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19-09-17 NS AJO Holdings 23 Elm St
z83. Watertown Town Council Administration Building 149 Main Street Watertown, MA 02472 Phone: 617-972-6470 ELECTED OFFICIALS: Mark S.Sideris, Report of the Committee on Economic Development and Planning Council President Meeting Date: July 16,2019 Vincent J.Piccirilli,Jr., The Committee convened on Tuesday, July 16, 2019 at 7:00 pm in the Richard E. Vice President& Mastran elo Council Chambers. Present were Kenneth Woodland chair; Lisa Feltner District C Councilor g > vice chair; and Vincent Piccirilli, secretary. Staff present was Steven Magoon, Assistant Caroline Bays Town Manager/Director of Community Development and Planning. Also present were Councilor At Large Councilors Angeline Kounelis, Susan Falkoff, and Anthony Palomba; representatives Anthony J.Donato, from NS AJO Holdings Inc.; and members of the public (Attachment A sign-in sheet). Councilor At Large Susan G.Falkoff, The purpose of the meeting was consideration of the request from NS AJO Holdings Councilor At Large Inc., currently approved for operation of a Registered Marijuana Dispensary at 23 Elm Anthony Palomba, Street, to operate as an Adult Use Marijuana Establishment at the same location. Councilor At Large Councilor Woodland began with an explanation that section 8 of the current Watertown Angeline B.Kounelis, Host Community Agreement with NS AJO Holdings dated July 12, 2017 (Attachment District A Councilor B) states that the agreement be renegotiated if the Town passes an ordinance allowing Lisa J.Feltner, recreational marijuana, which it did on November 27, 2018. As a result,NS AJO District B Councilor Holdings sent a letter to the Town on March 29, 2019 (Attachment C). Kenneth M.Woodland, District D Councilor Mr. Magoon made the following comments: 1. The NS AJO Holdings/Natural Selections medical marijuana facility at 23 Elm St is finished but has not started selling because of state certification delays with its Fitchburg grow facility. 2. The zoning ordinance passed by the Town allows a maximum of 3 recreation marijuana facilities. 3. The process specified by the Cannabis Control Commission (CCC)requires the Town to first negotiate a Host Community Agreement(HCA), then the petitioner submits a license application to the CCC, and then they submit an application to the Zoning Board of Appeals for a Special Permit. 4. The CCC requires a Community Meeting for public input before the Town negotiates the HCA. Next, the NS AJO Holdings team gave a presentation(Attachment D) about the proposed plan for its 23 Elm St facility to sell recreational marijuana. Michael Ross, their attorney, said that he provided a proposed new HCA today but that his client is still reviewing it(Attachment E). Mr. Ross noted he submitted an application to the Town on April 19, 2019 with additional information(Attachment F). Aidan O'Donovan, the CEO of NS AJO Holdings, noted there is chaos at the CCC and the timeline shown with a September 2019 local permitting date is unrealistic, and he expects this to slip six months. The chair open the meeting for public comments. Councilor Kounelis spoke and noted neighborhood residents opposed the 23 Elm St location three years ago, and that this location is isolated and has limited visibility from the street, and she will not support this plan. Page 1 of 2 Committee on Economic Development 8v Planning Report - July 16, 2019 4 Action Item: Councilor Piccirilli made a motion, seconded by Councilor Woodland, to recommend that the Town Council move forward with adult use marijuana to be operated by NS AJO Holdings at 23 Elm St and to have the Administration proceed with scheduling a Community Meeting and developing a draft Host Community Agreement to be brought back to the Committee for review. Councilor Feltner said she was not comfortable seconding the motion,being unclear on the process with the Town Council still developing criteria for approving adult use marijuana facilities, and having scheduled a meeting August 14 to do so. Mr. Magoon explained that this situation with 23 Elm St is different because NS AJO Holdings has already gone through the medical marijuana vetting process, and that they already have an HCA. He also noted that no other recreational marijuana petitioners have come forward with a formal request, as they are still searching for sites, and the Town still needs to develop criteria to evaluate applications when they do. The motion was voted unanimouslv 3-0. The follow-up meeting will be scheduled for October 7 at 7:00 pm. The meeting adjourned at 8:04 pm. Report prepared by Vincent Piccirilli Attachments: A - Sign-in sheet B -July 12, 2017 Watertown Host Community Agreement with NS AJO Holdings C -NS AJO Holdings Letter regarding Host Community Agreement March 29, 2019 D -NS AJO Holdings Presentation July 16, 2019 E -NS AJO Holdings Proposed Host Community Agreement submitted July 16, 2019 F -NS AJO Holdings Adult Use Application submitted April 19, 2019 Page 2 of 2 Attachment A T�avid S kes 30 2 h o r e, fee c, I 6 f^ e Z S k-. -�e� �I b�5 TV ' 12, � S� ree -f- L°n2 �f� /y /l t - Attachment B 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 14?,,' day of July, 2017 by and between NS AJO Holdings, Inc. a Massachusetts not-for- profit corporation with a principal office address of 67 Dana Street, #1, Cambridge, MA 02138 (the "Operator") and the City known as 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 Street, Watertown, MA 02472 in accordance with the Town's Zoning Ordinances and 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 M1Ps provided that they shall not bear a reasonable resemblance to any product available for consumption as a commercially available candy, 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 intends to 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; and WHEREAS, The Town enacted Ordinance#59 (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 HOST COMMUNITY AGREEMENT I—TOWN OF WATERTOWN, MA 1 I Page 2G3S74G.v1 Permit in the I-1,I-2, I-3 and RMUD Zoning Districts, which it may amend further from time to time (the"Town's Zoning Ordinance"); and WHEREAS, Operator intends that its Facility will engage in the sale of medical marijuana for medical purposes as may be permitted by the DPH,and for those purposes, seeks to locate the Facility in the RMUD Zoning District pursuant to Special Permit; and WHEREAS,The Facility shall comply with the buffer requirements set forth in 105 CMR 725.110(A)(14) and the Town's Zoning Ordinance; and WHEREAS, Operator intends to provide certain benefits to the Town in the event that it obtains a Final Certificate of Registration to operate an RMD in the Town and has received all required local permits and approvals; and WHEREAS, Operator has applied for a certificate of registration from the DPH to operate the Facility at 23 Elm Street, Watertown,MA; and WHEREAS, Operator is seeking a letter of support/non-opposition from the Town regarding Operator's application for the DPH License; and 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,provisions of this Agreement,the Operator and the Town enter into this Agreement in accordance with G.L c.44, §53A, on the following terms: 1. Community Impact Donation: The parties anticipate that the Town will incur additional expenses and impacts 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 shall provide as a gift to the Town a community impact donation(the"Community Impact Donation")in the amounts and payable at such times as described in Section 2 hereof. The Treasurer of the Town shall hold the Community Impact Donation in a separate account, to be expended by the Town without further appropriation pursuant to G.L. c.44, §53A, for the purposes of addressing the potential health, safety,and other effects or impacts of the Facility on the Town and on municipal programs, services,personnel, and facilities. The Funds shall be used at the Town's sole discretion, as approved by the Town Manager and Town Council. Notwithstanding the Community Impact Donation, nothing shall prevent the Operator from making additional donations from time to time to causes that will support the Town, including but not limited to local drug abuse prevention/treatment/education programs. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 21Page 2688746A 2. Payments: Operator shall provide as a gift to the Town the greater of either(a) an annual total of Two Hundred Thousand and 00/100 Dollars ($200,000.00), 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 Marijuana,transactions conducted at the Facility. In either case,the Community Impact Donation Payments shall begin 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. Operator shall set aside an additional One Hundred Thousand and 00/100 Dollars ($100,000.00) annually for the purpose of reimbursing the Town for any verified expenses incurred by the Town. Such expenses include but are not limited to additional demands on local law enforcement agencies, including but not limited to police details, and other emergency services. Operator shall notify the Town when Operator commences sales within the Town. Operator shall 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. 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. The Operator shall not request any tax credits or subsidy from the Town for the development of land or the Facility, including, but not limited to, any request for a real estate tax exemption or abatement as a non-profit corporation, and shall not object or otherwise challenge the taxability of land or the Facility. Notwithstanding the foregoing, (i) if real or personal property is determined to be non-taxable or partially non-taxable, a determination of which the Operator agrees not to seek at any time during this Agreement or(ii) if the value of such property is abated with the effect of reducing or eliminating the tax which would otherwise be paid if assessed at fair cash value as defined in G.L. c. 59, §38, or(iii) if Operator is determined to be entitled or subject to exemption with the effect of reducing or eliminating the tax which would otherwise be due if not so exempted,then Operator shall pay to the Town an amount which when added to the taxes, if any, paid on such property, shall be equal to the taxes which would have been payable on such property at fair cash value and at the otherwise applicable tax rate, if there had been no abatement or exemption; this payment shall be in addition to the Community Impact Donation made by Operator under Section 2 of this Agreement. 4. Community Impact Donation as Comnensatorv: The Community Impact Donation referenced 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. HOST COMMUNITY AGREEMENT I—TOWN OF WATERTOWN, MA 3 1 P a g e 2688746.0 5. Local Hirine: The Operator shall work in a good faith, legal and non-discriminatory manner to hire local vendors, suppliers, contractors and builders who are Watertown residents, where possible. Town residency shall be a positive factor in hiring decisions at the Facility. 6. ADDroval 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. The 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. 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 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; (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. Operator shall not provide delivery services from the RMD. Notwithstanding the foregoing,the RMD shall allow qualified personal caregivers to obtain and transport marijuana from a RMD on behalf of a registered qualifying patient consistent with DPH guidelines, 8. Non-Medical Mariivana: The Operator, its successors, and assigns hereby agrees to waive any rights it has or may have to cultivate, sell or process non-medical marijuana or to operate a Marijuana Establishment as defined in G.L. c.94G §1 for non-medical use ("Recreational Use") at the site of its RMD Facility within the Town and hereby agrees that it shall not engage in cultivating, selling or processing marijuana and marijuana products for Recreational Use within the Town.. Notwithstanding the foregoing, and for the avoidance of doubt, the immediately foregoing provision shall be null and void and of no force or effect in the event that any of the following occur: 1) legislation is passed and/or amended by the Commonwealth of Massachusetts requiring that RMDs undertake Recreational Use for continued operation , or 2)the Town enacts an ordinance or passes a ballot question in accordance with applicable law authorizing Recreational Use, or 3) an unaffiliated entity from Operator is authorized to open a Recreational Use within the Town. The Operator further agrees that in the event the Operator becomes licensed and permitted to operate a Marijuana Establishment at the same location as the RMD, the HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 4JPage 2688746.0 parties shall renegotiate the terms of this Agreement, including but not limited to increasing the amount of the payments to be made to the Town, in recognition that the additional purposes of the RMD may have greater impacts and effects on the Town. In no case shall the annual Donation Payments be reduced from the amounts specified in this Agreement. 9. 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 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 shall maintain a cooperative relationship with the Police Department, including but not limited to periodic meetings to review operational concerns, security, delivery schedule and procedures, cooperation in investigations, and communication to the Police Department of any suspicious activities on or in the immediate vicinity of the Facility and with regard to any anti-diversion procedures. Such camera(s)may be altered by the DPH during their security and architectural review process upon approval by the Police Department. 10. Registration and Annrovals 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 final 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.If Operator fails to secure either a final Certificate of Registration,or any of the required municipal approvals aforementioned, this Agreement shall be null and void; however, in such circumstances, Operator shall reimburse the Town for its legal fees associated with the negotiation of this Agreement. 11. Cooneration: 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 and any other municipal requirements for operating a RMD,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 the Facility, including but not limited design and security 12. Sunnort 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. This Agreement shall not affect, limit, or control the authority of Town boards, commissions, and departments to carry out their respective powers and duties to decide upon and to issue, or deny, applicable permits and other approvals under the statutes and regulations of the Commonwealth, the General and Zoning Ordinances of the Town, or applicable regulations of those boards, commissions, and departments, or to enforce said HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 51Page 26887A6A statutes, ordinances and regulations. The Town, by entering into this Agreement, is not thereby required or obligated to issue such permits and approvals as may be necessary for the Facility to operate in the Town, or to refrain from enforcement action against the Operator for violation of the terms of said permits and approvals or said statutes, ordinances, and regulations. 13. Assignment: This Agreement is binding upon the parties hereto,their successors, assigns and legal representatives. Operator shall not assign, sublet or otherwise transfer this Agreement, in whole or in part,and shall not assign or obligate any of the monies payable under this Agreement, 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(the"Affiliated Entity") which will utilize the Facility for the purposes allowed herein and shall fully comply with the terms of this Agreement, and which is duly authorized by the DPH or other authorizing entity, or if such assignment or transfer is the result of a merger, acquisition, or consolidation with the Operator. For the purposes hereof, an"Affiliated Entity" shall mean an entity which is under common control with and/or an entity having related parties to (and any such related party transactions between entities have been approved by the DPH)the Operator. 14. 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. 15. Retention of Regulatory Authority: 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. 16. Notices: Any and all notices, consents, demands, requests, approvals 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 and will be effective upon receipt for hand or said delivery and three days after mailing, to the other Party at the following addresses: If to TOWN: Michael J. Driscoll,Town Manager 149 Main St. Watertown,MA 02472 If to OPERATOR: Aidan O'Donovan, COO NS AJO Holdings, Inc. 67 Dana Street, #1 Cambridge, MA 02138 Either party may update their notice address by giving notice thereof as aforesaid. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN,MA 61Page 26887a6.vr 17. 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. Further, Operator agrees it will not challenge, in any jurisdiction, the enforceability of any provision included in this Agreement; and to the extent the validity of this Agreement is challenged in a court of competent jurisdiction, Operator shall pay for all reasonable fees and costs incurred by the Town in enforcing this Agreement. 18. Governine 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. 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. 20. 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 Sections 10, 17, 22 and 23 hereof shall remain in full force and effect. 21. Term: This Agreement shall remain in place for the life of the Facility unless both parties agree otherwise. In the event Operator relocates the Facility to a different location within the Town, the terms of this agreement shall apply to such relocated Facility for the life of such Facility. 22. ADDronriation: The Treasurer of the Town shall hold the Community Impact Donation Payments in a separate account, to be expended by the Town without further appropriation pursuant to G.L Chapter 44, Section 53A. While the purpose of this agreement is to assist the Town in addressing any public health, safety and other effects or impacts the Facility may have on the Town or impacts of the Facility on the Town and on municipal programs, services, personnel, and facilities,the Town may expend the Community Impact Donation Payments at its sole and absolute discretion, as approved by the Town Manager and Town Council. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 71Page 2688746.vr 23. 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. This agreement shall be subject to the requirements of the Massachusetts Public Records Law. 24. Waiver: Except as otherwise provided herein, 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. 25. Amendment and Modification: This Agreement may only be amended or modified 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. 26. Headings: The article, section, and paragraph headings in this Agreement are for convenience of reference only, are no part of this Agreement and shall in no way affect, modify, define or be used in interpreting the text of this Agreement, 27. Counterparts: This Agreement may be signed in any number of counterparts, each of which is an original, and 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. 29. Third-Party Beneficiaries: Nothing contained in this Agreement shall create a contractual relationship with or a cause of action in favor of a third parry against either Town or the Operator. 30. The Town may terminate this Agreement at any time by providing written notice to the Operator. HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN, MA 8 1 P a g e 2688746.vl IN WITNESS WHEREOF,the parties hereto have executed this Agreement on the day and year first above written. '7 OF WATERTOWN NS AJO HOLDINGS,INC.: Michael riscolBr 1J�� Aidan O'Donovan Town Manager Chief Operating Officer 579691 MATR/0018 HOST COMMUNITY AGREEMENT —TOWN OF WATERTOWN,MA 91Page 2688746A Attachment C March 29, 2019 Via E-Mail Watertown Town Manager 149 Main Street Watertown, MA 02472 Re: NS AJO Holdings Inc. —23 Elm Street Dear Mr. Driscoll, Reference is hereby made to that certain Host Community Agreement by and between NS AJO Holdings Inc., a Massachusetts corporation with a principal office address of 67 Dana Street, Unit#1, Cambridge, MA 02138 (the "Operator") and the City known as the Town of Watertown, a Massachusetts municipal corporation with a principal address of 149 Main Street, Watertown, MA 02472 (the "Town") dated July 12, 2017 (the "Agreement"). Pursuant to Section 8 of the Agreement, if the Operator becomes licensed and permitted to operate an adult use Marijuana Establishment at the same location as the Registered Marijuana Dispensary, the Operator and the Town shall renegotiate the terms of the Agreement, including but not limited to increasing the amount of the payments to be made to the Town. Unfortunately, this creates a chicken and egg problem. The Operator cannot apply for the CCC license without a Host Community Agreement Certification from Watertown, but Watertown is not yet obligated to negotiate with the Operator. At this time, the Operator is writing to respectfully request that the Town execute the Cannabis Control Commission's (the "CCC") Host Community Agreement Certification form so that it may apply for a license for a Marijuana Establishment from the CCC pursuant to Section 8 of the Agreement. As consideration for this accommodation, the Operator proposes that this letter serve as formal written confirmation of the parties agreement, that. "Notwithstanding anything to the contrary in the Agreement or any other understanding between the Town and the Operator,Watertown shall execute and deliver the Host Community Agreement Certification, and Operator hereby acknowledges, confirms and agrees that it will not open an adult use Marijuana Establishment, unless and until the Town and Operator amend the Agreement pursuant to Section 8 thereof and incorporating an adult use Marijuana Establishment use therein at the Property. The Town further acknowledges, confirms and agrees that it shall negotiate in good faith with the Operator to execute said amendment to the Agreement and shall not unreasonably withhold any approval thereof, by the requisite Town official, representative, council, committee or board. If you are in agreement with the foregoing terms, please execute this Agreement below where indicated. Executed under seal, and for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged. Very Truly Yours, NS AJO Holdings Inc. a4l-� By:Aidan O'Donovan Its: President Accepted and Agreed to: The Town of Watertown By: Michael J. Driscoll Its: Manager Attachment D Natural Selections (NS AJO Holdings, Inc.) Presentation to Watertown Town Council Committee on Economic Development and Planning July 16, 2019 Timeline Phase 1: Initial State and Local Licensing & Permitting Phase 2: Financing, Design and Construction Phase 3: Final Approvals and Opening O Phase 1 : Initial State and Local Licensing & Permitting 0 State Application of Intent Submitted June 6,2015 Letter of Support Issued from Watertown Town Council July 12,2017 # State Invitation to Submit Management and Operations Profile State Provisional Certificate of Registration Issued for Watertown September 15,2015 July 21,2017 State Management and Operations Profile Submitted Fitchburg Special Permit Process October 27,2015 June 22,2017—November 6,2017 Site Identification and Acquisition Work January 2016—May 2016 State Invitation to Submit Siting Profile July 26,2016 Watertown Town Council Process August 18,2016—July 12,2017 State Siting Profile Submitted Decebler 14,2016 Watertown ZBA Process December 6,2016—June 28,2017 Phase 2 : Financing, Design and Construction Engage Urban Grow(Cultivation Facility Equipment Supplier)and 0 Fitchburg Cultivation Capital Raise i Fuss&O'Neil(Facility Engineering Team)to further Develop September 2017—October 2018 * Cultivation Facility Design May—August 2018 State Architectural Review Application Filing for Fitchburg August 21,2017 Due Diligence and Purchase of Cultivation Facility June-July 2018 State Architectural Review Walkthrough for Fitchburg February 13,2018 State Architectural Review Application Filing for Watertown October 4,2018 Outreach to DPH for Fitchburg Architectural Review Approval March 15,2018 Outreach to DPH for Watertown Architectural Review Walkthrough November 26,2018 Outreach to DPH for Fitchburg Architectural Review Approval Outreach to DPH for Watertown Architectural Review Walkthrough April 6,2018 December 6,2018 Extension of Watertown Special Permit April 9,2018 Outreach to DPH for Watertown Architectural Review Walkthrough January 17,2019,January 22,2019&January 31,2019 Outreach to DPH for Fitchburg Architectural Review Approval Engage Seaver Construction and Begin Cultivation Construction April 18,2018 January 10,2019—March 1,2019(receipt of building permit) * Outreach to DPH for Fitchburg Architectural Review Approval April 25,2018 Engage Nagog Construction and Begin Watertown Construction November—December 20,2018(receipt of building permit) Phase 3 : Final Approvals and Opening j Watertown Construction Process: j Outreach to CCC re Waiver Request December 2018—June 2019 March 15,2019 Begin Waiver Request with CCC Inquiry to open Watertown without Completed Cultivation • Outreach to CCC re Waiver Request February4,2019 April 1,2019 Outreach to CCC re Waiver Request * Waiver Request Form Released by CCC February 11,2019 June 6,2019 Outreach to CCC re Waiver Request Waiver Request Application Filed February 14,2019 June 24,2019 Outreach to CCC re Waiver Request Continued Pursuit of Waiver February 19,2019 July—September,2019 Q Outreach to CCC re Waiver Request Fitchburg Construction Complete February 20,2019 October 2019 Outreach to CCC re Waiver Request Final License from CCC February 27,2019 November—December 2019 Outreach to CCC re Waiver Request Open Doors March 4,2019 January 2020 Cannabis in Massachusetts ; Commission Cannabis Control COAIKJONWFALTH OF MASS1CHCSETTS Massachusetts Industry Snapshot: 3,570 Applications, 435 Completed 172 Retail Applications Suffolk Total gross sales: $176 mil (since Nov, 14 2018) Current HCAs approved in Boston: 11 1 Dukes Q Nantucket As of June 7, 2019 Area Cannabis Licenses 1 8!IMON COUniry f%Q 1Y',`.I+I�Ala l,I Ht YFrSrallhll fgW6Ck �1VIrt Y�ert ly�U I113 N131J%* S9LIi NL a n avr6 SqucNr f�1 eel.n{.. 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Any customers doing so will be banned from the facility. • Retailers are prohibited from selling products containing nicotine or alcohol. • • • Retailers must utilize seed to sale tracking systems. • Signage, displays, or advertising of any material or products that depict marijuana is strictly prohibited. • Retailers cannot sell more than 1 ounce of flower or 5 grams of concentrate per transaction. ■No ■Yes MARIJUANA DISPENSARY FOR NS AJO HOLDINGS 23 ELM STREET, 13UILDING 2, WATERTOWN, MA 02472 DATE: D8-20-2018 OWNER: SURVEYOR; DRAWING FIST AfLY81Y QbDL3Qv8M1 VTP A99OC1e1By oLs of salu l eN w.is ra wu rnn!I Fxle AIPw L1111lA NS IJ4 PtkWp .kor FlaLnr-r B 91 EAMTFrf.SITE PrIOrOfi � F E7�SFEW61 kM Ad ..9L-..I a] C1-MAMM REII ew, gw4mepL.Yr..rr.rraWim PM YA5ONS& I toF414Ai41ysk!+a3a�+FLFu W �_a 614—iAkYZFUCaRftMMW.PrI ITri I f F4 REPRESENTATI'VE: TRAFFIC ENGINEER: Al PkDfWdaPLi%MCE A0 FLAJew'Amw w"1 ItiAl�¢QI.Pmmi to 3i i1 I9A PI�YYpg Lg6iI Tye LLP #liytl E11gIF1iiMLig Illt. ■d J4.P82PONf11 E"THrrF"IAn1"C: p(Grob JiDL PH-LT%gidFJF'MTI[>r,firr EluiY5T4G liblL4 '✓•q/L6VIYGCrHKFAYSAF+M•1N , M'l011*1YYgfY4Y+.d18EP AF�.]!�/MSOR�Vl1ANFN1I N[fllI II VA14l,L4lr;%"m 711-14M ATAQ EltAMWFkNAM*;NTEFOOR ELL-eAT a ist01RIFYPA}OSFNRS1�541-NffF 41-I AND SECnykMARCHFrECT: SECURITY= am-"0111-L wIP]■ZI . sIYxlxY imri % 60Lrg18l OkuEl&A5S8CihlLES K[pll h11 b1 FrxfirE6Pr�.1o��F 1i81.i..,na.4wn9owl 1}YQ[1phllfY,+l•iYl�e4.wr ro>I rLo� F[wrgn.lrx nwrt RJJL law � r C..f,hly YA4-0C17E nF'IIS.t<V.4WSP RUD 1LIOAS 0MUE GRFLE PLM ---I- SiTAI:� MMV1070 Fial, M PL MSCIEDUL.E1 EL44 STRUT f Isamm"t " -I"""DSTRUMRAL ENC-INEER; I 91.WILET 5N1010EF[ The dE se Group.INC. k401 IECHANC/LICHEBB J IrF41-IY o= aWYm T9 g1 :.■PA[x]4'� RIL.k L7eu�n+ey Icl Iv-1�CJIIrJOM�aYMFlrr�•aw t:■xtrx�x� F •OFL.}L W 'L14 LY4.•J W YA le l- LO4ri YLFIi 1 L .l el CrlrrrAL LlLlanw.a•.r<� ELM EaELTA1f.LL Wl E W LE5 N.0 RSERS MEP: F,N MrT1XfJL�rF-a �- F100 FafLTArG&sKcF:"T10hfi GoFF6u�LIFFg EI►gineering 6eFxlcee,uc. __ H!-JIdi1 Fl Fir Sf Pi�rYl^�'If1 FiiMIYf.Ft AN Vf1i W4�N11_ll im% 129 Csmrve R m'.SLOV XN eNhM1.hYl+►141R,4Yi7 SL[ IPJLLIO IFD S.lhG*J140.[} fil L r.Im.Lx Xw mm 99D a M, SEL�di fLOG1 ft" pr nfipn¢yan 1ECana.l"%WftWNU DOUGLAS OWN ASSOCIATES two, .r . +, OIY111HY71Y,�0:4fQq�r¢puF4pc4r Iw.wdv tntx, , _ ar 2 A��-_ � \ ;mx \»2 � _ Z § 9 §a« 9 TREE! R ./2 �"` � PIMA, P m . �� e a a a i 4 - 1 lei ' I r w F r u n lid • ..-�.-.� - DOUGLAS OWN t ASSOCLAM, RIC, AALkNA)ANkDlSg'KARY NSA4X' QMICi$ 11 d+++i4 :�F�Y. 4 +4�10�►! FE{0. MNWLW WIW4Y.�4W .� I El -- co � f In o «� I E+1 ,or. 1 I isr F1 rry.rxLctt*r. D F r f w N� , ��,_,;,,,,�--••..,—;�t` DOV%WOICUN $AWC<UTMr W- AMxf1 UANk615PE�xkY FOR NSAJO OL6ir4GS 11 Mm.sr+�2.*Wm mw,� CaM I _�,... .,r.,.�_ E GSTING FLOOR PLAN ....: I..'" �'Y" F .01 ilarulaairu+.r5l.aau - u .y. { �••`•••-- „� iS '-�ii1.LL 'y'J 'I.Ly.l.ii�l.i�ili �W' T + I �r #` i•�ir a x_ _ �iYr w•r�'.r��r.��.�N'r xr4 i ti. Ma Gl L T1!":t=-LLs4 LLWA, 111tY. I -w p - . .... .-Pw donr��nrxM No or w Al rpA �IYR FLOFlt.rRUlOBEG �Yl Dil�/iL - - _`_ _.I .DOW"OKUN 4L A AMA W. _ AMARLM.1+MDISKNI+ JkYFORNSmO 114LDINGS PROPOSED FLOOR PLAN r. r--r- I ""' r.t. *01 �%T: k � 4 �Y�I i111� MM YFK+�Jw#+ -- 1 I�ImLf iLFVAr104•lMOIUZW ariwi •wxa+lva Intl Lnr�orr _ 7JtMA .P.ILIIAIr1%.FIIMR I-ll alum 1 u3.t11111 rlLarcacEa �_III.txT.wu►.e�r3hraL��: ryU}IYY4{I A,MAFMUAf4A DiSPIN 5-i y FOk ri5 AJO HOIDINGS I SYE4U oaf-,L-Ww4+ JOAO34# 01 AS- �.:�• �+-+;��� PR4P33EOELEVA"UN3 rN 1 F.• T u', L f ..yam �_�� �' � -- - _ '_ - "Rs � � r •'�p� �Y � f �� � � � � �� � r .. .7 _. r J «� a i rLOn Security • Customers must be above 21 years of age. • Employees are required to pass a series of state and national background checks all of which is regularly reviewed by state agency. • Law enforcement and state officials are allowed access. • Two-door entry way to ensure only approved persons may enter the facility. • A description of the Marijuana Establishment's hours of operation and after-hours contact information shall be provided to the Cannabis Limited Access Control Commission and made available to law enforcement officials upon request. Security • Employing a live security guard during dispensary hours. • Granting access to video access feeds to state and local police departments. • Architectural and Operational Security measures address items such as perimeter barriers, lighting, critical building services, spatial adjacencies, control barriers, as well as staff and public access. • Electronic Security measures address items such as access control and alarm monitoring, video surveillance, and security communications. Secure Facility Design and Systems • Developing security protocols and systems that exceed the requirements set forth by the Commonwealth of Massachusetts. • Implementing and patrolling state of the art interior and exterior video surveillance systems, alarms, and duress systems. • Utilizing redundant systems that operate even in the instance of a power outage. Timeline for Opening Watertown Adopted Zoning Submit Application Local Permitting(HCA, ZBA) Regulations for Adult-Use for HCA July-September, 2019 Final Inspections and License November 27, 2018 April 19, 2019 January—February 2020 Initial Outreach to Meeting with Town Provisional Licensure(CCC) Open Doors Watertown Council Committee November—December, 2019 March 2020 February 2019 July 16, 2019 Community Benefits • Job creation (15 - 20 positions) - • Enhanced security in and outside the facility. - ""1uR : s r I • Community engagement and support for local initiatives. • Host Community Agreement and - increased tax revenue • Charitable Contributions ` f • Educational Seminars +' a Attachment E TOWN OF WATERTOWN AND NS AJO HOLDINGS, INC. HOST COMMUNITY AGREEMENT THIS HOST COMMUNITY AGREEMENT ("AGREEMENT') is entered into this day of July, 2019 by and between NS AJO HOLDINGS, INC., a Massachusetts incorporated company, and any successor in interest, with a principal office address of 67 Dana Street, #1, Cambridge, MA 02138, (the "Company"), and the Town of Watertown, a Massachusetts municipal corporation with a principal address of 149 Main Street,Watertown,MA, 02472 (the "Town"). WHEREAS, the Company wishes to operate a recreational marijuana retail establishment(a"Retail Establishment") on the property located at 23 Elm Street, Watertown, MA 02472 (the "Property"), in accordance with and pursuant to applicable state laws and regulations, including, but not limited to 935 CMR 500.00, and such approvals as may be issued by the Town in accordance with its Zoning Bylaws and other applicable local regulations (the "Facility"); and WHEREAS,the Company is still in the process of opening a Medical Marijuana Treatment Center as defined by the Commonwealth of Massachusetts Department of Public Health (the "DPH") as a not-for-profit entity registered under 105 CMR 725.100, known as a registered marijuana dispensary (an "RMD"), and is seeking to co-locate a Retail Establishment in accordance with 935 CMR 500.00 and 935 CMR 502.000, subject to all required local permits and required licenses from the CCC (as defined below); and WHEREAS, the Company intends to provide certain benefits to the Town in the event that it receives the requisite licenses from the Commonwealth of Massachusetts Cannabis Control Commission (the "CCC"), or such other state licensing or monitoring authority, as the case may be, to operate the Facility and receives all required local permits and approvals from the Town; and WHEREAS, the parties intend by this Agreement to satisfy the provisions of G.L. c.94G, §3(d), applicable to the operation of the Facility, such activities to be only undertaken in accordance with the applicable state and local laws and regulations in the Town. NOW THEREFORE, in consideration of the mutual promises and covenants set forth herein, and other good and valuable consideration,the receipt and sufficiency of which are hereby acknowledged, the Company and the Town agree as follows: 1. Recitals The Parties agree that the above Recitals are true and accurate and that they are incorporated herein and made a part hereof. 2. Annual Pavments In the event that the Company obtains the requisite licenses and/or approvals as may be required for the operation of a Facility, and receives any and all necessary and required permits and licenses of the Town, and at the expiration of any final appeal period related thereto, said matter not being appealed further, which permits and/or licenses allow the Company to locate, occupy and operate the Facility in the Town, then the Company agrees to provide the following Annual Payments: A. Community Impact Fee The Company anticipates that the Town will incur additional expenses and impacts on the Town's road and other infrastructure systems, law enforcement, fire protection services, inspectional services, and permitting and consulting services, as well as unforeseen impacts on the Town. Accordingly, in order to mitigate the financial impact on the Town and use of Town resources,the Company agrees to pay an Annual Community Impact Fee to the Town,in the amount and under the terms provided herein. 1. Company shall annually pay an Annual Community Impact Fee in an amount equal to three percent (3%) of the gross sales from marijuana and marijuana product sales at the Facility. 2. The Annual Community Impact Fee shall be made quarterly per the Town's fiscal year(July 1- June 30). The Annual Community Impact Fee for the first quarter of operation shall be prorated. This Agreement, and the Annual Community Impact Fee shall continue for a period of five (5)years (the "Term"). 3. The Town shall use the above referenced payments in its sole discretion,but shall make a good faith effort to allocate said payments to offset costs related to road and other infrastructure systems, law enforcement, fire protection services, inspectional services, public health and addiction services and permitting and consulting services, as well as unforeseen impacts upon the Town. B. Additional Costs, Pavments and Reimbursements 1. Permit and Connection Fees: The Company hereby acknowledges and accepts, and waives all rights to challenge, contest or appeal, the Town's building permit fee and other permit application fees, sewer and water connection fees, and all other local charges and fees generally applicable to other commercial developments in the Town. 2. Facility Consulting Fees and Costs: The Company shall reimburse the Town for any and all reasonable consulting costs and fees related to any land use applications concerning the Facility, negotiation of this and any other related agreements, and any review concerning the Facility, including planning, engineering, legal and/or environmental professional consultants and any related reasonable disbursements at standard rates charged by the above- referenced consultants in relation to the Facility. 3. Other Costs: The Company shall reimburse the Town for the actual costs incurred by the Town in connection with holding public meetings and forums substantially devoted to discussing the Facility and/or reviewing the Facility and for any and all reasonable consulting costs and fees related to the monitoring and enforcement of the terms of this Agreement, including,but not limited to independent financial auditors and legal fees. 4. Late Pavment Penalty: The Company acknowledges that time is of the essence with respect to their timely payment of all funds required under Section 2 of this Agreement. In the event that any such payments are not fully made with ten(10) days of the date they are due, the Town shall provide the Company with written notice of such failure to make a timely payment. The Company shall have a ten (10) day period to cure such failure to make timely payment from the date of receipt of such notice. If the Company fails to make full payment within such cure period, the Company shall be required to pay the Town a late payment penalty equal to five percent(5%) of such required payments. C. Annual Reporting for Host Communitv Impact Fees and Benefit Pavments The Company shall maintain books, financial records, and other compilations of data pertaining to the requirements of this Agreement in accordance with standard accounting practices and any applicable regulations or guidelines of the CCC. All records shall be kept for a period of at least seven (7) years. Upon request by the Town, the Company shall provide the Town with the same access to its financial records (to be treated as confidential, to the extent allowed by law) as it is required by the CCC and Department of Revenue for purposes of obtaining and maintaining a license for the Facility 3. Local Vendors and Emplovment To the extent such practice and its implementation are consistent with federal, state, and municipal laws and regulations, the Company will make every effort in a legal and non-discriminatory manner to give priority to local businesses, suppliers, contractors, builders and vendors in the provision of goods and services called for in the construction, maintenance and continued operation of the Facility when such contractors and suppliers are properly qualified and price competitive and shall use good faith efforts to hire Town residents. 4. Local Taxes At all times during the Term of this Agreement, property, both real and personal, owned or operated by the Company shall be treated as taxable, and all applicable real estate and personal property taxes for that property shall be paid either directly by the Company or by its landlord and neither the Company nor its landlord shall object or otherwise challenge the taxability of such property and shall not seek a non-profit or agricultural exemption or reduction with respect to such taxes. Notwithstanding the foregoing, (i) if real or personal property owned, leased or operated by the Company is determined to be non-taxable or partially non-taxable, or (ii) if the value of such property is abated with the effect of reducing or eliminating the tax which would otherwise be paid if assessed at fair cash value as defined in G.L. c. 59, §38, or(iii) if the Company is determined to be entitled or subject to exemption with the effect of reducing or eliminating the tax which would otherwise be due if not so exempted, then the Company shall pay to the Town an amount which when added to the taxes, if any, paid on such property, shall be equal to the taxes which would have been payable on such property at fair cash value and at the otherwise applicable tax rate, if there had been no abatement or exemption; this payment shall be in addition to the payment made by the Company under Section 2 of this Agreement. 5. Security To the extent requested by the Town's Police Department, and subject to the security and architectural review requirements of the CCC,or such other state licensing or monitoring authority, as the case may be, the Company shall work with the Town's Police Department in determining the placement of exterior security cameras. The Company agrees to cooperate with the Police Department,including but not limited to periodic meetings to review operational concerns, security, delivery schedule and procedures, cooperation in investigations, and communications with the Police Department of any suspicious activities at or in the immediate vicinity of the Facility, and with regard to any anti-diversion procedures. To the extent requested by the Town's Police Department,the Company shall work with the Police Department to implement a comprehensive diversion prevention plan to prevent diversion, such plan to be in place prior to the commencement of operations at the Establishment. 6. Community Imuact Hearing Concerns The Company agrees to employ its best efforts to work collaboratively and cooperatively with its neighboring businesses and residents to establish written policies and procedures to address mitigation of any concerns or issues that may arise through its operation of the Facility, including, but not limited to any and all concerns or issues raised at the Company's required Community Outreach Meeting relative to the operation of the Facility; said written policies and procedures, as may be amended from time to time, shall be reviewed and approved by the Town and shall be incorporated herein by reference and made a part of this Agreement,the same as if each were fully set forth herein. 7. Additional Oblieations The obligations of the Company and the Town recited herein are specifically contingent upon the Company obtaining a license for operation of the Facility in the Town, and the Company's receipt of any and all necessary local approvals to locate, occupy, and operate the Facility in the Town. This agreement does not affect, limit, or control the authority of Town boards, commissions, and departments to carry out their respective powers and duties to decide upon and to issue, or deny, applicable permits and other approvals under the statutes and regulations of the Commonwealth, the General and Zoning Bylaws of the Town, or applicable regulations of those boards, commissions, and departments or to enforce said statutes, Bylaws, and regulations. The Town,by entering into this Agreement, is not thereby required or obligated to issue such permits and approvals as may be necessary for the Facility to operate in the Town, or to refrain from enforcement action against the Company and/or its Facility for violation of the terms of said permits and approvals or said statutes, Bylaws, and regulations. 8. Support The Town agrees to submit to the CCC, or such other state licensing or monitoring authority, as the case may be, the required certifications relating to the Company's application for a license to operate the Facility where such compliance has been properly met,but makes no representation or promise that it will act on any other license or permit request, including, but not limited to any zoning application submitted for the Facility, in any particular way other than by the Town normal and regular course of conduct and in accordance with its rules and regulations and any statutory guidelines governing them. 9. Term Except as expressly provided herein, this Agreement shall take effect on the date set forth above, and shall be applicable for the Term as referenced in Section 2.A.2 of this Agreement, as long as the Company operates the Facility in the Town. Upon expiration of the Agreement, the parties may extend or renegotiate the terms of this Agreement 10. Successors/Assigns Neither the Company nor the Town shall not assign, sublet, or otherwise transfer their rights nor delegate its obligations under this Agreement,in whole or in part,without the prior written consent of the other party, which consent shall not be unreasonably withheld; provided however such consent shall not be required in the event such transfer or assignment is between the Operator and another entity which is authorized by the CCC or other authorizing entity to operate the Facility for dispensing of marijuana, or if such assignment or transfer is the result of: (i) an affiliate entity of the Company; or(ii) an entity which controls, is controlled by, or is under the common control of the Company; or(iii) to an entity into or with which Company may be merged or consolidated or by which it is acquired. 11. Notices Any and all notices, consents, demands, requests, approvals 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, and 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. To Town: To Company: 12. 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 the either party would be substantially or materially prejudiced. 13. Governing Law This Agreement shall be governed by, construed and enforced in accordance with the laws of the Commonwealth of Massachusetts, and the Company submits to the jurisdiction of any of its appropriate courts for the adjudication of disputes arising out of this Agreement. 14. Entire Agreement This Agreement, including all documents incorporated herein by reference, constitutes the entire integrated agreement between the Company and the Town with respect to the matters described herein. 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. 15. Amendments/Waiver: Amendments, or waivers of any term, condition, covenant, duty or obligation contained in this Agreement may be made only by written amendment executed by authorized representatives of both parties to the original Agreement, prior to the effective date of the amendment. 16. Headings: The article, section, and/or paragraph headings in this Agreement are for convenience of reference only, and shall in no way affect, modify, define or be used in interpreting the text of this Agreement. 17. Counterparts This Agreement may be signed in any number of counterparts all of which taken together, each of which is an original, and all of which shall constitute one and the same instrument, and any party hereto may execute this Agreement by signing one or more counterparts. 18. Signatures. Facsimile signatures affixed to this Agreement shall have the same weight and authority as an original signature. 19. No Joint Venture: The Parties hereto agree that nothing contained in this Agreement or any other documents executed in connection herewith is intended or shall be construed to establish the Town, or the Town and any other successor, affiliate or corporate entity as joint ventures or partners. 20. Nullity This Agreement shall be null and void in the event that the Company does not locate a Retail Establishment in the Town or relocates the Facility out of the Town. Further, in the case of any relocation out of the Town, the Company agrees that an adjustment of Annual Payments due to the Town hereunder shall be calculated based upon the period of occupation of the Facility within the Town,but in no event shall the Town be responsible for the return of any funds provided to it by the Company. 21. Third-Parties Nothing contained in this agreement shall create a contractual relationship with or a cause of action in favor of a third party against either the Town or the Company. IN WITNESS WHEREOF, the parties hereto have executed this Agreement on the day and year first written above. TOWN OF WATERTOWN NS AJO HOLDINGS, INC. NAME Aidan O'Donovan [POSITION], On behalf of NS AJO HOLDINGS, INC. On behalf of the Town of Watertown k12 P RinceLOBeL Attachment F April 16, 2019 Via E-Mail Delivery Steven Magoon Community Development& Planning, Director Town of Watertown 149 Main Street Watertown, MA 02472 Dear Director Magoon: This office represents NS AJO Holdings, Inc., in connection with the permitting and licensing of its co-located Medical Marijuana Treatment Center(the"MMTC") and Adult Use Marijuana Establishment(the"ME")at 23 Elm Street, Watertown, MA 02472 (the"Property"). Pursuant to our discussion, attached please find a proposal for the Adult Use Marijuana Retail Establishment phase of this project at the Property. As you know, NS AJO Holdings, Inc., currently holds a provisional license to operate the MMTC at the Property and is actively engaged in renovating and outfitting the Property for this use. NS AJO Holdings, Inc. intends to open the MMTC as soon as possible. However, given the recent shift of oversight and regulatory authority of the Massachusetts Medical Marijuana Program from the Massachusetts Department of Public Health to the Massachusetts Cannabis Control Commission, it is unclear at this time when the MMTC portion of this project will open. NS AJO Holdings, Inc., will continue to pursue approvals to open a MMTC at the Property. Notwithstanding its intention to actively pursue the opening of its Medical Marijuana Treatment Center at the Property, NS AJO Holdings, Inc., is also acutely aware of the timeline associated with the state licensing approval process for an Adult Use Marijuana Establishment. Accordingly, and pursuant to the attached proposal, NS AJO Holdings, Inc. is seeking to engage the Town of Watertown in discussions for the Adult Use Marijuana Establishment phase of this project. We would welcome the opportunity to meet with you and your team, or the appropriate Town Council committee, in order to start the process of amending the existing Host Community Agreement to permit an Adult Use Marijuana Retail Establishment at the Property. Please also note that given the fully designed and developed nature of this project for both the MMTC and ME, NS AJO Holdings, Inc. is prepared to file an application to the Zoning Board for a Special Permit. If appropriate, we would request that NS AJO Holdings, Inc. be permitted to pursue both the Host Community Agreement amendment at a Special Permit simultaneously. I look forward with talking with you soon. prince Lobel Tye LLP Best regards, One International Place Suite 3700 Boston, MA 02110 Michael P. Ross TEL: 617 456 8000 Direct: 617-456-8149 Email: mrossC&.orincelobel.corn PAX: 617 456 8100 www.princelobel.corn 3177374.E l APPLICATION FOR A HOST COMMUNITY AGREEMENT FOR AN ADULT USE MARIJUANA ESTABLISHMENT NS AJO HOLDINGS INC. d/b/a Natural Selections 67 Dana Street#1 Cambridge, MA 02138 c/o Michael P. Ross, Esq. Prince Lobel Tye LLP One International Place, Suite 3700 Boston, MA 02110 Applicant Property Location: 23 Elm Street, Building 2 Watertown, MA 02472 Prepared by: Michael P. Ross, Esq. Prince Lobel Tye LLP One International Place, Suite 3700 Boston, MA 02110 Telephone: 617-456-8000 Email: mross@Drincelobel.com April 19, 2019 Table of Contents Application for a Host Community Agreement For an Adult Use Marijuana Establishment Property Location: 23 Elm Street, Building, 2 Watertown, MA 02472 Section I: Natural Selections Overview..........................................................................................4 ExecutiveSummary...........................................................................................................................5 Introduction to Business.................................................................................................................6 Descriptionof Project.......................................................................................................................9 ProjectTimeline.................................................................................................................................9 SectionI1: Security Plan..................................................................................................................... 10 GeneralSecurity Plan....................................................................................................................11 Secure Transportation Plan........................................................................................................16 Anti-Diversion Plan........................................................................................................................19 Anti-Loitering Plan.........................................................................................................................28 Section III: Business & Marketing Plan........................................................................................ 33 Business Operations and Marketing Plan..............................................................................34 Section IV: Benefits & Effects on the Town of Watertown...................................................39 Fiscal & Community Impact on the Town of Watertown................................................40 Job Creation for the Town of Watertown ..............................................................................41 Section VI: Mitigation &Prevention of Potential Adverse Effects ....................................44 Introduction......................................................................................................................................45 Preventing Increased Crime.......................................................................................................45 Preventing Drugged Driving.......................................................................................................46 Cannabisand Driving.....................................................................................................................46 Preventing Distribution to Minors...........................................................................................47 PreventingHealth Issues..............................................................................................................49 Other Potential Effects on Town...............................................................................................49 2 Section VII: Best Practices &Standard Operating Procedures........................................... 52 Quality Control Best Practices....................................................................................................53 WasteDisposal Plan.......................................................................................................................54 Section VIII: Plans and Renderings............................................................................................. 57 3 Section I : Natural Selections Overview Executive Summary NS AJO Holdings d/b/a"Natural Selections"("Natural Selections,"or"the applicant") is a Massachusetts-based company committed to serving cannabis patients and customers in Watertown,Massachusetts.Natural Selections is an established organization committed to providing access to quality natural cannabis 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("Natural Selections,Colorado"), which has emerged as a leading cannabis 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 all regulations, 2) Safe, consistent and effective products of the highest quality, 3) Commitment to serving and educating customers, and 4) Commitment to scientific research and development. Natural Selections has assembled a team of experienced professionals excited to dedicate their business and cultivation expertise to produce cannabis in Massachusetts. The team is led by Aidan O'Donovan, an experienced cultivator and cannabis business owner. The applicant plans to build collaborative relationships with state and local governments to ensure a seamless integration into the community it serves.Natural Selections is committed to hiring local citizens and will ensure that a considerable portion of its workforce is from Watertown.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. The applicant is committed to supporting Town charities and will offer up to 3%of gross sales annually towards local causes. The applicant will also set aside funds annually to offset any additional or unforeseen issues that may affect the Town, such as additional demands on local law enforcement agencies, increased use of Town infrastructure, or the need for additional Town infrastructure, employees and equipment. Additionally,Natural Selections will establish ongoing community dialogues and seminars in order to provide transparency about its operations and education about the responsible use of cannabis. The team has extensive experience operating a safe and compliant dispensary. Founder Aidan O'Donovan is also the founder of a dispensary in Northglenn, Colorado. O'Donovan, and partner Brandon Banks will lead the team in all elements of developing, implementing, and maintaining a cannabis operation. With regard to cultivation,Banks 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 has been working in the Colorado cannabis industry since 2010.Prior to co-founding Natural Selections, Banks cultivated and bred several award-winning cannabis strains while working as the Master Grower for Green Man Cannabis. He was featured in the book,Big Weed, as a cultivation expert. Brandon Banks has a wealth of business experience and financial expertise from his time working Aidan O'Donovan and Co-Founder Brandon Banks will be responsible for matching the needs of patients and customers with the most effective health solutions,while ensuring that the operation is in compliance with all regulations. The founders' experience will also be critical to establish the business operations in a timely fashion to ensure that local residents have access to the dispensary as quickly as possible. 5 Natural Selections is committed to operating a highly secure and compliant dispensary in Watertown. To this effect,the applicant has engaged Dan Linskey,the former Superintendent-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 Town's history, including the Boston Marathon Bombings and the Occupy Movement. He has strong relationships with local law enforcement agencies throughout Massachusetts and Watertown, and will uphold Natural Selection's commitment to security as well as a seamless integration into the Watertown community. The team believes that Natural Selections will be instrumental in helping to create a strong cannabis industry in Massachusetts,where citizens are guaranteed safe and secure access to cannabis in a manner compliant with all state and local regulations. Introduction to Business Natural Selections intends to design and develop the dispensary while prioritizing efficiency, safety, community, and future development.Natural Selections is committed to creating a sense of community through its dispensary,which will create a shared sense of responsibility among customers and employees. To this effect,the applicant will invest in a spacious and inviting design to ensure that customers feel comfortable within the dispensary and have sufficient time to discuss all questions and concerns with dispensary agents. In addition to creating an inviting establishment for its patients and customers,the applicant is committed to implementing extensive security measures that will comply with all state and local regulations.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 premises. Dan Linskey will lead the Natural Selections team in designing and developing a secure dispensary and cultivation facility. Natural Selections has developed its business plan based on three commitments: high-quality products tailored for recreational use and 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 customers and patients with high quality cannabis that offers palliative care and pain relief,while reducing the side effects 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 company has taken a scientific approach to strain development,aggregating data based on patient feedback and carefully studying plant and terpenoid profiles. 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 6 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, cannabinoid profiles,regulation updates, as well as the applicant's services and programs. Although the applicant intends to focus on recreational sales, they have studied the medical conditions eligible for treatment under current regulations 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-dominant CBD-rich strain popular among patients suffering with Multiple Sclerosis. Patients have noted that this strain was helpful in mitigating symptoms such as pain, muscle 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/low-THC 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 chemotherapy—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. Spectrum#12 Spectrum#12 contains the cannabinoid 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 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. 7 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 cannabis industry. Natural Selections will only offer quality, lab tested products. The applicant guarantees that all batches of cannabis are tested at a certified laboratory for potency,terpenes,metals, pesticides, and microbials, as well as THC/CBD content. The results of these tests will be displayed on the packaging of all products. As per the regulations,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 customer or patient's specific ailments and needs. The applicant will provide extensive educational materials in its dispensary as well as on its website. Its website will have an extensive R&D section that posts information on all strains produced along with current testing results.Natural Selections' website will also have a research portal that shares reliable medical journal articles from high profile entities such as GW Pharmaceuticals, so qualifying customers,patients and dispensary agents are able to conduct their own research concerning the medicinal benefits of cannabis. 3) Best Practices for Cultivation,Processing, & Manufacturing Natural Selections is committed to maintaining high standards of production throughout all elements of the cultivation and processing recreational and medical cannabis. Chief Operating Officer Brandon Banks will lead the team in managing, tending, and cultivating the plants throughout all stages of the cultivation and dispensing process. Banks 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 strains 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 minimal 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 the overall quality of finished product. 8 Description of Project Natural Selections has identified 23 Elm St as an ideal location in which to establish its dispensary. This facility is located in the Town of Watertown,where there are approximately 287,000 residents living in the area and the surrounding regions. As previously mentioned, although the applicant will be focusing on the adult-use market,Natural Selections will offer medicinal strains and discounts to subsidize the excise tax for medical patients. The Project contains sufficient off-street parking to allow customers 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 include various security and safety equipment and technology, including but not limited to secure sally port, 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, and the operation will fully comply with Massachusetts guidelines. Project Timeline The Applicant has nearly completed its buildout for a Medical Marijuana Dispensary at the facility.As such,there is no construction component to this project. Contingent on its approval from the Town of Watertown,the Applicant will be filing its application with the Cannabis Control Commission and anticipates approximately a six month timeline from submission to final approval pursuant to its expedited review status as an existing medical marijuana license holder. 9 Section II : Security Plan General Security Plan Natural Selections operates in a high-risk security environment and is committed to implementing extensive security measures to protect customers,patients, caregivers, employees,and the general public.Natural Selections has designed an extensive security plan that will comply with all state and local regulations. 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 Plan(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 dispensary 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 dispensary 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 staff)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 originating 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 other unauthorized individuals. 11 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 • Access Control System • Entry&Exit Door Interlock System Architectural Security Prevention Measures To prevent armed violence,the applicant will focus on implementing measures 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 the 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 walling over two single metal doors, one double metal door and four metal-framed windows that exist along the building perimeter. Doors concealed in walls will be securely bolted from the interior side. Security mesh fastened to surrounding masonry will secure concealed windows. Security mesh will also be utilized to harden 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 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 commercial-grade 1,non-residential locks. Additionally, exterior locks and limited access area entries must be equipped with electric strike and biometric access hardware and be automatically locking. 12 Electronic Security Prevention Measures 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 dispensary or related facilities. As per the regulations,the applicant will implement access control and alarm monitoring,video surveillance, and security communications,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. Alarm Monitoring Intrusion detection for the Natural Selections dispensary is comprised of two independent commercial-grade alarm systems—a primary and a backup—to ensure an intrusion will be detected and reported should a 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. The intrusion alarm systems will be controlled by numeric keypad arming stations located inside the entry and exit doors. 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 current regulations, a duress alarm function will be provided at each PAS and BAS arming station to notify law-enforcement 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 detectors to ensure a device failure on one system will not compromise intrusion 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 current regulations. During non-business hours all cannabis will be stored in a locked, access-controlled space in a limited access area within the dispensary. The applicant's safe and vault for cash will be located in a restricted access area. A Limited Access Area means a building,room, or other indoor or outdoor area on the registered 13 premises of a dispensary where marijuana,MIPs, or marijuana by-products are cultivated, stored, weighed,packaged,processed, or disposed,under control of a dispensary,with access limited to only those dispensary agents designated by the dispensary. 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 1 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 numeric 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 the 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 Surveillance System The video surveillance system(VSS) 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 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 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 uninterruptible power source for continued operation during a power failure. 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, customers,patients, and caregivers is utilizing preventative methods. Natural Selections understands the importance of training dispensary agents to ensure that the they are able to perform the following: 1) execute all 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 emergency situation. 14 Closing& Opening Procedures 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 dispensary. 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 dispensary. This will ensure that the security equipment maintains proper surveillance of the dispensary. • 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 her own vehicle. Cash Management Security Each dispensary agent employee handling 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 biometric money safe separate from cannabis product. The vault will be kept in a limited access area. Department managers shall notify law enforcement when a potential risk is identified. Dispensary agents will be trained to identify suspicious activity from coworkers, customers,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 dispensary, 2) Loitering in the vicinity of the dispensary 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, or infractions to their direct managers immediately upon occurrence. Security system failures could include any alarm activation that requires response by local law enforcement,video failure, any acts of diversion, any destruction of cannabis in a manner that is not compliant with Natural Selections' waste disposal plan. Employees will be trained to respond in any situations involved with armed robbery or violence. Employees will be trained to respond appropriately in an 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 report will be provided to the Cannabis Control Commission identifying all 15 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 approved by the Cannabis Control Commission, on an annual basis. Audit report will be submitted to the Cannabis Control Commission 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. Secure Transportation Plan The applicant understands the risks presented by transporting recreational and medical cannabis and has designed an extensive security plan to ensure the safety of its employees and the Town 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. O'Donovan and Banks 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 state and local regulations. Transportation will only occur between the following: • Natural Selections' cultivation facility in Fitchburg to its dispensary 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 dispensary in secure vehicles. Only CCC-certified dispensary agents will be eligible to transport marijuana from the cultivation facility to the dispensary. The agents will receive extensive training to ensure that they are highly familiar with the regulations and all of Natural 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 vans 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 the following: a GPS system,heat and air conditioning suitable for 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. Transport routes will be randomized. The Security Director and Chief Operating Officer must 16 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 reportable incidents that occur during transport will be reported to the Department and local law enforcement within 24 hours,pursuant to the regulations. Guidelines for Shipping/Transport 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 F1owHub 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: i. Names and registration information for transportation agent. ii. Receiving licensed entity's name, address, and registration number. iii. Date and timestamps related to the transport. iv. Description of the marijuana or MIPS being transported. V. Weight of marijuana or MIPS being transported. vi. Mileage of the transporting vehicle at origination, at its destination, and the mileage back to its original destination. vii. 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. c. Upon arrival at the Natural Selections dispensary, an authorized dispensary agent must re-weigh,re-inventory, and account for on video all marijuana transported, within eight hours after arrival at the destination dispensary. The agent will log into F1owHub and compare the electronic manifest to the manifest presented by the transportation agent. The following information will be checked and confirmed: i. Names and registration information for transportation agent. ii. Receiving licensed entity's name, address, and registration number. iii. Date and timestamps related to the transport. iv. Description of the marijuana or MIPS being transported. V. Weight of marijuana or MIPS being transported. vi. Mileage of the transporting vehicle at origination, at its destination, and the mileage back to its original destination. vii. Signature from the cultivation agent creating the package as well as the transportation agent. The agents will be responsible for documenting and reporting any unusual discrepancy in weight or inventory to the Department and local law enforcement within 24 hours. 17 Upon arrival at an ISO-registered lab,an authorized laboratory employee agent will sign the manifest produced to the manifest delivered by the transportation agent to acknowledge receipt. Natural Selections will retain all shipping manifests for no less than one year and make them available to the Department upon request. The applicant will also implement and enforce the following secure transportation procedures: • Any vehicle used to transport marijuana must 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 the regulations 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 cannabis 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 corners 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 dispensary and shall not make any stops. In case of an emergency stop, a detailed log must be 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 dispensary 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; (e)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. 18 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 marijuana and shall produce it to the Department's authorized representative or law enforcement official upon request in compliance with the current regulations • Each transportation agent is required to double check for forms of identification approved by the Department before transporting any cannabis. • All authorized transport agents are 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 wear 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 transport, 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. In 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 made 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 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 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: 19 • 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 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 the regulations. Preventing employee theft, diversion, and pilferage 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 sale of marijuana going to criminal enterprises, gangs, and cartels. • 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 Robberies.Dispensary employees could provide internal security protocols and information to assist in robberies of cannabis businesses. 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: • 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. Strong 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 suspicious 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: • Transparency.Employees will be encouraged to offer feedback and strategic feedback, regardless of their level or position in the applicant. 20 • Benefits,training,and paid-time off.The applicant will offer each employee benefits, training, 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 indicators,performance evaluations, and division of responsibilities that will be implemented at all levels of the business. Implementing business practices to create a strong culture and empowering environment for employees is highly correlated with the prevention of turnover and in turn,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 combating theft and pilferage. The applicant is committed to establishing a culture of responsibility among its employees regarding the diversion of 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, and operations personnel will be encouraged to offer recommendations to the Chief Operating Officer regarding anti-diversion policies and other strategies. Employee Screening 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. 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 required job 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 former supervisors on the candidate's performance,if available. 4) Performing a criminal background check on the selected candidate to determine eligibility and to identify any other possible disqualifying items. 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 21 to conduct criminal and credit background checks, dispensary agents must be over the age of 21 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 cannabis products. Management personnel will undergo more extensive screening and will be required to provide fingerprinting and submission for a Level II 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 with state and local laws and regulations. Employee Training Program 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 customers 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-theft and anti-diversion plan as part of the initial grow agent training. 1) Identifying regions of dispensary 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 dispensary 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 dispensary • Access control effectively limits the ability for employees to move freely throughout the facility. o A Limited Access Area means a building,room, or other indoor or outdoor area on the registered premises of a dispensary where marijuana,MIPs,or marijuana by-products are cultivated, stored,weighed,packaged,processed, or disposed, under control of a dispensary,with access limited to only those dispensary agents designated by the dispensary. 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 a wrongdoer to identify vulnerabilities and plan an illicit activity. The errant entry alert feature that cues the Security Director of attempts at unauthorized entry also serves to highlight potentially suspicious behavior on the part of individual employees and may prompt a follow-up interview and corrective training. 22 2) Best Practices The training will also cover operational practices designed to prevent and deter diversion and prevent the sale of cannabis from going to criminal enterprises, gangs, and cartels. All employees will be required to understand that these methods of preventing diversion will be a 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 three 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 for 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-diversion 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. 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 dispensary 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 must 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 entrance, 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 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. • Employees will abide by restricted use of electronic devices (cell phones,music players, cameras, etc.)within the dispensary and the cultivation facility. Personal cell phone use 23 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) Reporting Diversion All employees will be trained to report any diversions,theft, or suspicious behavior to their supervising manager. Grow agents will have additional responsibilities regarding anti-diversion practices. In 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 uncertified 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 report 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,he or she will be expected to report the incident report directly to his or her manager and reconcile the error. • 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 24 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 document 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 re complete 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 an infraction against the business license, o Using a fellow grow agent's identification on any internal documents. 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. The applicant will use F1owHub 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 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 chronicle every step, ingredient, activity, transaction, and dispensary agent, recreational consumer, registered qualifying patient, or personal caregiver who handles, obtains, or possesses the product. Chain of Custody 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 25 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 future 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 or production process where a trackable item(plant,raw material, and 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 strain- 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(BLD10.15.17). 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 the plants, at all times during the harvest and drying process. All tags shall be grouped together by strain and hung on a hanger at the front of each batch in the dry room. Afterward, 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. • 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: 26 1) Harvest Name: A six digit date,Location, Tray number/letter, and the strain. 2) Weight: Using the information recorded on 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 sum of all plant weight for each strain. Take the total sum 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 prior to the transfer procedure. The grow agent will be responsible for inputting the following information. 1) Open the "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. 6) 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 portion(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 on 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 the"Report Waste"icon. • Select and highlight the batch that is complete. Click the"Finish Batch" icon located under the"Harvested"tab. Natural Selections will stay up-to-date on all developments within the cannabis industry that could affect the incentive for diversion. (i.e. system-wide cannabis shortages, changes in law, rapidly increasing patient registrations, etc.)Based on these developments,the applicant will evaluate and revise its security policies to mitigate the risk for specific incidents of diversion. 27 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 a dispensary seriously and will be committed to reporting any diversions or other reportable incidents to the Watertown Police Department within 24 hours of occurrence. Dispensing Limits Natural Selections will also work to ensure customers do not divert cannabis obtained through its dispensary by ensuring that they only procure the amount of cannabis legally allowed. This will ensure that customers do not have access to more cannabis than necessary and that customers do not have access to additional cannabis that could be sold or distributed to minors or other non- registered users. The applicant will strictly limit the amount of cannabis dispensed to each customer as per the regulations defined under the regulations Secure Waste Disposal Methods The applicant understands the risk associated with negligent waste disposal methods,which can potentially lead to diversion and distribution to consumers or 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 state and local regulations. 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 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 policies as well. All 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 premises, especially in regard to law enforcement's first priority of safety related to cannabis. The applicant 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 dispensary 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-threatening manner: 1) The Location of the Premises 28 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 dispensary at all times to remove individuals not complying with the regulations or other offending behavior. The Location of the Premises The applicant has chosen a location for its dispensary that is highly compliant with all regulations. The dispensary,which is located at 207 Highland Ave, 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 dispensary. The applicant understands the increased risk of loitering and congregating around structures, such as 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 dispensary. • 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 state and local regulations. 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 seamlessly into 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 dispensary,the Applicant will ensure 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 i 29 secure perimeter to limit access. Lighting is a critical design measure to prevent loitering. The surrounding streets around the dispensary have sufficient lighting to illuminate the dispensary's parking lot and surrounding area. The dispensary 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 dispensary 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 minors from congregating. Natural Selections is committed to complying with regulations in regard to creating a safe,neutral exterior that in no way promotes or advertises the sale of cannabis. • The Applicant will create and maintain a neutral design for its exterior,logo, and signage. • The signage outside of the dispensary will only be illuminated 60 minutes prior to the 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 customers and 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 the dispensary to create an 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 dispensary. 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 deter loiterers; however,the applicant will also consider implementing a number of other creative design efforts to detect and deter minors from surrounding the dispensary. Video 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 30 head-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 uninterruptible power source for continued operation during a power failure. 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, reporting, loitering to the local law enforcement agencies. Signage 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 minors 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. Anti-Loitering Devices Natural Selections took great precautions when considering the location for its dispensary to prevent loitering. However,the applicant will consider implementing additional preventative measures should loitering become an issue around the premises of the dispensary.Natural Selections understands that creating an atmosphere that is unappealing to minors will also assist in efforts to prevent the illegal distribution of cannabis to minors. Therefore,the applicant will do everything to ensure that loitering does not occur. • 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 classical music or other sounds that have been shown to discourage minors from loitering in an area. • 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 dispensary or in the surrounding premises,they will consider purchasing a security device known as "The Mosquito,"which schools and other spaces use in areas 2 Journal of Popular Music Studies,Volume 19,Issue 4,Pages 342-358 3 The Mosquito TM Copyright©2012.Moving Sound Tech. 31 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. 32 Section III : Business & Marketing Plan Business Operations and Marketing Plan Natural Selections is an established organization committed to providing access to quality natural cannabis 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, customers, 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 all regulations and reflect its commitment to natural,quality products.Natural Selections intends to integrate seamlessly into the Watertown community and will identify 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. The applicant is committed to utilizing tasteful branding strategies that are aligned with its values and compliant with regulations the applicant has chosen its name, "Natural Selections,"to reflect its commitment to providing high quality,natural plant-based cannabis to its customers and patients. The Natural Selections brand reflects the medicinal chemical compounds found in cannabis plants,rather than the cannabis plant itself. As per the regulations,the applicant will not utilize symbols, images of marijuana, related paraphernalia, and colloquial references to cannabis and marijuana 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,bearing a symbol of or references to marijuana or MIPs,including the logo of the dispensary. Packaging Natural Selections will invest in packaging based on brand reliability,transparency and quality that is in compliance with the regulations. Each product will be contained in simple packaging that is opaque and child proof. In 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 must have labels on them, detailing the potency,the types of chemicals used in cultivation and other information. Education In lieu of traditional business marketing and advertising strategies,the applicant will utilize extensive educational materials, seminars, and campaigns to educate customers regarding the use of cannabis.Natural Selections will begin its marketing efforts with a grassroots campaign to 34 educate customers about the effects of medicinal cannabis,methods of consumption, as well as cannabinoids and their associated benefits. The applicant's website will have extensive information about Natural Selections' mission, research, strains, and testing results from registered labs. Customers will be able to access a list of current cannabis strains and products available at the dispensary. 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 customer feedback and carefully studying plant and terpenoid profiles to provide its customers with as much information as possible.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 consumers are able to access their content on the web. The applicant will also invest in written materials and handouts to educate employees and customers on methods of consumption, dosage, and types of cannabinoids and their associated effects. The applicant is committed to providing the utmost quality care to its customers and educating employees and customers on all potential side effects. The educational materials will provide information on the following: 1) Methods of cannabis consumption Inhaling cannabis Customers may elect to inhale cannabis by packing a small amount of dried flower into a pipe or rolling paper or utilizing a vaporizer. Customers 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 cannabis affects their body.Customers should note that they may experience side effects such as coughing and irritation of the throat. Customers will be informed to use caution 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 Orally Administered Cannabis-Infused Products Consuming cannabis-infused products affects customers differently than inhaling cannabis. 35 These products can affect consumers 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, consumers begin by consuming '/4 of their recommended dosage.Beginning with a portion of the recommended dose is the best way for a consumer to learn how a strain of cannabis or a specific food-based product interacts with their body. After an hour,the consumer can increase their dosage in increments remaining aware of the effects.If a consumer 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 customer. Topical& Taansdermal Treatment 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 customer determine the correct dosage based on the prescription from the patient's medical practitioner and the customer's experience with cannabis. The employees will provide the following general recommendations to each customer: • 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. • Inhaling Cannabis.Wait between short inhalations for a few minutes to observe the strength of the product. Begin with'/4 of prescribed dose and note how the product affects the body. • Edible products.When eating cannabis or consuming cannabis-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. Consumers who are new to edible products should begin with a dose that is less than 0.5 ml to gauge how the product affects their body. • Determine dosage amount based on prescription and the mg of THC in each product.Divide the product up accordingly to the prescribed dose. If it is your first time using the product divide the dosage into '/4 of the prescribed amount in order to gauge its effects. • 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 36 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 treating certain medical conditions, the applicant has taken a scientific approach to strain development, aggregating data based on customer and 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 cannabinoids 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 cannabinoid profiles and terpene levels in all produced strains and cannabis-infused products. Additionally,the applicant utilizes an HPLC to isolate cannabinoids to produce ratio-specific products. Natural Selections understands that each individual's body physiology is unique and certain products and strains affect recreational consumers and 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 customers, 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 team 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 customers. The team hopes that Natural Selections can be instrumental in building a strong cannabis industry in Massachusetts,where customers and patients are guaranteed safe access to cannabis and education. The core of the applicant's branding strategy lies in building strong relationships with customers. The applicant believes in personally interacting with all of its customers and helping design treatment plans that are uniquely catered to them. Natural Selections has considered its commitment to its customers through the design process of the dispensary. The applicant will invest in a spacious and inviting design to ensure that customers will have sufficient time and space to make their decisions. The applicant will employ enough dispensary agents to ensure that each customer 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 customer's objectives and experience in previously using cannabis. Dispensary agents will offer each customer a wealth of information regarding the available cannabis strains and cannabis-infused products, cannabinoids and their associated benefits,risks and adverse side effects associated with cannabis, and various methods of consumption. The 37 dispensary agents will also inquire about customer' 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 for medical patients,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 dispensary and be responsible to maintain accurate records of patients identification and registration documents,manage scheduling patient traffic 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. 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. • 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 Town of Watertown to provide public health educational programs geared towards education and prevention of HIV/AIDS and substance abuse: o 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,cachexia, 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 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 treat 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. 38 Section IV : Benefits & Effects on the Town of Watertown Fiscal & Community Impact on the Town of Watertown Natural Selections is committed to benefiting the Town of Watertown through community and fiscal impact. 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. 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 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. Fixed salaries and benefits for the executive management, administrative, and operating teams will come to $817,700 in Year 1. These wages and salaries will increase as the business grows. Natural Selections will offer its employees competitive salaries and will provide benefits, such as healthcare, social security,workers' compensation,life insurance, and a 401K plan. • Community Charitable Contributions:Natural Selections plans to build collaborative relationships with state and local governments in order to ensure a seamless integration into the 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. Team members will also organize community outreach efforts, such as trash pick-up events,to create a safer, cleaner Town as well as provide transparency about their operations and education about the responsible use of cannabis. • 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 Town 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, cachexia, and emotional decline. Natural Selections, Colorado has worked with many HIV/AIDS patients at its current facility in Northglenn, Colorado and understands the devastating impact that this disease can have on families and 40 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.a • 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 Town 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. Job Creation for the Town 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 regulators and producing safe, consistent cannabis products of the highest quality. The applicant 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. The applicant is committed to ensuring that cultivation and dispensary operations are staffed appropriately to remain in compliance with state law and department regulations,while simultaneously providing the highest quality of care to its customers and patients. Initially, Natural Selections will hire around 20 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: Executive Office General Manager 1 Compliance Director 1 Community Outreach Manager 1 Quality Assurance Manager 1 Human Resources Director 1 IT Manager 1 Bookkeeper 1 Dispensary 4 41 Director of Patient Affairs I Customer Coordinator 1 Dispensary Manager 2 Dispensary Agent 10 Security Personnel 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 the organizational flow between connection between executive leadership, directors, and managers in the various departments. 42 Director of Compliance Compliance Manager Chief Financial Business Director of man u Human Officer Development Hu Resources Resorces Manager Controller Bookkeeper Dispensary Dispensary Director of Manager Agent Patients Affairds Patient Dispensary Coordinator Chief Executive Officer Medical Assistant Medical Director Researcher Cultivation Director of Crow Agent Trimmer Cultivation Extraction Extraction Manager Assistant Director of Infused Infused Manufacturing Processing Products Products Chief Oppeerating Manager Assistant Officer Packaging Packaging Manager Assistant Transportation Manager (Director ns 1T Manager r Maintenance Laborer Manager Operations ofSecurity Agent yofSocial Media ty Manager Outreach 43 Section VI : Mitigation & Prevention of Potential Adverse Effects Introduction Natural Selections has taken great precautions in creating its security and safety plans,with the intention of protecting its customers, employees,patients, and caregivers. The applicant does not expect to cause increased demands on the Town's police, fire, emergency, or health-related services and does not expect to cause an adverse impact on the Town 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 Town 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 of jobs 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 offsetting any potential use of resources, while simultaneously bettering the economy. Preventing Increased Crime The applicant does not expect that the legalization of cannabis will result in an increase in crime. According to an 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.' 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 are 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 regulations 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 Town's police department and will meet on an annual basis to discuss concerns and effective security operations regarding the dispensary. While the applicant does not expect an increase in crime rate or an increased demand on the Town's police department,Natural Selections anticipates that it's monthly Town payments will mitigate any financial drain on the Town's resources. 5"Status Report:Marijuana Legalization in Colorado After One Year of Retail Sales and Two Years of Decriminalization.Drug Policy Alliance: 2015. 6 Barnes,J.C.,Robert G.Morris,Michael TenEyck,and Tomislav V.Kovandzic. "The Effect of Medical Marijuana Laws on Crime:Evidence from State Panel Data, 1990-2006."PLoS ONE 9(3): e92816.March 2014. 45 Preventing Drugged Driving 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 consumers and employees about the risks associated with operating a motor vehicle after consuming cannabis. The educational materials will outline Massachusetts law so that employees will be able to inform consumers 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 the influence of intoxicating liquor, or of marijuana,narcotic drugs, depressants or stimulant substances, as defined in section one of chapter ninety-four C, or 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 cannabis is not an acceptable defense when charged with a drugged driving offense. In addition to this information, consumers 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 law the maximum penalty for the first offense of driving under the influence is up to 30 months jail time,license suspension for up to one year,and the fines and penalties for driving under the influence range from $500 to $5,000. (State DUI Driving Laws). Cannabis and Driving Each Customer 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? 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. 46 Q:How does law enforcement determine impairment by the use of marijuana? A: Officers are becoming trained to look out for warning signs associated with driving under the impairment of marijuana.Additionally,while Massachusetts does not legally require that drivers submit to a drug test to determine impairment the refusal to submit a drug test can be included in evidence if a 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 minors.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. Natural Selections will begin prevention on the premises with rigorous physical security measures that ensure only eligible recreational consumers,registered qualifying patients,personal caregivers,dispensary agents and other authorized individuals can access the dispensary.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. In the event that Natural Selections becomes aware of such activity, or is otherwise suspicious,it will take immediate action. Branding&Packaging The applicant is committed avoiding any images or branding strategies that would seek to influence or attract consumers from the general public, specifically minors. 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 2 1+consumers and 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 all regulations 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 dispensary'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 resembling 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. 7 The Cole Memo. 47 The dispensary 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 dispensary that produced the MEP,together with the dispensary'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 cannabinoid 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 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 the regulations • A warning if nuts or other known allergens are contained in the product • This statement, including capitalization: "This product has not been 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." 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 dispensary that is highly compliant with the regulations. The dispensary,which is located at 23 Elm St, is not situated within 500 feet of a K-12 public or private school, as required by the Town of Watertown regulations.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, and is much more commercial in nature. The dispensary will in no way reference the sale of marijuana through its logo, external signage or on 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 measures 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 the CCC 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 all regulations 48 Preventing Health Issues 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 consumers and patients to benefit from cannabinoids 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 consumers and patients who do not wish to inhale burning plant vegetation. The applicant will also offer a selection of vaporizer pens that allow consumers 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 consumers and patients with compromised immune systems seeking cannabis as medicine. The applicant is committed to purchasing a CO2 extraction machine for its manufacturing/processing lab and using CO2 as a processing method. Other Potential Effects on Town The applicant has considered other potential effects that its operations could have on the Town of Watertown and has outlined solutions and strategies to mitigate these. Increased Demands on Watertown Fire Department The applicant will not be cultivating marijuana on site at its dispensary. Therefore,the applicant does not expect that its operations will have any emergency incidents that will increase the burden on the Town's fire department. The applicant will ensure that its dispensary is fully compliant with fire codes and fire prevention. The applicant will form a relationship with the Town'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 dispensary is fully compliant with fire code and fire safety prevention techniques,thereby causing no additional demand on the Town'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. 49 Increased Demands on Watertown's Emergencv Services The applicant does not expect to require or impact the Town's emergency services. However, in the event of an emergency,the applicant expects that its CHA annual payment and Community Host Agreement will cover any financial loss. Increased Demands on Watertown's Health Services While Natural Selections expects that its dispensary will have a positive impact on the community's health and education,the applicant does understand the potential health risks associated with marijuana. The applicant is committed to educating patients and caregivers about the potential risks of marijuana. The applicant also intends 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 use its position as a dispensary to educate the community about substance abuse and the responsible use of cannabis. Including its preventive measures,the applicant expects that its Community Host Agreement will mitigate any potential financial demand on the Town's health services. Increased Air,Noise,Light and/or Water pollution 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 dispensary 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. • Air Pollution: Natural Selections will not be cultivating 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 increase 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 security system will utilize motion-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 marijuana off-site therefore the applicant does not anticipate an increase in water pollution at the dispensary. 50 Increased Traffic and Traffic Mitieation The applicant will expect an increase in traffic to its dispensary,which is located at 23 Elm Street. The applicant chose this location because of its commercial neighborhood and its significant distance from schools, and rehab centers. Based on its current Market Analysis,the applicant does not expect to have more than 15 customers 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 dispensary. As customer 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 should offset any impact on the Town's financial resources. Natural Selections intends to have a positive impact on the Town of Watertown and its community. The applicant is committed to offsetting any potential negative impacts on the community with educational programs, charitable donations, and through its Community Host Agreement. 51 Section VII : Best Practices & Standard Operating Procedures Quality Control Best Practices The applicant is committed to a rigorous testing policy and has established partnerships with ISO- certified laboratories to test all produced strains and cannabis-infused 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 dispensary. The dispensary shall maintain the results of all testing for no less than one year; Marijuana shall be tested for the cannabinoid 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(THC). • Metals(including arsenic, cadmium, lead, and mercury) • Pesticide Residue and Plant Growth Regulators • Microbial contaminants and mycotoxins • 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 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 recreational consumers,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 of components, 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. 53 • Packaging, labeling and distributing. All products shall be suitably packaged in accordance with regulations 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 requirements. If any discrepancies are observed,the product shall be immediately quarantined and investigated.All employees must verify that all labels have the correct names, amounts or 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 performed 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 redistribution. The applicant will emulate waste disposal strategies at the 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 all regulations. 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 performing 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 cannabis waste will be processed at the cultivation facility.No cannabis waste will be processed at the applicant's dispensary. • 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 for 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 regulations, all disposed waste containing cannabis material or byproducts must be rendered useless and unrecognizable. Grow agents will be responsible for grinding and incorporating the cannabis waste with solid wastes such that the resulting mixture renders the 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. 54 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 regulations,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 dispensary 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 cannabis waste with solid wastes such that the resulting mixture renders the cannabis waste unusable. Once such 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 cannabis waste is organic material as defined in the regulations,the mixture may be composted at an operation that is in compliance with the requirements of the regulations. • 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-tracking 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 55 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 flowers found to have contaminants will be rejected for processing and removed from the batch. If contaminated flowers have reached the processing facility,they are returned to the cultivation facility. Before rendering useless,the contaminated product is inventoried and reweighed. 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. • Dumpsters and waste bins used will meet all state and local laws, and when not in use are keptlocked. • 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 members. 56 . Section VIII : Plans and Renderings Note: Plans and Renderings redacted from the Committee Report for security reasons