants that were initially cut down(by strain),and delivers the plants to the trim crew.There will only be one harvest manager and one additional grow agent putting plants to mitigate tine risk of error and diversion. Once a plant is trimmed,him is recorded separately from buds as buds are seilabie products and trim is repurposed for processing.After harvest,waste is disposed of according to the Waste Disposal Plan. Drying/Curing Curing is the process of slowly removing the remaining excess moisture from the cannabis product.During this period,the remaining moisture is slowly removed,allowing for even moisture distribution throughout the flower,while preserving terpenes and other volatile compounds.The applicant is dedicated to the highest-quality,post-production practices and ( implements a 60-day cure on all products.Properly curing medical cannabis further develops cannabinoids and flavonoids to ensure a pleasant and quality product is consumed, Post-Hrtrvest Upon completion of each harvest,the cultivation room and post-harvest rooms are thoroughly cleaned and sanitized prior to new plants being introduced.Drying areas are sterilized with hydrogen dioxide between all batches. During the post-harvest handling of product,daily inspections in the dry area are carried out to inspect for contaminants and potential pathogens. Further,while being stored for final processing,the product is stored between 6-10%moisture content to minimize the possibility for any mold germination to occur.A rotating member of management performs inventory audits of the secured roonn with product ready for distribution once per day In addition to the cure room storage cabinets.Rotating the supervisory manager to check each day prevents the opportunity and motivation for diversion.It is up to the Harvest Manager to assure the inventory of drying plants as pail of required internal documentation.Plant inventory is done weekly as a group with all team members in a similar style rotation by using the unique barcode,stain,and location. Mauufactm•ing/Processing Best Practices I ! Natural Selections is committed to offering a wide variety of high-quality manufactured infused I products("MIPS")at its dispensary.These products will allow patients to digest a concentrated amount of cannabinoids,while ingesting little to no plant carcinogens.Natural Selections intends to create and dispense the following infused products: i � • \ 70 • Cannabis concentrates&waxes, • Bairns,topical,ointments,salves,dermal patches, Tinctures,capsules • Vaporizer cartridges The applicant will produce all of its MIPS at the cultivation and processing facility in Fitchburg, Massachusetts.All production will take place in a limited access area,which will be monitored by video surveillance cameras at all times.Security staff will also monitor employee entry and exit out of the processing lab. Natural Selections is committed to utilizing Super Critical Carbon dioxide extraction CO2 methods to create its selections of M1PS.The applicant believes that this method of extraction is far superior to butane,which has been known to leave residual toxins in cannabis-infiused products.In July of 2015,Washington became the first state to ban the use of butane as an extraction solvent for medical patients.Boulder County,Colorado has taken similar measures to follow suit.Although there is limited research and data available on the effects of residuals,these legal measures have underscored the possibility of these trace residuals being a threat to patients with compromised immune systems seeking cannabis as medicine. i i Tire applicant has allocated sufficient capital to purchase a CO2 Botanical Extraction machine for $63,500 from Apex Supercritical labs.The applicant has extensive experience utilizing CO2 extraction to create concentrates and oils and believes that it is one of the most effective ways to reduce cannabis to its essential compounds.This processing method uses pressurized carbon dioxide to separate plant material and cannabinoids.Manufacturers can pinpoint the desired components they wish to extract front a material.After the CO2 is purged,tine final product is a 't potent and pure amber oil.The end product has virtually no residual solvent,as CO2 evaporates. Natural Selections will be committed to ensuring reliability,transparency and quality of its MIPS products.The applicant will select packaging that is highly compliant with 105 CMR 725.105(E) and designed to prevent accidental ingestion by children.Products will be packaged in plain, opaque,tannper-proof,and childproof containers without depictions of the product,cartoons,or images other than the RMD's logo.On the interior,Information is placed describing nutrients, pesticides,ingredients,and recommendations on methods of intake,dosing, batch information and contact information. The applicant does not intend to produce edible MIPS immediately upon opening operations and will focus instead on creating concentrates,oils,tinctures,capsules,and salves.However, in any case,Natural Selections will never produce edible MIPS that bear a reasonable resemblance to ! any product available for consumption as a commercially available canny. I Natural Selections will place a legible,firmly affixed label on each MIPS product with the following information: The registered qualifying patient's name; • The name and registration number of the RMD that produced the MIP,together with the RMD's telephone number and mailing address,and website information,if any; • The name of the product; • The quantity of usable marijuana contained within the product as measured in ounces; • A list of ingredients,including the cannabinold profile of the marijuana contained within � f i 71 r` the product, including the THC level; • The date of product creation and the recommended"use by"or expiration date; • A batch number,sequential serial number,and bar code when used,to identify the batch associated with manufacturing and processing; • Directions for use of the product if relevant; • A statement that the product has been tested for contaminants,that there were no adverse findings,and the date of testing in accordance with 105 CMR 725,1 05(C)(2); • A warning if flats or other known allergens are contained in the product;and • This statement,including capitalization:"This product has not beef]analyzed or approved by the FDA.There is limited information on the side effects of using this product,and there may be associated health risks.Do not drive or operate machinery when under the influence of this product.KEEP THIS PRODUCT AWAY FROM CHILDREN.' Any agents who come into contact with marijuana o non-edible MIPs,including cultivation, production,or packaging,will receive training and must understand the requirements for food handlers specified in 105 CMR 300.000:Reportable Diseases,Surveillance,and Isolation and Quarantine Requirements; Any dispensary agent working in direct contact with preparation of marijuana or non-edible MIPs shall conform to sanitary practices while on duty,including: 1.Maintaining adequate personal cleanliness;and 2.Washing bands thoroughly in an adequate hand-washing area before starting work,and at any other time when hands may have become soiled { or contaminated. t Quality Control Best Practices Tire applicant is committed to a rigorous testing policy and has established partnerships with ISO- certified laboratories to test all produced strains and cannabis-inflrsed products. The applicant has established quality control protocols that require the testing of all products for chemical and biological contaminants prior to selling them at the MMTC,The RMD shall maintain the results of all testing fo-no less than one year; Marijuana shall be tested for the cannabluoid profile and for contaminants as specified by the Department,including but not limited to mold,mildew,heavy metals,plant-growth regulators, and the presence of non-organic pesticides. The applicant will ensure that each product is tested for the following: • Cannabinoid profile.The testing results will include at minimum the dry weight cannabidiol(CBD)and tetrohydrocannabinol (TI-IC). • Metals(including arsenic,cadmium,lead,and mercury) • Pesticide Residue and Plant Growth Regulators Microbial contaminants and mycotoxius • Residual solvents.As described above,the applicant will utilize Supercritical Carbon Dioxide extraction methods,which do not leave residuals in the products. • Finished Plant Material Production • Concentrate Production ,f j 72 f ( Natural Selections will implement policies and procedures for responding to results indicating contamination,which shall include destruction of contaminated product and assessment of the source of contamination.These policies will be available to registered qualifying patients and Personal caregivers, Natural Selections is committed to quality assurance in all elements of its cultivation,production, and servicing. Other quality control procedures beyond rigorous testing include: • Facility and equipment. All facilities used by the applicant will have adequate work areas and equipment for the intended task.The facilities will have sufficient space,a clean environment,and appropriate lighting,ventilation,heating,cooling,plumbing, washing and sanitation.Equipment will not contaminate products or otherwise react with, add to,or be absorbed by product and will be properly maintained,calibrated,cleaned, and sanitized at appropriate intervals following written procedures. • Control ofcon:poments,containers and closures. Written procedures will be developed, maintained and followed that describe the handling,review,acceptance,and control of material used in the manufacture of products,Materials will be controlled (segregated, labeled)until they have been examined and released for use,Materials will be handled and stored in a manner that prevents degradation or contamination. • Chain of Custody.Natural Selections will emulate current inventory control systems at the facility in Colorado,which entails a series of comprehensive policies and procedures to ensure a clear chain of custody and accountability for all aspects of the applicant's inventory and recordkeeping processes.All plants,raw materials,finished products,and ( byproducts will be tracked and properly stored throughout the course of cultivation, processing,and dispensing. • Packaging,labeling and distributing. All products shall be suitably packaged in accordance with 105 CMR 725.105(E)to protect products from alteration,contamination, damage during storage,and handling and shipping.All products will be packaged in tight,light-resistant containers and stored at controlled room temperature(unless otherwise indicated).All labels will be examined prior to distribution to ensure the information matches the compounding and formulation record requirennents.If ally discrepancies are observed,the product shall be immediately quarantined and investigated.All employees must verify that all labels have the correct names,amounts o, concentrations of ingredients,total volume,beyond-use date,appropriate routes of administration,storage conditions,and other safe use information as needed.A distribution record of each batch will be.kept that is sufficiently detailed to allow traceability and facilitate a recall if necessary. • Cleaning and Sanitizing, Cleaning,sanitizing and organizing of the direct and contiguous cultivation and processing areas must be perfumed at the beginning of each day and may be performed additionally as necessary. Waste Disposal Plan The applicant understands the risk associated with negligent waste disposal methods,which can potentially lead to diversion,theft,and distribution to non-registered patients.The applicant will emulate waste disposal strategies at the facility in Colorado,which have been designed to prevent 73 theft from occurring after the necessary disposal of cannabis plant material,damaged plants,and contaminated cannabis products.The applicant is committed to monitoring,recording,and securing the destruction of all cannabis,cannabis products,and cannabis plant material in an adequate manner compliant with 105 CMR 725,105(J). The applicant is committed to educating all grow agents on the importance of proper waste disposal methods and the risks and dangers associated with not following these procedures.The cultivation manager will be responsible for upholding all waste management policies and perfuming regular checks to ensure that no incidents of diversion have occurred.Grow agents will receive extensive training regarding waste disposal methods and will be expected to uphold these policies as well.All medical cannabis waste will be processed at the cultivation facility.No cannabis waste will be processed at the applicant's MMTC. • Plant material waste and non-plant material waste will be discarded in separate waste bins.These bins will be clearly identifiable with respective colors and signs. o Waste bins designated for cannabis plant material will be green and waste bins designated fo-non-cannabis plant material will be black. • All waste bins are stored in limited access areas. Only grow agents will have access to cannabis waste bins. Waste and waste bins are stored out of the public view. • In compliance with CMR 725.105(J)(3),all disposed waste containing cannabis material or byproducts must be rendered useless and unrecognizable.Grow agents will be responsible for grinding and incorporating the medical cannabis waste with solid wastes such that the resulting mixture renders the medical cannabis waste unusable, All weighed wasted is mixed at 1:1 rate with used media. (• Processing waste occurs the day of a harvest event,This allows more time for the media to mix with the cannabis,which helps render the product unusable and unrecognizable. At this juncture,grow agents will be responsible for weighing all waste in"Plant Material Only"and"All Other Waste"bins.The grow agents will record weights of the amount of raw material,type of raw material,and date in the Inventory Management System,This is outlined in more detail under"Chain of Custody&Inventory Management." • In compliances with CMR 725,105(1)(5),when cannabis or MIPs are disposed of,the applicant will create and maintain a written record of the date, the type and quantity disposed of,the manner of disposal,and the persons present during the disposal,with their signatures.The applicant will keep disposal records for at least two years. • The applicant will dispose of all solid waste generated at its RMD or cultivation facility as follows: (a)Incineration in a commercial or municipal waste combustor in Massachusetts holding a valid permit issued by the Department of Environmental Protection (DEP).No fewer than two dispensary agents must witness and document destruction;or (b)Disposal in a landfill holding a valid permit issued by the DEP or by the appropriate state agency in the state in which the facility is located.No fewer than two dispensary agents must witness and document disposal in the landfill;or (c)Grinding and incorporating the medical cannabis waste with solid wastes such that the resulting mixture renders the medical cannabis waste unusable.Once l . 74 such medical cannabis waste has been rendered unusable,it may be: • Disposed of in a solid waste management facility that holds a valid permit issued by the DEP or by the appropriate state agency in the state in which the facility is located;or • If the material mixed with the medical cannabis waste is organic material as defined in 310 CMR 16,02,the mixture may be composted at an operation that is in compliance with the requirements of 310 CMR 16,00. • When excess plants and damaged plants are to be discarded,the unique tracking tag (RFID)with plant identifier,date and associated grow agent is to be filed. A folder is kept for all discarded plant filing.Until waste processing finishes,the plant waste is discarded in a cannabis waste bin and the media is held. • Damaged plants with Inflorescences that have medicinal value will be cut at the stock, where the soil meets the stock. In these cases,the plant identifier is recorded on the harvest sheet of its original respective batch.The damaged plant is then harvested and all corresponding weights are recorded on the correlated harvest sheet. The grow agent will be responsible for making a note in the inventory management system regarding the cause of the damaged plant and the reason for its premature harvest,The salvageable sections are placed in the Dry Room and bucketed with the remaining harvest.These plants are intended for production.All posted cultivation and dispensary manifest or inventories are updated. The plant is then removed from the electronic plant-tacking inventory. Damaged plants found to contain potential contaminants with or without Inflorescences of medicinal value are rendered useless. The plant identifier is recorded on the harvest sheet of its original respective batch. The damaged plant is then weighed as a whole and corresponding weights are recorded on the correlating harvest sheet. Grow agents will be responsible for noting the cause of the potential contaminants and cause for the plant being harvested prematurely. Until waste processing occurs,the plant waste is discard In a cannabis waste bin with the media.Next,all posted cultivation and dispensary manifests or inventories are updated. The plant is then removed from the inventory management tracking system. • During the drying process and prior to packaging and preparing for processing,cannabis flower found to have contaminants will be rejected for processing and removed from the batch. If contaminated flower have reached the processing facility,they are returned to the cultivation facility.Before rendering useless,the contaminated product is inventoried and rewelghed.The grow agents will be responsible for recording the potential contaminates present,date and time.After the cannabis reaches the cultivation facility,it is reweighed and inventoried at the cultivation facility. Until waste processing occurs,it is stored in a limited access area. • Dunipstes and waste bins used will meet all state and local laws,and when not in use are keptlacked. • Video surveillance will be present at limited access entries and exits in areas containing waste.The keys or access codes to waste disposal areas are only provided to necessary cultivation and manufacturing facility staff and waste management staff member. • Dispensary agents will ensure that patients are informed of the risks of disposing 75 cannabis or cannabis products through traditional disposal methods.In compliance with 105 CMR 725.105(J),the applicant will accept at no charge unused,excess,or contaminated cannabis from a registered qualifying patient or personal caregiver,and shall destroy it as provided and maintain a written record of such disposal,which shall include the name of the supplying registered qualifying patient or personal caregiver if applicable. i t , 76