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HomeMy Public PortalAboutKeltic Green Watertown Application 11-15-19Cf V KELTIC Keltic Green Inc Application for Consideration Licensed Marijuana Retail Establishment 390 Arsenal Street Watertown Ma November 15th, 2019 Keltic Green Inc. 41 Matawanakee Trail Littleton Ma, 01460 617.257.7799 Justin@KelticGreenma.com NOVEMBER 14, 2019 Town of Watertown / Town Council Attention: Steven Magoon, Director Department of Community Development & Planning Town Hall Administration Building 149 Main St, Watertown, MA 02472 Dear Town Council, �J KELTIC On Behalf of Keltic Green Incorporated, please accept this letter as a formal request to be considered as an applicant in the Watertown cannabis licensing process. Keltic seeks to operate a licensed Retail Marijuana Establishment within the Town of Watertown located at 390 Arsenal Street. We appreciate the opportunity to be considered and look forward to presenting our concepts and business strategies. Keltic's submission consists of the following Sections. A. Draft Host Community Agreement B. Site Plan with Zoning Compliance Table C. Floor Plan D. Parking Management and Transportation Summary Report E. Security and Operations Summary (Detailed Plans to be reviewed internally, coordinated by the police department) F. Company/Applicant Business structure and summary of Business Plan We look forward to your guidance upon submittal of our application, and we would like to thank you in advance for the opportunity. Regards, Justin Smith CEO / Keltic Green, Inc. 617 257 7799 / Justin@KelticGreenMa.com KELTIC GREEN, INC. HOST COMMUNITY AGREEMENT FOR THE SITING OF A RETAIL MARIJUANA ESTABLISHMENT IN THE TOWN OF WATERTOWN This Host Community Agreement ("Agreement") is entered into this day of December, 2019, by and between the Town of Watertown, a Massachusetts municipal corporation, with executive offices located at 390 Arsenal Street, Watertown, MA 01821 ("the Town") by and through its duly elected Town Manager, and Keltic Green, Inc.("the Company"), a Massachusetts corporation with an address of 41 Matawanakee Trail, Littleton, Ma 01460. RECITALS WHEREAS, the Company wishes to locate a licensed retail marijuana establishment at 390 Arsenal Street, (hereinafter the "Establishment") which property is located within the Regional Mixed Use District thus requiring the issuance of a special permit in accordance with Section 5.01 of the Watertown Zoning Ordinances, as amended; and in accordance with the laws of the Commonwealth of Massachusetts; WHEREAS, the Company, notwithstanding any exempt status, shall pay all local taxes attributable to its operation of the Establishment, including but not limited to, real estate and personal property taxes, for the space within which it is located; WHEREAS, Company desires to be a responsible corporate citizen and contributing member of the business community of the Town, and in the event the contingencies noted below are met, intends to provide certain benefits to the Town over and above typical economic development benefits attributable with similar new manufacturing and retail concerns locating in the Town; and WHEREAS, the Town believes that the Company's operation of a retail marijuana establishment at the Establishment location, coupled with its contributions to the Town, as set forth herein, would advance the public good; and WHEREAS, the Town has agreed to approve up to two retail marijuana establishments within the Town of Watertown; and Now THEREFORE, for good and valuable consideration the receipt and sufficiency of which is hereby acknowledged and for the mutual promises set forth below, the parties agree as follows: AGREEMENT 1. Host Community Payment. In the event the Company obtains a Final Certificate of Registration, or its equivalent, for the operation of the Establishment in the Town from the Massachusetts Department of Public Health, the Cannabis Control Commission, or such other state licensing authority (hereinafter "Licensing Authority"), as the case may be, and receives any and all necessary and required permits and licenses required by the Town, and at the expiration of any final appeal period related thereto said matter not 11Page being appealed further, which said permits and/or licenses allow Company to locate, occupy and operate the Establishment in the Town, then the Company agrees to the following: a. The Company shall make five (5) annual host community payments of 3 percent (3%) of the gross sales of the Establishment to the Town (the "Annual Payment") for a period of five (5) years / sixty (60) months. The initial Annual Payment shall be due twelve (12) months after the first day of operation (the "Initial Payment"), and each subsequent Annual Payment shall be due on the anniversary date of the Initial Payment. b. The Company agrees to Provide additional payments of: - A charitable contribution to be made in an amount equal to XXXXX. The initial charitable contribution shall be due twelve (12) months after the issuance of a Final Certificate of Registration or its equivalent (the "Initial Payment"), and each subsequent Annual Payment shall be due on the anniversary date of the Initial Payment. The Town Manager's office shall have full discretion as to the disbursement of the charitable gift. c. Each payment shall be accompanied by a certificate of a certified public accountant or by a statement under oath by the Company's chief financial officer that the payment is true and accurate. d. "Gross sales" shall be defined as the grand total of all sale transactions reported in a period, without any deductions included within the figure. 2. Successor HCA. To the fullest extent permitted by law, but no later than 90 days before the expiration of this agreement the Company agrees to negotiate with the municipality in good faith over a successor Host Community Agreement. 3. Payments. The Company shall make the payments set forth in Section 1 of this Agreement made payable to the Town. The parties understand and acknowledge that the Town is under no obligation to use the payments described in Section 1(a) above in any particular manner, provided, however, that the payments are reasonably related to the costs imposed upon the Town by the operation of the Establishment. 4. Other Payments. The Company anticipates that it will be required to pay water and sewer charges to the Town; and that the Company will pay any and all fees associated with the local permitting of the Establishment. 2IPage 5. Review. The Town and the Company will review the Annual Payment every twelve (12) months to ensure that the Annual Payment is reasonably related to the costs imposed upon the Town by the operation of the Establishment. 6. 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 Company or by its landlord, and neither Company nor its landlord shall object or otherwise challenge the taxability of such property and shall not seek a non- profit exemption from paying such taxes. 7. Community Support and Additional Obligations. a. The Company agrees to provide no less than 100 man hours yearly to participate in community service activities including but not limited to; Town -sponsored educational programs on public health and drug abuse prevention, senior assistance, community cleanup, veteran's assistance. b. Local Vendors — 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 and vendors in the provision of goods and services called for in the construction, maintenance and continued operation of the Establishment. The Company shall use good faith efforts to ensure that at least fifty percent (50%) of the vendors and/or contractors utilized by the Establishment will be based in the Town. c. Employment/Salaries — except for senior management, and to the extent such practice and its implementation are consistent with federal, state, and municipal laws and regulations, the Company shall use good faith efforts to ensure that at least fifty percent (50%) of the employees of the Establishment will be Town residents. d. The Company shall provide the Town with annual reports indicating the percentages of vendors and employees in accordance with paragraphs (a) and (b) above. e. The Company shall, at least annually, provide the Town with copies of all reports submitted to the Licensing Authority regarding operations at the Establishment. f. The Company will work with the Town's Health Department to ensure that all Company products are tested to the satisfaction of the Town. 8. Support. The Town agrees to submit to the Licensing Authority all documentation and information required by the Licensing Authority from the Town for the Company to obtain approval to operate a retail marijuana establishment. The Town agrees to support the Company's application with the Licensing Authority but makes no representation or promise that it will act on any other license or permit request in any particular way other 31Page than by the Town's normal and regular course of conduct and in accordance with their rules and regulations and any statutory guidelines governing them. The Town agrees to use best effort to work with Company, if approved, to help advise the Company on their community support and employee outreach programs. 9. Security. Company shall maintain security at the Establishment in accordance with the security plan presented to the Town and approved by the Licensing Authority. In addition, Company shall at all times comply with all applicable laws and regulations regarding the operations of the Establishment and the security thereof. Such compliance shall include, but will not be limited to: providing hours of operation; after-hours contact information and access to surveillance operations; and requiring dispensary agents to produce their Program ID Card to law enforcement upon request. Company shall promptly report the discovery of the following to Town police within twenty-four (24) hours: diversion of marijuana; unusual discrepancies identified during inventory, theft, loss and any criminal action; unusual discrepancy in weight or inventory during transportation; any vehicle accidents, diversions, losses, or other reportable incidents that occur during transport; any suspicious act involving the sale, distribution, and delivery of marijuana by any person; unauthorized destruction of marijuana; any loss or unauthorized alteration of records related to marijuana, registered qualifying patients, personal caregivers, or dispensary agents; an alarm activation or other event that requires response by public safety personnel; failure of any security alarm system due to a loss of electrical power or mechanical malfunction that is expected to last longer than eight (8) hours; and any other breach of security. 10. Approval of Manager. If requested by the Town, the Company 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 and any other relevant regulations, of the person proposed to act as on -site manager of the Establishment. The submittal shall include authorization to perform a criminal history (CORI) check. Town shall consider such request for approval within thirty (30) days following submittal to determine, in consultation with the Chief of Police, if the person proposed is of suitable character to act as on -site manager. Such approval shall not be unreasonably denied, conditioned or delayed. In the event that Town does not provide confirmation or rejection of the proposed on -site manager within thirty (30) days, that manager shall be deemed approved by Town. This approval process shall also apply to any change of on - site manager. Term and Termination. This Agreement shall take effect on the day above written, subject to the contingencies noted herein. At the conclusion of the term of this Agreement, the parties shall renegotiate a new Host Community Agreement in accordance with the current prevailing regulations and laws as such regulations and laws may be amended or replaced. In the event Company no longer does business in the Town or in any way loses or as its license revoked by the State, this Agreement shall become null and void; however the Company will be responsible for the prorated portion 4IPage of the Annual Payment due as under Section 1 above. The Town may terminate this Agreement at any time. In the event the Town terminates this Agreement, Company shall not be required to cease operations as long as the Company continues to make all payments to the Town pursuant to this Agreement or during the time such negotiation proceedings are pending. In such event the Company shall be considered to be in compliance with all relevant state laws and CCC regulations regarding the existence of a Host Community Agreement. 11. Governing Law. This Agreement shall be governed in accordance with the laws of the Commonwealth of Massachusetts and venue for any dispute hereunder shall be in the courts of Middlesex County. 12. 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 all signatories to the original Agreement, prior to the effective date of the amendment. 13. Severability. If any term or condition of the Agreement or any application thereof shall to any extent be held invalid, illegal or unenforceable by the 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. 14. Successors/Assigns. This Agreement is binding upon the parties hereto, their successors, assigns and legal representatives. Neither the Town nor Company shall assign or transfer any interest in the Agreement without the written consent of the other. 15. Entire Agreement. This Agreement 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. 16. Notices. Except as otherwise provided herein, any notices given under this Agreement shall be addressed as follows: To Town: To Licensee: Manager Michael J. Driscoll Watertown Town Hall 149 Main Street Watertown, MA 02472 Keltic Green, Inc. 41 Matawanakee Trail Littleton, MA 01460 5IPage Notice shall be deemed given (a) two (2) business days after the date when it is deposited with the U.S. Post Office, if sent by first class or certified mail, (b) one (1) business day after the date when it is deposited with an overnight courier, if next business day delivery is required, (c) upon the date personal delivery is made, or (d) upon the date when it is sent by facsimile, if the sender receives a facsimile report confirming such delivery has been successful and the sender mails a copy of such notice to the other party by U.S. first-class mail on such date. * * * SIGNATURES ON FOLLOWING PAGE * * * 6IPage IN WITNESS WHEREOF, the parties have hereafter set faith their hand as of the date first above written. Town of Watertown Michael J. Driscoll Town Manager Keltic Green, Inc. Justin W. Smith CEO 7 1 P a g e ZONING TABLE OLR/EsavAL REOUIREMENn RmIIRED I E17SANG mwo-sm MIN/MUM LOT REV//REV0VM AREA - 22, 417-1 50. FT. 22, 4171- SQ. FT FRONTAGE 50 FT 159 FT 169 FT. IMPERVIOUS COVERAGE 9OX, 61.37 7797 OPEN SPACE 1OX, 31. 8X, 19. 1X, MIMMUM YARD REW AV"7SS FRONT SETBACK 10 FT. MAX 51.08-L- FT' NA SIDE SETBACK 25 FT 26.66i FT. NA REAR SETBACK 30 FT 26.55-1 FT* NA MAXIMUM BUILDING` COVERAGE 50X, 18.77 NA STORIES 5 STORIES 1 STORY** NA HEIGHT 55 FT. 20 FT.** NA FLOOR AREA RA77O 2.0 19. 7X NA `LXIJ11NU NUN-(,UNI-UKMINL' **BASED ON VISUAL OBSERVATION 0 EXISTING USE- COMMERICIAL OXISTING BUILDING 5,750 S. F. G - RECORD OWNER FARKM REOU/REAA FNTS 390 ARSENAL, LLC REQUIRED: REFERENCES RETAIL SALES/SERI40E AND OFFICE ��rr 1 SPACE PER 350 50 FT. OF GROSS FLOOR AREAT DEED BOOK 68643, PAGE 416 (4,200 SO FT. EXISTING BUILDING)x(1 SPACE PER 350 SO FT.)= 12 SPACES PLAN 1038 OF 1978 EXISTING ZONING 22 SPACES INDUSTRIAL 1, /-1 PROPOSED: 29 SPACES LANDSCAPE AREA: REQUIRED: 57 PROPOSED: 6.17 MBR� pGE 0 wN � CA VVATERTOWN NINAY GREE SCAPE BUFFER _ - - g' LAND - - O I I ONE WA Y 14' ± O 5 9 I I I I i I I I I I 0 0 PARCEL 2 A=22, 417f S.F EXISTING BUILDING 4,200 S. F. GONG PAD I L OADING AREA I I I I I I O I 3 I I ,,n, 18, �23'± 1 T - n I I - I I L------- - ---- -- ------------------------- 5' LANDSCAPE BUFFER CONC. SIDEWALK ARSENAL STREET (PUBLIC ^- 60' WIDE) 41 LOCUS Ltw- SCALE T - VW PROJECT LOCATM 390 ARSENAL STREET M � Watertown, Massachusetts 02472 2 R'RFIRAFED FOR a Keltic Green Inc. 41 Matawanakee Trial Littleton, Massachusetts 01460 HANCOCK EXISTING USE - COMMERCIAL T r7 ASSOCIATES Civil Engineers Land Surveyors Wetland Scientists 34 CHELMSFORD STREET, CHELMSFORD. MA 01824 VOICE (978) 244-0110, FAX (978) 244-1133 WWW.HAN000KASSOCIATES.COM NO.I BY IAPPI DATE I ISSUE/REVISION DESCRIPTION HCA EXHIBIT PLAN DWG: 2HCA-10 LAYOUT:HCA-10 SCALE SCA SHEET: 1 OF 1 PROJECT NO.: 22412 THE LOT LINES SHOWN ON THIS SKETCH ARE COMPILED FROM THE MASSGIS TAX PARCELS AND ARE NOT ACCURATE. A FIELD SURVEY DONE TO BETTER DETERMINE THE BOUNDARY CONDITIONS. - PROJECT LOCATION 390 ARSENAL ST. PARCEL ID: 1213-3-0 10 EXHIBIrxaN OF LAND /N WA TEf)TOW/N, MA PREPARED FOR KEL 7 7C GREEN /l1C. M: X: \22412—Keltic Green—Watertown\DWG\ THE PURPOSE OF THIS SKETCH IS TO SHOW THE DISTANCE BETWEEN THE PROPOSED REGISTERED MARIJUANA DISPENSARY LOCATED AT 390 ARSENAL Sl AND THE ARSENAL PARK LOCATED AT 485 ARSENAL ST. PER CITY OF WATERTOWN ZONING ORDINANCES SECT. 5.03 "NOTES Ti TABLE OF USE REGULATIONS" SUB —SECT. (16) " MEDICAL MARIJUANA TREATMENT CENTERS AND ADULT USE MARIJUANA ESTABLISHMENTS (SECTION 8.04) ARE PROHIBITED FROM SITING SUCH CENTERS AND '� OR ESTABLISHMENTS WITHIN... A 500 ---- FOO1 BUFFER FROM PUBLIC PARKS, PLAYGROUNDS,A ND THE CHARLES RIVER RESERVATION... THE DISTANCE SHALL NE MEASURED IN A STRAIGHT LINE FROM THE NEAREST POINT OF THE PROPERTY LINE Of THE PROPOSED USE TO THE NEAREST � PONT OF THE PROPERTY LINE OF 1H PRE-EXSITING ESTABLISHMENT OR PARK. l in s ARSENAL PARK " 485 ARSENAL ST. PARCEL ID: 1301-2A-0 . v ` SCALE:1 "=200' 0 100 200 4C HANCOCK ASSOCIATES 34 CHELMSFORD ST., CHELMSFORD, MA. 01824 VOICE (978) 244-0110, FAX (978) 244-1133 PLOT DATE: Jun 12, 2019 DWG: 22412eng1.dwg CHECK BY: BG DATE: 6/12/19 JOB NO.: 22412 N U 00 '- o > a ui w 0c) z o _= O Lo co , Lu 0 U >ti SECURE GENERAL Z OFFICE OFFICE IDF STORAGE INVENTORY STORAGE Q W STAFF AREA 16 15 18 9 U Q 7 105 SF 105 SF 55 SF 269 SF 133 SF 138 SFco U 223 SF (a ti a STAFF HALL 13 a o SECURE PUBLIC TOILET `� POINTS OF SALE RECEIVING STAFF TOILET 12 � � 4 J 56 SF 0 350 SF a 340 SF D 51 SF U = N M O O RECEPTION 45 SF DISPENSARY Lo 0 -1 11 1096 SF SECURE r VESTIBULE ♦ ^ VJ Z 1 o o 0 243 SF EXIT Wco z 10 wD wD /w O a- U o W � 35 SF U Q J LLI Z w ENTRY EXIT PRODUCT J ENTRY O Z W Q W n CONCEPT FLOOR PLAN ' 1 /4" = 1'-0" CONCEPT DESIGN PROJ. NO. 1903-03 DATE: APRIL 9, 2019 DRAWN BY: J. MOBERG REVISIONS NO. DATE NOTES CONCEPT FLOOR PLAN (ALPHA) TRAFFIC PLAN Keltic Green has contracted with Nitsch Engineering, a certified traffic consultant and has conducted a full traffic impact report to provide to the Town of Watertown. Please see the complete traffic impact report in Exhibit A, following this "Traffic Plan" Section. The Transportation Impact Report concluded that there will be minimal to negligible impact on the existing traffic in the area. Regardless, and subject to the submission of the Transportation Impact Report, Keltic Green Inc. is providing additional information related to Keltic's strategy to mitigate parking and traffic impacts arising out its operations at the Property. Keltic hereby proposes the implementation of an initial appointment -only plan (the "Appointment Plan"), which is described below, to mitigate concerns related to parking and traffic impacts. Implementation of similar appointment -only plans have proven to be successful for the mitigation of initial traffic and parking impacts at other adult -use retail marijuana establishments throughout the Commonwealth. For example, Alternative Therapies Group, Inc. in Salem, Sanctuary Medicinals, Inc. in Gardner, and Good Chemistry, Inc. in Worcester all implemented appointment -only plans that were gradually phased out as the initial excitement associated with these businesses subsided and customer demand and traffic decreased as a result of the opening of additional adult -use retail marijuana establishments around the Commonwealth. Keltic's Appointment Plan is intended to mirror the success of the appointment -only plans used by other marijuana establishments in the Commonwealth to ensure that there is as little impact as possible to traffic in the area. Keltic would anticipate that Watertown's Police, Fire, and Engineering Departments will likely approve of the use of the Appointment Plan as an initial strategy to mitigate the Town's traffic and parking concerns. The specifics of Keltic's Appointment Plan are set forth in greater detail below. I. Appointment Plan Goals — Ensure the safety of customers, employees, and surrounding abutters; — Minimize the impact of traffic flow on adjacent businesses and nearby streets; — Facilitate efficient parking lot operations to minimize backup on adjacent streets; — Implement efficient appointment systems to reduce initial traffic burdens; — Provide information to allow customers and patients to get to/from the Property efficiently and safely; — Promote efficient coordination between Keltic and the Town; and — Establish open lines of communication with the Town, abutters, nearby residents, and local businesses. II. Appointment Plan Details a. The Appointment -Only Period Upon opening, Keltic anticipates its hours to be Mon -Wed 8:00 am —10:00 pm, Thurs-Sat 8:00 am —11:00 pm and Sun 9:00 am — 10:00 pm (willing to adjust) For at least the first 30 days of operation (or as long as necessary), as part of its soft opening, Keltic will only offer facility access to customers who have made an appointment online through Keltic's website (the "Appointment Only Period"). Offering services at the Property by appointment only will prevent an overflow of customers, mitigate traffic impacts, educate customers about how to safely access the facility, and allow for efficient operations. During the Appointment -Only Period, Keltic will allow up to thirty-two (32) appointments per hour, or approximately one (1) appointments every fifteen (15) minutes at up to seven (8) separate point of sale counters. A chart displaying a breakdown of the Appointment Plan over the course of a day is attached hereto as Exhibit B. Keltic anticipates that as customers become familiar with the facility, the process, and the products, they will, on average, spend less than ten (15) minutes at the facility per visit. Furthermore, as detailed below, Keltic's website will have a pre -order option that will allow customers to place their orders online prior to arrival at the facility. This will reduce visit time and help mitigate potential traffic, parking and congestion issues. b. Dissemination of Appointment -Only Information Keltic will be sure to include clearly marked information about the Appointment -Only Period, traffic, and parking for the Property on its website and social media channels. Although Keltic does not anticipate conducting any outbound media activities, it will include information about appointment requirements, traffic, and parking in its responses to inbound media requests should it receive any. Additionally, a map of traffic flows will be available on Keltic's website. Keltic will also provide this information to the Town of Watertown and the Watertown Police Department to be shared at their discretion. Prior to opening, Keltic will send a mailing to the neighborhoods closest to the Property to inform them about opening procedures and provide contact information that they can utilize to receive additional information or alert Keltic's management team about system inefficiencies. c. Booking Appointments The process for booking appointments through Keltic's website will involve the following steps: — After acknowledging that they are at least 21 years of age or older, the customer accessing the website will click on an "adult -use appointment" link, which will bring them to a page where they will input their name, email address and phone number. — Once the customer's contact information has been inputted, they will then be able to select an available appointment time during Keltic's normal business hours. — Once Keltic confirms the appointment, the customer will receive an email and text message confirmation. d. Online Ordering After setting an appointment by following the steps above, the process for customers pre -ordering products through Keltic's website will involve the following steps: — The customer accessing the website will click on a "pre -order" link, which will bring them to a page that contains Keltic's menu, which will be updated on a daily basis. — The customer will then be able to select their desired products and submit the order to Keltic to be pre -packaged at Keltic's facility. — Upon the customer's arrival at the facility at their designated appointment time, the order will be ready for payment and pick up. e. Plan Evaluation Keltic will request meetings with representatives from Watertown and the Watertown Police Department to discuss traffic and queue management at the following times: — Prior to opening the facility; — One week after opening; — Two weeks after opening or as needed in the first month after opening; — One month after opening; — Two months after opening; — Six months after opening; and — Upon request of the Littleton Police Department and/or the Town Officials. Prior to implementing any changes to the Appointment Plan, Keltic will seek input from Town Officials regarding the possibility of increasing the number of available appointments per hour in order to respond to customer demand. III. Site Plan and Parking a. Available Parking Spaces Keltic currently has twenty-nine (29) dedicated parking spaces available for its customers. Employees will be parking in an off -site location. Accordingly, the available parking at the Property is sufficient to accommodate Keltic's customer parking demands. b. Parking Lot Management During the Appointment -Only Period and for as long as is deemed necessary by the Watertown Police Department and Town officials, Keltic will seek to employ police details in areas designated by the Watertown Police Department to control and direct traffic in front of the Property. During the Appointment -Only Period and as long is deemed necessary by the Watertown Police Department and Town officials, Keltic will employ parking lot attendants to ensure the safe and efficient flow of customers in and out of the parking lot. The parking lot attendants will direct customers to available parking spaces to eliminate backups from occurring in and out of the lot, and assist customers to safely traverse the parking lot when walking in and out of the facility. Keltic will designate a marked area of the parking lot for ride share operations to reduce inefficiencies within the parking lot. Signage will indicate that vehicles may not idle in the lot. Further, before a customer is permitted to enter the facility, a member of the police detail or security guard will confirm their appointment and will not be allowed to park prior to 10 minutes before appointment time. Email may be printed out to show confirmation of appointment or the customer may choose to show receipt of email on their phone for proof they do have a scheduled appointment to enter the facility. IV. Customer Flow a. Entry Vestibule In accordance with 935 CMR 500.140(3), access to Keltic's facility is limited to individuals 21 years of age and older. Customers will be required to ring an exterior video doorbell to gain access into the premises. Individuals will be required to show proof of identification at the video doorbell to gain entry. When the door is opened, an attendant will immediately register their entry into a digital tally system. Keltic specifically designed its facility to address the issue of customers potentially having to wait at the exterior of the facility by creating an expanded interior vestibule to accommodate customers inside and minimize lines outside the facility. Upon a customer's entry into the lobby, they will be required to provide proof of identification that is scanned via a card reader to confirm the form of identification is valid. An individual will not be admitted to the sales floor unless the Keltic agent has verified that the individual is an appropriate age to enter the facility. b. Retail Floor Once inside the retail area, adult use customers will enter a queue to obtain individualized service where they may select any of the products available to them with the help of a Keltic agent. A Keltic agent will remain permanently stationed at the queue to assist in directing them, as desired, directly to a point of sale terminal or to the dispensary floor for a personalized discussion with an agent. Upon checkout, customers will be required to confirm their identities and age a second time. Checkout also activates the seed -to -sale tracking system, which will be compliant with 935 CMR 500.105(8). In the event a Keltic agent determines an individual would place themselves or the public at risk, the agent will refuse to sell any marijuana products to that individual. c. Queuing/Loitering Prevention Keltic will not allow physical queuing to occur at the exterior of the facility. As stated above, Keltic specifically designed its facility to address customers potential having to wait at the exterior by creating an expanded interior vestibule to accommodate customers inside and minimize lines outside the dispensary. Initially, during the Appointment Period, queuing will not be an issue as the number of customers will be limited. In the event that the number of appointments and/or customers increases, Keltic's expanded interior vestibule will provide an area for customers to wait until a point -of -sale counter becomes available. Keltic will also utilize parking lot attendants and a Watertown Police detail to assist with monitoring any "queuing" or loitering outside the Property. These techniques, combined with Keltic's Appointment Plan, and pre-order/pickup system should serve to ease, if not eliminate, any potential crowd control issues. Keltic will continue to utilize, hone, and develop these techniques as long as is necessary to alleviate any potential issues related to crowd control. Finally, when a customer exits the facility, they will not be allowed to hang around or loiter in the parking lot. A parking lot attendant and/or the Watertown Police detail will monitor for such behavior and immediately direct any loitering customer to leave the parking area in order to free up their parking space for the next customer arriving for their appointment. This no loitering policy will be strictly enforced to mitigate the chances of any customers congregating outside of the facility. IV. Conclusion Keltic is committed to taking affirmative steps to ensure that its adult -use retail marijuana establishment will not result in any disruption to the surrounding area. As set forth above, Keltic intends to address any concerns related to traffic and crowd control through the implementation of the Appointment Plan, utilization of designated and surrounding parking areas, and through an ongoing and transparent relationship with the Watertown Police Department and other Town officials. Keltic is dedicated to making a positive impact in the Watertown community by being a good corporate citizen, contributing volunteer hours and charitable donations, as well as through the payment of fees negotiated in the Host Community Agreement. Watertown voted in favor of adult -use marijuana and Keltic is prepared to provide the community with consistent, high -quality, products, service, and education in a safe, friendly, and inviting environment. Exhibit B — Daily Appointment Plan 08:00 AM 08:15 AM 08:30 AM 08:45 AM 09:00 AM Appointment 1 Appointment 2 Appointment 3 Appointment 4 Appointment 5 Appointment 1 Appointment 2 Appointment 3 Appointment 4 Appointment 5 Appointment 1 Appointment 2 Appointment 3 Appointment 4 Appointment 5 09:15 AM 09:30 AM 09:45 AM 10:00 AM 10:15 AM 10:30 AM 10:45 AM 11:00 AM 11:15AM 11:30 AM 11:45 AM 12:00 PM 12:15 PM 12:30 PM 12:45 PM 1:00 PM 1:15 PM 1:30 PM 1:45 PM 2:00 PM 2:15 PM Appointment 6 Appointment 7 Appointment 8 Appointment 9 Appointment 10 Appointment 11 Appointment 12 Appointment 13 Appointment 14 Appointment 15 Appointment 16 Appointment 17 Appointment 18 Appointment 19 Appointment 20 Appointment 21 Appointment 22 Appointment 23 Appointment 24 Appointment 25 Appointment 26 Appointment 6 Appointment 7 Appointment 8 Appointment 9 Appointment 10 Appointment 11 Appointment 12 Appointment 13 Appointment 14 Appointment 15 Appointment 16 Appointment 17 Appointment 18 Appointment 19 Appointment 20 Appointment 21 Appointment 22 Appointment 23 Appointment 24 Appointment 25 Appointment 26 Appointment 6 Appointment 7 Appointment 8 Appointment 9 Appointment 10 Appointment 11 Appointment 12 Appointment 13 Appointment 14 Appointment 15 Appointment 16 Appointment 17 Appointment 18 Appointment 19 Appointment 20 Appointment 21 Appointment 22 Appointment 23 Appointment 24 Appointment 25 Appointment 26 2:30 PM 2:45 PM 3:00 PM 3:15 PM 3:30 PM 3:45 PM 4:00 PM 4:15 PM 4:30 PM 4:45 PM 5:00 PM 5:15 PM 5:30 PM 5:45 PM 6:00 PM 6:15 PM 6:30 PM 6:45 PM 7:00 PM 7:15 PM 7:30 PM Appointment 27 Appointment 28 Appointment 29 Appointment 30 Appointment 31 Appointment 32 Appointment 33 Appointment 34 Appointment 35 Appointment 36 Appointment 37 Appointment 38 Appointment 39 Appointment 40 Appointment 41 Appointment 42 Appointment 43 Appointment 44 Appointment 45 Appointment 46 Appointment 47 Appointment 27 Appointment 27 Appointment 28 Appointment 29 Appointment 30 Appointment 31 Appointment 32 Appointment 33 Appointment 34 Appointment 35 Appointment 36 Appointment 37 Appointment 38 Appointment 39 Appointment 40 Appointment 41 Appointment 42 Appointment 43 Appointment 44 Appointment 45 Appointment 46 Appointment 47 Appointment 28 Appointment 29 Appointment 30 Appointment 31 Appointment 32 Appointment 33 Appointment 34 Appointment 35 Appointment 36 Appointment 37 Appointment 38 Appointment 39 Appointment 40 Appointment 41 Appointment 42 Appointment 43 Appointment 44 Appointment 45 Appointment 46 Appointment 47 7:45 PM 8:00 PM 8:15 PM 8:30 PM 8:45 PM 9:00 PM 9:15 PM 9:30 PM 9:45 PM CLOSE Appointment 48 Appointment 49 Appointment 50 Appointment 51 Appointment 52 Appointment 53 Appointment 54 Appointment 55 Appointment 56 NO APPOINTMENTS Appointment 48 Appointment 48 Appointment 49 Appointment 50 Appointment 51 Appointment 52 Appointment 53 Appointment 54 Appointment 55 Appointment 56 NO APPOINTMENTS Appointment 49 Appointment 50 Appointment 51 Appointment 52 Appointment 53 Appointment 54 Appointment 55 Appointment 56 NO APPOINTMENTS * NOTE: 8 Point of Sale Terminals will be in place. This chart shows 3 Point of Sale Terminals to reflect 3 total appointments every 15 minutes. The total proposed MAXIMUM number of appointments over the course of a day is 448 appointments. The AVERAGE number of appointments over the course of a day is expected to be 300 appointments. The data entered in the financial projections worksheet within the Business Plan is based on the Average of 300 appointments per day. From a traffic perspective, this will equate to 8 cars entering the parking lot every 15 minutes and 8 cars exiting the parking lot every 15 minutes. On average, this allows each car a little over 2 minutes to navigate out onto Arsenal Street which does not impact existing traffic. Transportation Impact Report Recreational Marijuana Retailer Watertown, MA July 26, 2019 Prepared for: Keltic Green, Inc. 41 Matawanakee Trail Littleton, MA 01460 Submitted by: Nitsch Engineering 2 Center Plaza, Suite 430 Boston, MA 02108 Nitsch Project #13632. TABLE OF CONTENTS 1 INTRODUCTION............................................................................................................................................4 2 EXISTING CONDITIONS...............................................................................................................................6 2.1 Study Area Roadways.......................................................................................................................... 6 2.2 Study Area Intersections....................................................................................................................... 7 2.3 Existing Parking..................................................................................................................................10 3 SAFETY ANALYSIS....................................................................................................................................12 3.1 Crash Data.......................................................................................................................................... 12 3.2 Intersection Crash Rates.................................................................................................................... 13 4 EXISTING TRAFFIC CONDITIONS............................................................................................................14 4.1 2019 Traffic Count Data...................................................................................................................... 14 4.2 Seasonal Adjustment.......................................................................................................................... 14 5 FUTURE NO -BUILD TRAFFIC CONDITIONS............................................................................................16 5.1 Background Growth............................................................................................................................16 5.2 2026 No -Build Traffic Volumes...........................................................................................................16 6.1 Trip Generation...................................................................................................................................18 6.2 Trip Distribution and Assignment........................................................................................................20 6.3 Proposed 2026 Build Volumes............................................................................................................20 6.4 Parking Generation............................................................................................................................. 24 6.5 Parking Adequacy............................................................................................................................... 24 7 OPERATIONS ANALYSIS..........................................................................................................................25 7.1 Level of Service Criteria......................................................................................................................25 7.2 Capacity Analysis................................................................................................................................ 25 7.3 2019 Existing Capacity Analysis.........................................................................................................26 7.4 2026 No -Build Capacity Analysis........................................................................................................ 28 7.5 Traffic Signal Warrant......................................................................................................................... 30 7.6 2026 Build Capacity Analysis.............................................................................................................. 31 8 SIGHT DISTANCE.......................................................................................................................................34 9 CONCLUSIONS AND MTIGATION.............................................................................................................36 9.1 Conclusions.........................................................................................................................................36 9.2 Mitigation.............................................................................................................................................36 -2- LIST OF TABLES Table 1 - Crash Summary............................................................... Table 2 - Crash Rate Summary....................................................... Table 3 - Automatic Traffic Recorder (ATR) Summary ................... Table 4 - Site Generated Trips ........................................................ Table 5 - Level of Service Conditions for Intersections .................. Table 6A - Level of Service Summary — 2019 Existing Conditions Table 6B - LOS Summary Existing Saturday .................................. Table 7A - Level of Service Summary — 2026 No -Build Conditions Table 7B - LOS Summary No -Build Saturday ................................. Table 8A - Level of Service Summary — 2026 Build Conditions ..... Table 8B - LOS Summary Build Saturday ....................................... Table 9 - Sight Distance Criteria ..................................................... Table 10 - Proposed Sight Distance Evaluation ............................. LIST OF FIGURES 12 13 14 19 25 26 27 28 29 31 32 34 35 Figure1: Locus Map............................................................................................................................................. 5 Figure 2: Intersection Locations......................................................................................................................... 11 Figure 3: 2019 Existing Peak Hour Volumes..................................................................................................... 15 Figure 4: 2026 Future No -Build Peak Hour Volumes......................................................................................... 17 Figure5: Trip Distribution................................................................................................................................... 21 Figure6: Trip Assignment.................................................................................................................................. 22 Figure 7: 2026 Future Build Peak Hour Volumes.............................................................................................. 23 -3- INTRODUCTION 1.1 General/Site Location Nitsch Engineering has been retained by Keltic Green, Inc. (KGI) to prepare a qualitative assessment of safety, traffic circulation, and traffic access/egress associated with the proposed recreational marijuana retail facility located at 390 Arsenal Street in Watertown, Massachusetts. The report describes the project area, presents traffic counts, and analyzes existing and future traffic operation efficiency. The data is used to examine the traffic circulations and overall operations, and to evaluate the traffic impacts of the proposed facility. The standards used for analysis conform to the 2009 edition of the Manual on Uniform Traffic Control Devices (MUTCD) and the 2010 edition of the Highway Capacity Manual. The following conditions are analyzed in this report: Existing Conditions 2019; Future 2026 No -Build; and Future 2026 Build. Figure 1 is the Locus Map showing the proximity of the new facility and the surrounding roadway network, and the proposed study intersections. -4- ;AP.,qw IT jiFf +� �' � .. • ,: �+$� �� .' �,�' _ "� r� � - .+ice xr. +'' i LAU - L } �:_ a • �,:�., _V� T TOWN - r . 1GP RESS STREET L J Project Location AIlk RSEN ---- - r A'' s •, 1 ' ArsenatS#re W ELER_AVENUE et nrw� AR VENUE----- 2 EXISTING CONDITIONS The proposed facility will be sited on a parcel of land at 390 Arsenal Street in Watertown. The existing Site has two curb cuts on Arsenal Street. 2.1 Study Area Roadways To examine the existing conditions, we studied and collected data at the following roadways: 1. Arsenal Street; 2. Arsenal Way; 3. Arsenal Court; 4. Talcott Avenue; 5. Kingsbury Avenue; and 6. School Street. Arsenal Street Arsenal Street is classified by the MassDOT as an urban minor arterial or rural major collector and runs in the east -west directions with its eastern terminus at Boston City line and its western terminus at North Beacon Street. The posted speed limit along the roadway is 30 miles per hour. The land use along Arsenal Street near the project site is a mix of residential and commercial. The roadway in the study area is within the jurisdiction of the Town of Watertown. Arsenal Way Arsenal Way is classified by the MassDOT as a local roadway and runs in the south -north directions with its southern terminus at Arsenal Street and its northern terminus is dead end. The road is not posted for speed limit. The land use along Arsenal Way is primarily commercial. The roadway is within the jurisdiction of the Town of Watertown. Arsenal Court Arsenal Court is classified by the MassDOT as a local roadway and runs in the south -north directions with its northern terminus at Arsenal Street and its southern terminus is dead end. The road is not posted for speed limit. The land use along Arsenal Court is primarily commercial. The roadway is within the jurisdiction of the Town of Watertown. Talcott Avenue Talcott Avenue is classified by the MassDOT as a local roadway and runs in the south -north directions with its southern terminus at Kingsbury Avenue and its northern terminus at Arsenal Street. The road is not posted for speed limit. The land use along Talcott Avenue is primarily commercial. The roadway is within the jurisdiction of the Town of Watertown. on Kingsbury Avenue Kingsbury Avenue is classified by the MassDOT as a local roadway and runs in the north -south then east directions with its northern terminus at Arsenal Street and its eastern terminus at Talcott Avenue. The road is not posted for speed limit. The land use along Kingsbury Avenue is primarily commercial. The roadway is within the jurisdiction of the Town of Watertown. School Street School Street is classified by the MassDOT as a urban collector or rural minor collector and runs in the south - north directions with its southern terminus at Arsenal Street and its northern terminus at Belmont Town line. The posted speed limit along the roadway is 35 miles per hour. The land use along School Street is primarily residential, with pockets of commercial use. The roadway is within the jurisdiction of the Town of Watertown. 2.2 Study Area Intersections The study area contains four intersections (Figure 2). To examine the existing conditions, we designated the following intersections as the main intersections of the study. 1. Intersection of Arsenal Street at Watertown Mall; 2. Intersection of Arsenal Street at Arsenal Mall; 3. Intersection of Arsenal Street at Arsenal Way and Arsenal Court; 4. Intersection of Arsenal Street at Talcott Avenue; and 5. Intersection of Arsenal Street at School Street Arsenal Street at Watertown Mall Arsenal Street and Watertown Mall driveway intersect as a three-way signalized intersection. Arsenal Street approaches from the east and the west, and Watertown Mall driveway from the north. ADA accessible crosswalks are present across Arsenal Street EB approach and Watertown Mall driveway. From east, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline that transitions into a raised 7-foot wide concrete median. Approaching the intersection, the approach consists of three lanes, one exclusive right turn lane that permits right -turn movements transitioning north onto the Watertown Mall driveway, and two through lanes that permit through movements transitioning onto Arsenal Street WB. The width of the roadway at the intersection is approximately 75 feet. Cement concrete sidewalks are present on both sides of the roadway. From west, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of three lanes, one exclusive left turn lane that permits left -turn movements transitioning north onto the Watertown Mall driveway, and two through lanes that permit through movements transitioning onto Arsenal Street EB. The width of the roadway at the intersection is approximately 62 feet. Cement concrete sidewalks are present on both sides of the roadway. -7- From north, Watertown Mall driveway is a two-way roadway with two lanes in the south direction and one lane in the north direction, separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes, one exclusive right -turn lane that permits right turn movements transitioning west onto Arsenal Street WB, and one exclusive left -turn lane that permits left turns transitioning east onto Arsenal Street EB. The width of the roadway at the intersection is approximately 45 feet. Cement concrete sidewalk is present on the north side of the roadway. Arsenal Street at Arsenal Mall Arsenal Street, Arsenal Mall driveway and Watertown Mall secondary driveway intersect as a four-way signalized intersection. Arsenal Street approaches from the east and the west, and Watertown Mall secondary driveway from the north, and Arsenal Mall driveway from the south. ADA accessible crosswalks are present across all approaches at the intersection. From east, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of three lanes, one exclusive left turn lane that permits left -turn movements transitioning south onto the Arsenal Mall driveway, and two through lanes that permit through movements transitioning onto Arsenal Street WB and right turns onto Watertown Mall secondary driveway. The width of the roadway at the intersection is approximately 60 feet. Cement concrete sidewalks are present on both sides of the roadway. From west, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of four lanes, one exclusive left turn lane that permits left -turn movements transitioning north onto the Watertown Mall secondary driveway, two through lanes that permit through movements transitioning onto Arsenal Street EB, and one exclusive right -turn lane that transitions south onto Arsenal Mall driveway. The width of the roadway at the intersection is approximately 75 feet. Cement concrete sidewalks are present on both sides of the roadway. From north, Watertown Mall secondary driveway is a two-way roadway with one lane in each direction, separated by a double yellow centerline. Approaching the intersection, the approach consists of one general purpose lane that permits right turn movements transitioning west onto Arsenal Street WB, through movements south to Arsenal Mall driveway, and left turns transitioning east onto Arsenal Street EB. The width of the roadway at the intersection is approximately 35 feet. There are no sidewalks present on either side of the roadway. Arsenal Street at Arsenal Way and Arsenal Court Arsenal Street, Arsenal Court and Arsenal Way intersect as a four-way signalized intersection. Arsenal Street approaches from the east and the west, Arsenal Way from the north, and Arsenal court from the south. ADA accessible crosswalks are present across all approaches at the intersection. From east, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes, one that permits left -turn movements transitioning south onto the Arsenal court and through movements transitioning onto Arsenal Street WB, and one that permits through movements transitioning onto Arsenal Street WB and right turns onto Arsenal Way. The width of the roadway at the intersection is approximately 55 feet. Cement concrete sidewalks are present on both sides of the roadway. From west, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes, one that permits left -turn movements transitioning north onto the Arsenal way and through movements transitioning onto Arsenal Street EB, and one that permits through movements transitioning onto Arsenal Street EB and right turns onto Arsenal Court. The width of the roadway at the intersection is approximately 53 feet. Cement concrete sidewalks are present on both sides of the roadway. From north, Arsenal Way is a two-way roadway with one lane in each direction, separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes, one exclusive left -turn lane that permits left -turns transitioning east onto Arsenal Street EB, and one that permits through movements south onto Arsenal court and right turns transitioning west onto Arsenal Street WB. The width of the roadway at the intersection is approximately 46 feet. Cement concrete sidewalk is present on the east side of the roadway. From south, Arsenal Court is a two-way roadway with one lane in each direction, separated by a double yellow centerline. Approaching the intersection, the approach consists of one general purpose lane that permits right turn movements transitioning east onto Arsenal Street EB, through movements north to Arsenal Way, and left turns transitioning west onto Arsenal Street WB. The width of the roadway at the intersection is approximately 26 feet. Cement concrete sidewalk is present on the west side of the roadway. Arsenal Street at Talcott Avenue Arsenal Street and Talcott Avenue intersect as a three-way signalized intersection. Arsenal Street approaches from the east and the west, and Talcott Avenue from the south. ADA accessible crosswalks are present across all approaches at the intersection. From east, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes that permits left -turn movements transitioning south onto Talcott Avenue and through movements transitioning onto Arsenal Street WB. The width of the roadway at the intersection is approximately 54 feet. Cement concrete sidewalks are present on both sides of the roadway. From west, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes that permits right -turn movements transitioning south onto Talcott Avenue and through movements transitioning onto Arsenal Street EB. The width of the roadway at the intersection is approximately 53 feet. Cement concrete sidewalks are present on both sides of the roadway. M From south, Talcott Avenue is a two-way roadway with two lanes in each direction, separated by a 36-ft wide raised grass median with a 6-ft wide sidewalk in the middle. Approaching the intersection, the approach consists of two lanes, one exclusive left -turn lane that permits left turn movements transitioning west onto Arsenal Street WB, and one exclusive right -turn lane that permits right turns transitioning east onto Arsenal Street EB. The width of the roadway at the intersection is approximately 77 feet. Cement concrete sidewalk is present in the median and west side of the roadway. Arsenal Street at School Street Arsenal Street and School Street intersect as a three-way signalized intersection. Arsenal Street approaches from the east and the west, and School Street from the north. ADA accessible crosswalks are present across all approaches at the intersection. From east, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes that permits right -turn movements transitioning north onto School Street and through movements transitioning onto Arsenal Street WB. The width of the roadway at the intersection is approximately 52 feet. Cement concrete sidewalks are present on both sides of the roadway. From west, Arsenal Street is a two-way roadway with two lanes in each direction separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes that permits left -turn movements transitioning north onto School Street and through movements transitioning onto Arsenal Street EB. The width of the roadway at the intersection is approximately 52 feet. Cement concrete sidewalks are present on both sides of the roadway. From north, School Street is a two-way roadway with one lane in each direction, separated by a double yellow centerline. Approaching the intersection, the approach consists of two lanes, one exclusive left -turn lane that permits left turn movements transitioning east onto Arsenal Street EB, and one general purpose lane that permits left -turn movements transitioning east onto Arsenal Street EB and right turns transitioning west onto Arsenal Street WB. The width of the roadway at the intersection is approximately 52 feet. Cement concrete sidewalks are present on both sides of the roadway. 2.3 Existing Parking Nitsch Engineering inventoried the site. 24 parking spaces exist in the parking lot. None of the spots are marked as ADA accessible spaces -10- � ''•y+. � „ a •r'� �` '.■� � �, Wl��� ��� � ,ram A���t .�, .��.�•: tea• V ` J. art• -- ~� y E TOW y. - t's. 71N ifs V : all I e'` a► - ^' -- iLIN* N STUDY INTERSECTIONS: OArsenal Street at Watertown �. I •.P, Arsenal Street at Arsenal Mall _ Arsenal Street at Arsenal Way Arsenal r i O Street at Talcott f� Arsenal Street at School Street ' ARSENAL C ART_ f ~! ARSENqL=STREEj yy�� rrFr EAir.,sra.� 1 1 11 111 3 SAFETY ANALYSIS 3.1 Crash Data Crash data available from MassDOT for the three most available recent years of 2014 to 2016 was collected and reviewed for the study area intersections. The total crashes, severity, manner of collision, and percentage that occurred during peak hours and/or wet/icy weather conditions for each intersection are presented in Table 1, Crash Summary. A copy of the crash data is included in the Appendix. Tahle 1 - Crash Summary Number of Crashes Severity Manner of Collision Percent During Location Total Crashes Avg PDa Plb NRc Fd Ae REf s 9 Otherh Incl. Ped- Bike PeakYear ours' Hours Wet/Icy Condition Conditions Arsenal 2014 0 0 0 0 0 0 0 0 0 0 0% 0% Street at Watertown 0.0 2015 0 0 0 0 0 0 0 0 0 0 0% 0% 2016 0 0 0 0 0 0 0 0 0 0 0% 0% Mall 2014 0 0 0 0 0 0 0 0 0 0 0% 0% Arsenal 2015 0 0 0 0 0 0 0 0 0 0 0% 0% Street at 0.0 Arsenal Mall 2016 0 0 0 0 0 0 0 0 0 0 0% 0% Arsenal 2014 0 0 0 0 0 0 0 0 0 0 0% 0% Street at 2015 4 3 1 0 0 1 2 0 1 1 25% 0% Arsenal Way 2.3 and Arsenal Court 2016 3 2 1 0 0 1 1 0 1 0 0% 33% Arsenal 2014 1 1 0 0 0 0 1 0 0 0 100% 100% Street at Talcott 2.0 2015 5 2 3 0 0 1 3 0 1 0 20% 20% 2016 0 0 0 0 0 0 0 0 0 0 0% 0% Avenue Arsenal 2014 3 3 0 0 0 1 1 0 1 0 67% 33% Street at School 2.7 2015 2 2 0 0 0 1 1 0 0 0 0% 0% 2016 3 3 0 0 0 0 1 0 2 0 0% 33% Street Total ALL 21 7 16 5 0 0 5 10 0 6 1 24% 24% aProperty Damage Only; bPersonal Injury Only (non -Fatal Injury); `Not Reported; dFatality; eAngle; (Rear end; 91-lead on; 'Sideswipe, opposite direction; sideswipe, same direction, single vehicle crash, rear -to -rear, not reported, unknown, etc.; JIncludes pedestrian or cyclist; 'Occurred between 7-9am or 4-6pm In terms of severity, 16 reported property damages, and five reported personal injury. In terms of the type of collision, five reported an angle collision, another 10 were rear end collision, and six reported other type. There were one crash that included a bicycle or a pedestrian. In total 24% of the crashes occurred during wet/icy conditions, and 24% of the crashes occurred during peak hours. Analyzing the crash data, as most crashes were of angle or rear -end type, the crashes were most likely caused by driver carelessness or inattentiveness. -12- 3.2 Intersection Crash Rates The intersection crash rate is recognized as an effective tool to measure the safety of intersections. For intersections, crash rates are expressed by the number of crashes per million entering vehicles (MEV). As of June 26, 2018, the average statewide crash rate for unsignalized intersections is 0.57 crashes per MEV and 0.78 crashes per MEV for signalized intersections. For District 6, which includes the Town of Watertown, the rate for unsignalized intersections is 0.52 crashes per MEV and 0.71 crashes per MEV for signalized intersections. As shown in Table 2 - Crash rate Summary, all of the Intersections are below both Statewide and Districtwide averages. Crash rate worksheets can be found in Appendix A-3. Table 2 - Crash Rate Summary Total Compared to Averaged Location Control Crashes Crash Rate' Statewide District 4 Arsenal Street at Watertown Signalized 0 0.00 Below Below Mall Arsenal Street at Arsenal Signalized 0 0.00 Below Below Mall Arsenal Street at Arsenal Signalized 7 0.35 Below Below Way and Arsenal Court Arsenal Street at Talcott Signalized 6 0.28 Below Below Avenue Arsenal Street at School Signalized 8 0.32 Below Below Street Signalized Average Unsignalized Average Statewide 0.78 0.57 District 6 0.71 0.52 -13- 4 EXISTING TRAFFIC CONDITIONS 4.1 2019 Traffic Count Data Automatic Traffic Recorder (ATR) Data Nitsch Engineering retained Precision Data Industries, LLC (PDI) of Framingham, Massachusetts to conduct 48-hour Automatic Traffic Recorder (ATR) vehicle traffic counts at the study area; from Friday, June 14 to Saturday, June 15, 2019. Table 3 summarizes the ATR data. A copy of the raw traffic count data is included in Appendix A-1. Table 3 - Automatic Traffic Recorder (ATR) Summary ADTa PEAK HOUR TRAFFIC LOCATION PERIOD K factor a VOLUMES DIRECTIONAL PERIOD VOLUMES DIRECTIONAL (vpd)b DISTRIBUTION (vph)° DISTRIBUTION Arsenal Street Weekday 17,223 57.50% WB Morning 1,179 50.5% WB 0.07 west of Talcott Avenue Evening 1,346 61.9% WB 0.08 Turning Movement Count (TMC) Data PDI collected Turning Movement Counts (TMC) data for the study area intersections on Friday, June14, 2019 from 11:00 AM to 1:00 PM and 4:00 PM to 6:00 PM; and on Saturday June 15, 2019 from 11:00 AM to 1:00 PM to capture both the weekday midday and afternoon peak periods as well as Saturday midday peak periods. The TMC data included bicycle and pedestrian counts. The peak hours within the study area were established as 11:00 AM to 12:00 PM during the weekday morning period, 4:00 PM to 5:00 PM during the afternoon period, and 12:00 AM to 1:00 PM during Saturday midday. The 2019 Existing Traffic Volumes are shown in Figure 3. 4.2 Seasonal Adjustment Nitsch Engineering used the MassDOT 2013 Weekday Seasonal Adjustment Factors to establish if the traffic counts needed to be seasonally adjusted. The composition of the study area falls within "Group U4-7 Urban Arterials". Counts within Group U4-7 collected during the months of May and June experience values equal to one (1) to three (3) percent higher than the average counted volumes. To present conservative traffic volumes in this study, Nitsch Engineering made no reduction in the counted volumes. -14- LEGEND: O SIGNALIZED INTERSECTION _r U UNSIGNALIZED INTERSECTION'S xx(xx)[xx] AM(PM)[SAT] TRAFFIC VOLUMES 61, Arsenal st I� )613) 24,9(324)[2101ena/sr 3 (c81(34� 1 J2(z3s �+ 428(426)(440)550(4j45(1)fs)� S - • ♦7 1f22 ) 409(3)3)[532] � 17(22.)f201 z pr 0 0 O p - O _ 3 6(5)(3) o 535(S9 /- 95(75) -81 -- 5p(Sg 398 (S3�) Arsena/ St Y '� 15� 4(461)[550 �tt )f58) .\4 (118)(128 116(73)[104]� �/* 3j12(115)1213] 12(44q)(42q) • > 2(4p3)f422 - ^L PROJECT SITE Arsena/St Sg�(6 ) �� -�. s .•.. 20 S' �z(11fo) N � : - 0 250 500 1,000 N ':= Feet Figure 3: 2019 Existing Peak Hour Volumes Recreational Marijuana Retailer Watertown, MA Data Source: MassGIS Nitsch Project #13632 IVitsch Engineering 5 FUTURE NO -BUILD TRAFFIC CONDITIONS 5.1 Background Growth Nitsch Engineering used the data from the nearest MassDOT count station #4134 for previous years, located on Arlington Street just north of Arsenal Street to calculate the background traffic growth. Comparing the values collected at the count station indicates that traffic has increased by approximately 4% since 2009, or equivalent of 0.4 percent per year in this area. We used a conservative annual background traffic growth factor of 1 %, which is also consistent with recent MassDOT projects in eastern Massachusetts. 5.2 2026 No -Build Traffic Volumes The 2026 No -Build Traffic Volumes are shown in Figure 4 and are derived by applying the traffic growth rate of 1 % per year over the seven-year design horizon to project the 2026 traffic volumes. -16- `L ` /ry Arsena/St 26J(34?)1225 458 1� `1 �Oq(» 39(50)135]85s1 C 184(252)177 S (455)l4,- 589(g0g)t7750)381� v /� 438(400)!5>0] 19(29)f��11�� l p O -• o o` IT N 3 6(5)!3I 5>3 F �� ( ... "• 422(49(81)[84] S 58(69)l681185I 4)[589 N o y g PROJECT - N `a SITE0 C -. 1 T ` 4-28(20 f. "i Arsena/sr )!20 ] t� 639 •i", �2� 9)!20 o] 821 c 61g(29(1g)[15I R 9)112]]�� / Figure 4: 2026 Future No -Build Peak Hour Volumes Recreational Marijuana Retailer Watertown, MA Data Source: MassGIS Nitsch Project #13632 LEGEND: O SIGNALIZED INTERSECTION V I� D UNSIGNALIZED INTERSECTION r XX(XX)[XX] AM(PM)[SAT] TRAFFIC VOLUMES r OWN 3 "v S •\44 1 (4 6)/454] 7 V �f 71 ' 0 250 500 1,000 _ Feet 011�r Nitsch Engineering 6 PROPOSED FUTURE CONDITIONS 6.1 Trip Generation Nitsch Engineering used the Institute of Transportation Engineers (ITE) publication Trip Generation, 10th Edition to estimate the vehicle trip rates for the proposed development and establish the net trips as a result of the proposed retail shop and dispensary. Trip generation rates for the retail shop and dispensary were appointment based, and in line with the Land Use Code (LUC) 882 (Marijuana Dispensary). The following information was provided by KGI: • 1,876 square feet of retail; • Hours of Operation: 10:00 AM-10:00 PM (Sunday through Saturday); • KGI's anticipated appointment based maximum customers visits per day: 360 or 30 per hour; • Maximum number of employees at the proposed Facility: 12 — 18 per day; • Based off of KGI's operating experience and projections for the adult use market, the average projected time spent inside our dispensary per customer is 15 minutes. If we assume an average distribution of the 360 customers over the twelve (12) hours our Facility is open, we would expect an average of 8 customers inside our facility at any given time. • We expect an average of two deliveries per week during normal business hours. • To remain conservative in our analysis, we assumed that all site generated trips will be vehicular trips and did not adjust based on other travel mode characteristics (walking/bicycle or transit). Table 4 summarize the total Project generated trips (employees and visitors) for the daily, morning and evening peak hours. -18- Table 4 - Site Generated Trips Proposed Appointment based Trips (LUC 882) Weekday Daily 480 Entering 240 Exiting 240 Weekday Midday Peak 40 Entering 21 Exiting 19 Weekday Evening Peak 57 Entering 28 Exiting 29 Saturday Midday Peak 69 Entering 34 Exiting 35 As illustrated in Table 4, approximately 480 net new daily trips (240 trips in and 240 trips out) are expected to be generated by the Project, with 40 net new trips (21 in and 19 out) during the Midday peak hour, 57 net new trips (28 in and 29 out) during the evening peak hour, and 69 net new trips (34 in and 35 out) during the Saturday midday peak hour. -19- 6.2 Trip Distribution and Assignment The trips to/from the proposed retail shop and dispensary will be distributed and assigned based on the existing travel patterns and logical travel routes, which are based on the existing roadway network both within the Town of Watertown and the surrounding region. The Trip Distribution Percentages specific to the proposed retail shop and dispensary are shown in Figure 5. The resultant trip assignment volumes for both the weekday midday, weekday evening, and Saturday midday peak hours were calculated by multiplying the trip distribution by the trip generation from Table 3 and are shown in Figure 6 for the weekday midday and the weekday evening peak hours. 6.3 Proposed 2026 Build Volumes For the proposed retail shop and dispensary, the corresponding trip assignment volumes were balanced based on the proposed access and egress to the site and added to the 2026 No -Build Volumes to yield the 2026 Build Volumes. The 2026 Build Volumes for the proposed retail shop and dispensary are shown in Figure 7. -20- •- LEGEND: r N J O SIGNALIZED INTERSECTION U UNSIGNALIZED INTERSECTION 13 3 r xxi(xxi) IN (OUT) � Arsenal Sl � L i2$ o� SO a \ . rzs o� ft) S S , • k Y v 25 0 A' IT IML _ A'enar sr "► ' ' A'�anar sr (Sp to g o S 0010 9 k,; 50') S PROJECT ^� r SITEF At . ..','��• '` y � : - �' • yap' nar Soo o - �.. - : 0 250 500 1,000 Figure 5: Trip Distribution Recreational Marijuana Retailer Watertown, MA Data Source: MassGIS Nitsch Project #13632 r 0� Nitsch Engineering Figure 6: Trip Assignment Recreational Marijuana Retailer Watertown, MA Data Source: MassGIS Nitsch Project #13632 r 011� Nitsch Engineering LEGEND: O SIGNALIZED INTERSECTION V I� U UNSIGNALIZED INTERSECTION r 3 v XX(XX)[XX] AM(PM)[SAT] TRAFFIC VOLUMES /"r q�enai st � y •� j16(j89 � . gaenar sr � 4 .� 7j1(3Sq)l23 � 3g(Sp)(3 �16j31 - • , � 1gq(252)l1j S g63(463)(4g0JJ 699(523)Jjg1] 443(40711si 91 � 19(29)1221—. � l ='� 3 0 c h o I •— 8 28(2p)120J • Arsena�sr 6S0(j rc^ j(1g)l2, 91 M .^ S 29(19)l16 N V 628(599)[79 1� asenai st /� Z 6(S)l31 € 11 ._ 11(79)!1 iJ~ l % I y I� 5841654)[6, g A �1 � o 432�529)�l[p�J C (69)( 8J 21 zs(jgX112J� `7� �fj, '6,1sr �452(123)C 7 8(41 4)[228J� S (49p)14j11 r PROJECT 6)14jp1y N� SITE anal s, \ 11 (14 1� ~ �. .r U �� j2S10 (8 31je Amy 04 �. _ f :_ s ,3= ': 0 250 500 1,000 -. K , Feet Figure 7: 2026 Future Build Peak Hour Volumes Recreational Marijuana Retailer Watertown, MA Data Source: MassGIS Nitsch Project #13632 Nitsch Engineering 6.4 Parking Generation Nitsch Engineering used the Institute of Transportation Engineers (ITE) publication Parking Generation Manual, 5th Edition to estimate the parking demand for the proposed development. Parking generation rates for the retail shop and dispensary were based on Land Use Code (LUC) 882 (Marijuana Dispensary). The calculated parking demand for approximately 1,876 square feet dispensary is 14 spaces. As a comparison, Nitsch Engineering also calculated the parking spaces needed for the proposed dispensary based on the vehicular traffic forecasts developed above. As noted, the patron activity is expected to generate 21 vehicle visits during weekday midday peak hour, 29 vehicle visits during weekday evening peak hour, and 35 vehicle visits during Saturday midday peak hour. Based on KGI's operating experience and projections for the adult use market, a typical visit to a dispensary lasts approximately 15 minutes. Therefore, 21 trips over the course of an hour would generate a demand for approximately 6 parking spaces for a weekday midday peak hour. Similarly, 29 trips over the course of an hour would generate a demand for approximately 8 parking spaces for a weekday evening peak hour, and 35 trips over the course of an hour would generate a demand for approximately 9 parking spaces for a Saturday midday peak hour. Assuming that each employee will be commuting and parking at the lot, the project related parking demand will be approximately 27 spaces. 6.5 Parking Adequacy The Facility parking lot, when complete, will provide 29 striped parking spaces that include two accessible spaces. This meets the Architectural Access Board (AAB) Code of Massachusetts Regulations (521 CMR) for the required number of handicapped parking spaces. The parking lot provides adequate parking (29 parking spaces) for the projected peak demand of 27 spaces. -24- 7 OPERATIONS ANALYSIS 7.1 Level of Service Criteria A Level of Service (LOS) analysis is a quantitative assessment of traffic operations at an intersection. Nitsch Engineering conducted a LOS analysis at the study area intersections using the procedures outlined in the 2010 Highway Capacity Manual (HCM)'. The intersections were analyzed using SYNCHRO Version 10 computer software, which conforms to MassDOT requirements. The HCM bases its LOS results on average delay experienced by vehicles at intersections. The HCM categorizes LOS by letters A through F, with LOS A representing minimum delays and good service, and LOS F representing significant delays and poor service. MassDOT considers, LOS A, B, C, and D as acceptable in urban/suburban areas, and LOS E and F as unacceptable. Table 5 shows the LOS criteria for signalized and un-signalized intersections. Table 5 - Level of Service Conditions for Intersections Signalized Intersections Un-signalized Intersections Level of Service' Stopped Delay per Vehicle' Seconds Level of Service' Stopped Delay per Vehicle' Seconds A 0to10 A 0to10 B >10to20 B >10to15 C >20 to 35 C >15 to 25 D >35 to 55 D >25 to 35 E >55 to 80 E >35 to 50 F Over 80 F Over 50 'Reference: 2010 Highway Capacity Manual, TRB Nitsch Engineering analyzed the traffic operations at the study intersections based on the information provided by KGI and the traffic volumes obtained in June 14 and June 15, 2019. The Level of Service Summary for Existing, 2026 No -Build, and 2026 Build conditions are shown in Tables 6 through 8. The analysis worksheets are provided in the Appendix. 7.2 Capacity Analysis Nitsch Engineering performed traffic analyses to evaluate traffic operations for the 2019 Existing Conditions, 2026 No -Build Conditions, and 2026 Build Conditions during the weekday midday, weekday afternoon, and Saturday midday peak hours at the study intersections. The analyses depict the volume -to -capacity (v/c) ratio, vehicle delay, LOS, and the 50th/95th percentile vehicle queues. 12010 Highway Capacity Manual; Transportation Research Board. -25- 7.3 2019 Existing Capacity Analysis Nitsch Engineering analyzed the 2019 Existing Conditions traffic operations at the study intersections based on the existing traffic counts performed by PDI in June 2019. The Level of Service Summary is shown in Table 6A and 6B. The analysis worksheets are provided in Appendix A-4. Table 6A - Level of Service Summary - 2019 Existing Conditions LOCATION DIRECTION / MOVEMENT' WEEKDAY MIDDAY PEAK HOUR WEEKDAY EVENING PEAK HOUR V/CZ FDELAy3 LOS4 500th 905th V/C2 DELAY3 LOS4 500th 905th Arsenal St EB-LT 0.51 11.0 B 38 170 0.55 12.8 B 49 197 Arsenal St. at Arsenal St WB-TR 0.61 16.3 B 68 221 0.65 16.7 B 79 252 School St School St SB-LR 0.54 15.2 B 28 110 0.61 19.4 B 52 160 Total 0.61 14.2 B 0.65 16.1 B Arsenal St EB-LT 0.67 23.5 C 111 173 0.66 26.8 C 100 173 Arsenal St WB-TR 0.51 13.6 B 105 164 0.65 18.0 B 132 210 Arsenal St at Talcott Ave NB -LT 0.27 29.9 C 21 56 0.52 36.0 D 41 100 Talcott Ave Talcott Ave NB-R 0.24 4.8 A 0 14 0.38 11.1 B 0 39 Driveway SB -LTR 0.03 0.1 A 0 0 0.04 18.7 B 1 15 Total 0.67 17.9 B 0.66 21.8 C Arsenal St EB-LT 0.60 17.8 B 103 158 0.56 18.3 B 97 152 Arsenal St at Arsenal St WB-TR 0.63 18.2 B 110 168 0.67 20.2 C 123 190 Arsenal Arsenal Ct NB-LTR 0.18 18.1 B 5 30 0.11 1.1 A 0 2 Ct/Arsenal Way Arsenal Way SB-L 0.12 27.0 C 9 33 0.28 30.5 C 17 51 Arsenal Way SB-TR 0.09 0.3 A 0 0 0.14 0.5 A 0 0 Total 0.63 17.5 B 0.67 18.3 B Arsenal St EB-L 0.42 41.2 D 49 113 0.37 42.0 D 40 96 Arsenal St EB-T 0.42 25.3 C 93 154 0.48 26.4 C 113 184 Arsenal St EB-R 0.23 6.0 A 0 40 0.15 5.1 A 0 26 Arsenal St at Arsenal St WB-L 0.28 41.4 D 26 70 0.31 42.0 D 31 81 Arsenal Mall/Watertown Arsenal St WB-TR 0.63 30.6 C 141 228 0.65 30.0 C 158 251 Mall Arsenal Mall NB -LT 0.51 44.4 D 48 113 0.47 43.6 D 45 106 Arsenal Mall NB-R 0.12 6.9 A 0 27 0.13 6.7 A 0 29 Watertown MI SB-LTR 0.17 17.4 B 5 36 0.13 15.4 B 2 29 Total 0.63 27.8 C 0.65 28.2 C Arsenal St EB-L 0.53 41.0 D 53 119 0.53 41.0 D 55 121 Arsenal St EB-T 0.29 15.9 B 64 105 0.30 15.5 B 68 111 Arsenal St WB-T 0.64 32.8 C 100 170 0.66 32.4 C 107 179 Arsenal St at Watertown Mall Arsenal St WB-R 0.25 2.3 A 0 16 0.19 2.3 A 0 14 Watertown MI SB-L 0.56 37.9 D 71 148 0.52 37.9 D 61 132 Watertown MI SB-R 0.53 10.8 B 0 60 0.55 10.8 B 0 61 Total 0.64 23.1 C 0.66 23.2 C 'SB = Southbound, EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; 2Volume to Capacity Ratio; 3Vehicle Delay, measured in seconds; ^Level Of Service; 550th Percentile Queue (in feet); 695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile volume exceeds capacity, queue may be longer; - = Volume exceeds capacity, queue is theoretically infinite -26- Table 6B - LOS Summary Existing Saturday LOCATION DIRECTION / MOVEMENT WEEKDAY MIDDAY PEAK HOUR V/C2 DELAY3 LOS° 50th Q5 95th Q5 Arsenal St EB-LT 0.61 12.7 B 51 213 Arsenal St. at Arsenal St WB-TR 0.59 17.0 B 71 222 School St School St SB-LR 0.54 16.4 B 31 118 Total 0.61 15.1 B Arsenal St EB-LT 0.74 24.5 C 156 250 Arsenal St WB-TR 0.45 11.6 B 96 147 Arsenal St at Talcott Ave NB -LT 0.25 34.4 C 19 58 Talcott Ave Talcott Ave NB-R 0.40 12.5 B 0 45 Driveway SIB -LTR 0.04 0.3 A 0 0 Total 0.74 18.5 B Arsenal St EB-LT 0.64 16.5 B 86 195 Arsenal St Arsenal St WB-TR 0.58 15.7 B 75 172 at Arsenal Arsenal Ct NB-LTR 0.13 19.2 B 3 28 Ct/Arsenal Arsenal Way SB-L 0.11 27.5 C 7 32 Way Arsenal Way SB-TR 0.02 0.1 A 0 0 Total 0.64 16.3 B Arsenal St EB-L 0.40 43.8 D 42 102 Arsenal St EB-T 0.65 31.8 C 146 237 Arsenal St EB-R 0.23 6.9 A 0 41 Arsenal St at Arsenal St WB-L 0.33 43.7 D 31 81 Arsenal Mall/Watertown Arsenal St WB-TR 0.67 33.3 C 145 239 Mall Arsenal Mall NB -LT 0.59 45.1 D 66 144 Arsenal Mall NB-R 0.10 6.1 A 0 26 Watertown MI SB-LTR 0.09 14.2 B 1 25 Total 0.67 31.6 C Arsenal St EB-L 0.71 47.7 D 113 263 Arsenal St EB-T 0.30 15.9 B 76 124 Arsenal St WB-T 0.67 36.4 D 115 178 Arsenal St at Watertown Mall Arsenal St WB-R 0.21 2.2 A 0 14 Watertown MI SB-L 0.62 42.0 D 90 168 Watertown MI SB-R 0.46 8.8 A 0 62 Total 0.71 26.7 C 'SB = Southbound, EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; 2Volume to Capacity Ratio; 3Vehicle Delay, measured in seconds; °Level Of Service; 550th Percentile Queue (in feet); 695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile volume exceeds capacity, queue may be longer; - = Volume exceeds capacity, queue is theoretical) infinite -27- 7.4 2026 No -Build Capacity Analysis Nitsch Engineering analyzed the 2026 No -Build Conditions traffic operations at the study intersections. The 2026 No -Build Condition represents the 2019 Existing Conditions and projects a traffic increase at the rate of 1 % per year between 2019 and 2026. The Level of Service Summary is shown in Table 7A and 7B. The analysis worksheets are provided in Appendix A-4. Table 7A - Level of Service Summary - 2026 No -Build Conditions LOCATION DIRECTION / MOVEMENT' WEEKDAY MIDDAY PEAK HOUR WEEKDAY EVENING PEAK HOUR V/C2 DELAYS LOS° 50Q,th 905th V/CZ DELAY3 LOS° 500t5 905th Arsenal St EB-LT 0.55 11.7 B 44 188 0.65 14.1 B 56 223 Arsenal St. at Arsenal St WB-TR 0.62 16.7 B 78 246 0.65 17.3 B 92 288 School St School St SB-LR 0.58 16.2 B 35 121 0.65 20.9 C 63 174 Total 0.62 14.9 B 0.65 17.2 B Arsenal St EB-LT 0.69 23.7 C 122 190 0.68 27.2 C 110 192 Arsenal St WB-TR 0.55 14.0 B 116 179 0.69 18.9 B 147 233 Arsenal St at Talcott Ave NB -LT 0.31 31.6 C 23 61 0.55 37.9 D 47 111 Talcott Ave Talcott Ave NB-R 0.27 5.7 A 0 18 0.41 12.7 B 0 46 Driveway SIB -LTR 0.03 0.1 A 0 0 0.04 19.2 B 1 15 Total 0.69 18.2 B 0.69 22.7 C Arsenal St EB-LT 0.65 19.4 B 114 173 0.58 18.3 B 108 167 Arsenal St at Arsenal St WB-TR 0.68 19.9 B 121 184 0.68 20.3 C 136 208 Arsenal CUArsenal Arsenal Ct NB-LTR 0.20 18.2 B 5 32 0.12 1.7 A 0 3 Way Arsenal Way SB-L 0.18 29.5 C 10 36 0.30 32.2 C 19 56 Arsenal Way SB-TR 0.10 0.4 A 0 0 0.16 0.6 A 0 0 Total 0.68 19.1 B 0.68 18.4 B Arsenal St EB-L 0.47 44.0 D 55 125 0.42 44.7 D 44 105 Arsenal St EB-T 0.45 26.5 C 103 171 0.53 27.8 C 125 203 Arsenal St EB-R 0.25 5.8 A 0 42 0.17 5.9 A 0 32 Arsenal St at Arsenal St WB-L 0.33 44.0 D 31 82 0.38 44.7 D 38 94 Arsenal Mall/Watertown Arsenal St WB-TR 0.68 32.5 C 156 253 0.70 31.9 C 175 276 Mall Arsenal Mall NB -LT 0.56 48.2 D 54 125 0.52 46.7 D 51 116 Arsenal Mall NB-R 0.11 6.8 A 0 28 0.13 6.4 A 0 30 Watertown MI SB-LTR 0.18 17.7 B 5 40 0.14 15.5 B 2 31 Total 0.68 29.4 C 0.70 30.0 C Arsenal St EB-L 0.56 43.0 D 59 130 0.57 43.1 D 61 134 Arsenal St EB-T 0.30 16.2 B 71 115 0.32 15.7 B 76 122 Arsenal St WB-T 0.66 33.5 C 110 184 0.68 33.2 C 118 194 Arsenal St at Watertown Mall Arsenal St WB-R 0.26 2.2 A 0 16 0.20 2.2 A 0 14 Watertown MI SB-L 0.58 39.1 D 78 161 0.55 39.2 D 69 144 Watertown MI SB-R 0.55 10.9 B 0 63 0.56 10.8 B 0 64 Total 0.66 23.6 C 0.68 23.9 C 1SB = Southbound, EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; 2Volume to Capacity Ratio; 3Vehicle Delay, measured in seconds; ^Level Of Service; 550th Percentile Queue (in feet); 695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile volume exceeds capacity, queue may be longer; - = Volume exceeds capacity, queue is theoretically infinite -28- Table 713 - LOS Summary No -Build Saturday LOCATION DIRECTION / MOVEMENT WEEKDAY MIDDAY PEAK HOUR V/C2 DELAY3 LOS° 50th Q5 95th Q5 Arsenal St EB-LT 0.64 13.7 B 58 261 Arsenal St. at Arsenal St WB-TR 0.57 16.6 B 80 247 School St School St SB-LR 0.59 18.7 B 44 130 Total 0.64 15.9 B Arsenal St EB-LT 0.76 24.9 C 172 275 Arsenal St WB-TR 0.48 11.8 B 106 161 Arsenal St at Talcott Ave NB -LT 0.28 36.0 D 22 63 Talcott Ave Talcott Ave NB-R 0.42 13.1 B 0 48 Driveway SIB -LTR 0.04 0.3 A 0 0 Total 0.76 18.9 B Arsenal St EB-LT 0.66 16.7 B 95 213 Arsenal St Arsenal St WB-TR 0.60 15.8 B 83 189 at Arsenal Arsenal Ct NB-LTR 0.15 19.3 B 4 31 Ct/Arsenal Arsenal Way SB-L 0.12 28.5 C 7 34 Way Arsenal Way SB-TR 0.02 0.1 A 0 0 Total 0.66 16.4 B Arsenal St EB-L 0.43 46.8 D 48 113 Arsenal St EB-T 0.66 32.5 C 164 266 Arsenal St EB-R 0.23 6.6 A 0 43 Arsenal St at Arsenal St WB-L 0.38 46.8 D 39 87 Arsenal Mall/Watertown Arsenal St WB-TR 0.69 34.1 C 170 276 Mall Arsenal Mall NB -LT 0.62 47.7 D 77 162 Arsenal Mall NB-R 0.11 6.1 A 0 27 Watertown MI SB-LTR 0.10 14.3 B 1 26 Total 0.69 32.6 C Arsenal St EB-L 0.78 53.7 D 126 299 Arsenal St EB-T 0.31 16.3 B 84 136 Arsenal St WB-T 0.69 37.0 D 126 194 Arsenal St at Watertown Mall Arsenal St WB-R 0.22 2.1 A 0 15 Watertown MI SB-L 0.65 43.1 D 99 182 Watertown MI SB-R 0.49 9.0 A 0 66 Total 1 0.78 1 27.9 C 'SB = Southbound, EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; VVouume to Capacity Ratio; 3Vehicle Delay, measured in seconds; °Level Of Service; 550th Percentile Queue (in feet); 695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile volume exceeds capacity, queue may be longer; - = Volume exceeds capacity, queue is theoretical) infinite -29- 7.5 Traffic Signal Warrant Nitsch engineering performed the Signal Warrant Analysis for Arsenal Street at Site Driveway intersection. We performed the warrants based on the procedures outlined in the Manual on Uniform Traffic Control Devices2 (MUTCD), 2009 edition. The MUTCD indicates nine (9) separate conditions under which a traffic signal warrant can be met, and they are shown below. 1. Warrant 1: Eight -Hour Vehicular Volume; 2. Warrant 2: Four -Hour Vehicular Volume; 3. Warrant 3: Peak Hour; 4. Warrant 4: Pedestrian Volume; 5. Warrant 5: School Crossing; 6. Warrant 6: Coordinated Signal System; 7. Warrant 7: Crash Experience; 8. Warrant 8: Roadway Network; and 9. Warrant 9: Intersection Near A Grade Crossing. A traffic signal should only be installed if one or more of the warrants are met, and if it is determined through analysis and engineering judgment that the installation of a traffic signal would improve the overall safety and/or traffic operations at the intersection. Given the criteria set forth in the MUTCD and the assumptions above, presently none of the warrants are met. We believe that the proposed Facility will have a minimal to negligible impact on traffic operations at the study intersections. The Traffic Signal Warrant Analysis is included in Appendix A-5. 2 Manual on Uniform Traffic Control Devices for Streets and Highways, 2009 Edition, Federal Highway Administration -30- 7.6 2026 Build Capacity Analysis Nitsch Engineering analyzed the 2026 Build Conditions traffic operations at the study intersections for the proposed facility. The 2026 Build Conditions represents the 2026 No -Build Conditions traffic volumes with the proposed volumes. The Level of Service Summary is shown in Tables 8A and 8B. The analysis worksheets are provided in Appendix A-4. Table 8A - Level of Service Summary - 2026 Build Conditions LOCATION DIRECTION / MOVEMENT WEEKDAY MIDDAY PEAK HOUR WEEKDAY EVENING PEAK HOUR V/CZ DELAY3 LOS° 50Oth 9O5th V/CZ DELAY3 LOS° 50Oth 9O5th Arsenal St EB-LT 0.55 11.9 B 45 191 0.65 14.3 B 58 234 Arsenal St. at Arsenal St WB-TR 0.63 16.8 B 80 252 0.65 17.5 B 95 297 School St School St SB-LR 0.58 16.6 B 37 124 0.65 21.5 C 68 178 Total 0.63 15.0 B 0.65 17.5 B Arsenal St EB-LT 0.29 0.2 A 1 0.22 0.3 A 1 Arsenal St at Arsenal St WB-TR 0.31 0.0 A 0 0.34 0.0 A 0 Site Driveway Driveway SB - L 0.04 20.3 C 3 0.06 19.6 C 5 Driveway SB - R 0.01 8.9 A 1 0.02 9.1 A 1 Arsenal St EB-LT 0.69 23.7 C 124 193 0.68 27.2 C 114 198 Arsenal St WB-TR 0.56 14.0 B 118 182 0.70 19.0 B 151 239 Arsenal St at Talcott Ave NB -LT 0.31 31.8 C 23 62 0.55 38.4 D 47 113 Talcott Ave Talcott Ave NB-R 0.27 5.8 A 0 18 0.41 12.8 B 0 46 Driveway SB -LTR 0.03 0.1 A 0 0 0.04 19.4 B 1 15 Total 0.69 18.3 B 0.70 22.8 C Arsenal St EB-LT 0.65 19.4 B 116 176 0.58 18.3 B 112 173 Arsenal St at Arsenal St WB-TR 0.68 19.9 B 124 187 0.69 20.3 C 141 213 Arsenal Arsenal Ct NB-LTR 0.20 18.4 B 5 32 0.12 1.7 A 0 3 Ct/Arsenal Way Arsenal Way SB-L 0.18 29.7 C 10 36 0.30 32.6 C 20 56 Arsenal Way SB-TR 0.10 0.4 A 0 0 0.16 0.6 A 0 0 Total 0.68 19.1 B 0.69 18.5 B Arsenal St EB-L 0.47 44.3 D 56 126 0.42 45.1 D 45 106 Arsenal St EB-T 0.46 26.4 C 106 175 0.53 27.7 C 130 209 Arsenal St EB-R 0.25 5.8 A 0 41 0.16 5.8 A 0 31 Arsenal St at Arsenal St WB-L 0.34 44.5 D 32 83 0.38 45.1 D 38 94 Arsenal Mall/Watertown Arsenal St WB-TR 0.68 32.5 C 161 259 0.70 31.8 C 180 283 Mall Arsenal Mall NB -LT 0.57 48.7 D 55 126 0.53 47.4 D 51 117 Arsenal Mall NB-R 0.11 6.8 A 0 28 0.13 6.5 A 0 30 Watertown MI SB-LTR 0.18 17.7 B 6 40 0.14 15.6 B 2 31 Total 0.68 29.5 C 0.70 30.0 C -31- Arsenal St EB-L 0.56 43.3 D 59 131 0.57 43.6 D 62 135 Arsenal St EB-T 0.31 16.2 B 72 118 0.33 15.8 B 79 126 Arsenal St WB-T 0.66 33.6 C 113 189 0.69 33.4 C 123 201 Arsenal St at Arsenal St WB-R Watertown Mall 0.26 2.2 A 0 16 0.20 2.2 A 0 14 Watertown MI SB-L 0.58 39.3 D 79 161 0.55 39.4 D 69 145 Watertown MI SB-R 0.55 11.0 B 0 63 0.56 10.9 B 0 64 Total 0.66 23.8 C 0.69 24.0 C EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; 2Volume to Capacity Ratio; 3Vehicle Delay, E'SBthbound, in seconds;°Level Of Service; 550th Percentile Queue (in feet);695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile ceeds capacity, queue may be longer; - = Volume exceeds capacity, queue is theoretically infinite Table 813 - LOS Summary Build Saturdav LOCATION DIRECTION / MOVEMENT WEEKDAY MIDDAY PEAK HOUR V/CZ DELAY3 LOS° 50th QS 95th6 Q Arsenal St EB-LT 0.65 14.1 B 60 273 Arsenal St. at Arsenal St WB-TR 0.58 16.7 B 83 256 School St School St SB-LR 0.60 19.5 B 48 136 Total 0.65 16.3 B Arsenal St EB-LT 0.34 0.2 A 1 Arsenal St at Arsenal St WB-TR 0.30 0.0 A 0 Site Driveway Driveway SB - L 0.08 19.8 C 6 Driveway SB - R 0.02 8.9 A 1 Arsenal St EB-LT 0.76 24.8 C 178 283 Arsenal St WB-TR 0.49 11.8 B 110 165 Arsenal St at Talcott Ave NB -LT 0.28 36.5 D 22 63 Talcott Ave Talcott Ave NB-R 0.42 13.2 B 0 48 Driveway SB -LTR 0.04 0.3 A 0 0 Total 0.76 18.8 B Arsenal St EB-LT 0.65 16.5 B 97 220 Arsenal St Arsenal St WB-TR 0.60 15.7 B 85 194 at Arsenal Arsenal Ct NB-LTR 0.15 19.5 B 4 31 Ct/Arsenal Arsenal Way SB-L 0.12 28.8 C 8 35 Way Arsenal Way SB-TR 0.02 0.1 A 0 0 Total 0.65 16.3 B Arsenal St EB-L 0.44 47.3 D 48 114 Arsenal St EB-T 0.67 32.7 C 171 275 Arsenal St EB-R 0.23 6.5 A 0 42 Arsenal St at Arsenal St WB-L 0.38 47.2 D 39 98 Arsenal Mall/Watertown Arsenal St WB-TR 0.70 34.2 C 176 284 Mall Arsenal Mall NB -LT 0.62 48.1 D 77 164 Arsenal Mall NB-R 0.11 6.2 A 0 28 Watertown MI SB-LTR 0.10 14.3 B 1 27 Total 0.70 32.8 C -32- Arsenal St EB-L 0.79 54.8 D 127 303 Arsenal St EB-T 0.33 16.4 B 88 142 Arsenal St WB-T 0.70 37.2 D 133 202 Arsenal St at Arsenal St WB-R Watertown Mall 0.21 2.1 A 0 15 Watertown MI SB-L 0.65 43.4 D 100 183 Watertown MI SB-R 0.49 9.1 A 0 66 Total 0.79 28.1 C SB = Southbound, EB = Eastbound, WB = Westbound, L = Left -turn, T = Through movement, R = Right -turn; ZVolume to Capacity Ratio; 3Vehicle Delay, measured in seconds; °Level Of Service; 550th Percentile Queue (in feet); 695th Percentile Queue (in feet) based upon 22 feet per vehicle; # = 95th percentile volume exceeds capacity, queue may be longer; — = Volume exceeds capacity, queue is theoretical) infinite -33- 8 SIGHT DISTANCE Stopping Sight Distance (SSD) is the length of the roadway ahead that is visible to the driver and should be sufficiently long to enable a vehicle traveling at or near the design speed to stop before reaching a stationary object in its path. Stopping sight distance is the sum of the distance traversed by the vehicle from the instant the driver sights an object necessitating a stop to the instant the brakes are applied and the distance needed to stop the vehicle from the instant brake application begins. Intersection Sight Distance (ISD) is the length of the leg of the departure sight triangle along the major road in both directions for a vehicle stopped on the minor road waiting to depart. The critical departure sight triangles for the new facility driveways are for traffic approaching from either the left or right for left turns from the driveways onto Arsenal Street. The methods for determining the sight distances needed by drivers approaching intersections are based on the same principles as stopping sight distance, but incorporate modified assumptions based on observed driver behavior at intersections. The SSD and ISD values associated with a given design speed are shown in Table 9. The site distance evaluations for the intersection are shown in Table 10. Table 9 - Sight Distance Criteria DESIGN SPEED DESIGN STOPPING SIGHT DISTANCE VALUE' (SSD) RECOMMENDED INTERSECTION SIGHT DISTANCE VALUE2 (ISD) (MPH) (FT) (FT) 15 80 170 20 115 225 25 155 280 30 200 335 35 250 390 40 305 445 45 360 500 50 425 555 55 495 610 60 570 665 65 645 720 70 730 775 75 820 830 80 1 910 885 Source: A Policy on Geometric Design of Highways and Streets, AASHTO, Washington DC (2011) 'Design value based on a grade of less than 3%, a brake reaction distance predicted on a time of 2.5 seconds and a deceleration rate of 11.2 ft/s2 2Recommended value based on Case B1 - a stopped passenger car to turn left onto a two-lane highway with no median and grades 3% or less -34- We used the posted speed limit of 30 MPH for Arsenal Street for the sight distance analysis. As shown in Table 10 both SSD and ISD values at the strip mall driveway exceed the minimum values. Table 10 - Proposed Sight Distance Evaluation POSTED MINIMUM MEASURED INTERSECTION SPEED (FEET)1,2 (FEET) OBSTRUCTION (MPH) Arsenal Street at the Site Driveway Stopping Sight Distance: Arsenal Street Eastbound 30 200 >400 Arsenal Street Westbound 30 200 >400 Intersection Sight Distance: Looking to the right from Driveway 30 335 >400 Looking to the left from Driveway 30 335 >440 Source: A Policy on Geometric Design of Highways and Streets, AASHTO, Washington DC (2011) Table 3-1. Stopping Sight Distance on Level Roadways 2 Table 9-6. Design Intersection Sight Distance - Case B1, Left Turn from Stop -35- 9 CONCLUSIONS AND MTIGATION 9.1 Conclusions Nitsch Engineering has been retained by Keltic Green, Inc. (KGI) to prepare a qualitative assessment of safety, traffic circulation, and traffic access/egress associated with the proposed recreational marijuana retail facility located at 390 Arsenal Street in Watertown, Massachusetts. We examined the build condition with respect to the projected employees and customers at the proposed Facility in Watertown. This would result a slight increase in traffic volumes within the study area during the weekday midday peak, weekday evening peak, and Saturday midday peak hours totaling approximately 40 additional trips (21 entering and 19 exiting) during the weekday midday peak hour, approximately 57 additional trips (28 entering and 29 exiting) during the weekday evening peak, and approximately 69 additional trips (34 entering and 35 exiting) during the Saturday midday. Based on the capacity analysis for the proposed facility, traffic operations at all the intersections will remain generally unchanged. It is expected that the traffic volumes from the proposed Facility will have a minimal to negligible impact on traffic operations at the study intersections. 9.2 Mitigation As noted above, project related traffic impacts are nominal, and the roadway system has adequate capacity to readily absorb the anticipated project -related traffic increases. Consequently, no traffic mitigation measures appear warranted. Similarly, the parking inventory at the site indicates that there is adequate parking capacity to accommodate project -related customer parking demands. -36- Tv.JtT KELTIC SECURITY PLAN STATEMENT FROM KELTIC GREEN INC.'S CHIEF OF SECURITY: My name is Mike Allen and I am the Chief of Security for Keltic Green, Inc. ("Keltic"). I have provided security consulting services for the past 2 1/2 years to marijuana establishments in both New Hampshire and Massachusetts since retiring as Police Chief from the City of Rochester, NH Police Department in December of 2016. I am submitting the following proposed security plan (the "Plan) on behalf of Keltic for your review. The Plan was developed in accordance with 935 CMR 500.000 Cannabis Control Commission regulations, Watertown Local Ordinances, security industry best practices using the principles of Crime Prevention Through Environmental Design (CPTED), and my 30+ years of law enforcement, military and security experience. Our proposal is to locate a Marijuana Retail Establishment at 390 Arsenal Street, Watertown, MA. I am hopeful that the Plan outlined below meets all the requirements of your office and am confident Keltic will have a minimal impact on public safety services in the City of Watertown. On behalf of Keltic, I look forward to working cooperatively with the Watertown Police Department to incorporate suggestions and feedback into the Plan to ensure the safest experience for employees, customers, and the City. Respectfully Submitted, Michael J. Allen Chief of Security Keltic Green Inc. KELTIC GREEN, INC. - SECURITY PLAN HOURS OF OPERATION (Subject to Approval by the Special Permit Granting Authority): Monday: 8:00 a.m. to 10:00 p.m. Tuesday: 8:00 a.m. to 10:00 p.m. Wednesday: 8:00 a.m. to 10:00 p.m. Thursday: 8:00 a.m. to 11:00 p.m. Friday: 8:00 a.m. to 11:00 p.m. Saturday: 8:00 a.m. to 11:00 p.m. Sunday: 9:00 a.m. to 10:00 p.m. AFTER-HOURS CONTACT INFORMATION: Justin Smith, CEO - 617 257 7799 SECURITY LEVELS: The site plan review of the facility has been reviewed physically and electronically for the purposes of providing, designing, and commissioning a new Electronic Security Access Control System that includes Perimeter Monitoring, Panic Alarms, Motion Detectors, and Intrusion Detection System. A Video Management System (VMS), has been selected to monitor, record, and archive video on a Network Video Recorder (NVR). Astronaut Security is the preferred security integrator for Keltic and assisted in the design and engineering of the proposed security system. The facility was reviewed and delineated into three levels of security access to provide the highest level of security which meets or exceeds the standards of the Cannabis Control Commission and the City of Watertown. Employee access to different levels is based solely on need, and their access credentials are programmed accordingly. Level 1 The facility will be open to the general public for the recreational sale of product. The general public, employees, visitors, and vendors will be required to enter the facility through one entrance which is monitored by CCTV cameras as outlined in the security drawings. All perspective customers will "check in" at the lobby/vestibule area with valid photo identification for KELTIC GREEN, INC. - SECURITY PLAN presentation to the receptionist. The receptionist will process the identification through an electronic ID verification system for the purpose of validation. A panic alarm is also located at the receptionist counter. Customers must present a valid form of identification containing a photograph and date of birth. Acceptable forms of ID include a driver's license, government -issued ID card, military identification card, or a passport. In the event dispensary agents observe suspicious behavior by a customer while at the dispensary, the Dispensary Manager and/or the Director of Security will be notified and no sale will be issued. Immediate notification to the Watertown Police Department shall be made if agents observe behavior indicating suspected diversion. Examples of such behavior include: Customer appears to be under the influence of drugs or alcohol. Customer makes threats. Customer is suspected of attempting to purchase product for anyone that appears to be under the age of 21. Dispensary agents will refuse to dispense to a customer if there is concern the customer or public would be placed at risk. All employees will have company issued photo ID badges, with specific levels of access based on their job description and responsibilities. A "card reader" will control employee access to permissible facility levels. Employees are subjected to a vetting process before employment. No cell phones, cameras or other recording devices are allowed to be used within the facility to take video or photographs. Cell phones will only be allowed for communications purposes. Keltic staff will notify any customer who appears to be taking photographs or video and to cease such behaviors for security reasons. This is a "No Smoking" facility, to include any/all type of electronic inhaling devices. Signage will be posted in the vestibule indicating these restrictions. Level 2 To enter this designated security level, everyone is required to enter through a card access - controlled door. This level requires ALL EMPLOYEES to be displaying a company PHOTO ID Badge and all Vendors/ Contractors to be displaying an ID Badge. All Vendors/Contractors are required to be escorted by a dispensary agent. All outside vendors, contractors, and customers shall always be escorted by a dispensary agent authorized to enter the limited access Level #2 areas to view the product on display. They will be greeted at the door of the lobby, once their valid photo identification has been approved by KELTIC GREEN, INC. - SECURITY PLAN the receptionist. All contractors and vendors will be required to sign in and out, wear a visitor/vendor ID Badge, and always escorted by their designated dispensary agent. This area is open to the general public but limits the access and free movement to other sections of the facility. Members of the general public will be escorted by a Dispensary Agent in order to maintain a controlled environment. This entire area is monitored by CCTV cameras, and motion detectors as outlined in the security drawings. Should note at the "Point of Sale" area (POS) there are Panic Alarms for immediate Emergency Notification to the Watertown Police Department. Wireless panic buttons will also be carried by the on -duty manager and on -site security officers. Level 3 To enter this designated level of access, all person(s) are required to present a Level #3 company issued photo ID access badge which is pre-programmed for Level #3 access. Level #3 is equipped with dual authentication card readers. This is the highest level of security within the facility and limited to those who need to be in the area based on their job description and responsibilities. By equipping the area with Biometrics/keypad reader, this eliminates the possibility of using another person's ID badge to gain access to this area. The area is monitored by CCTV cameras. Entrance/egress from this area is continuously monitored by the CCTV cameras as well as perimeter alarm contact points on the entrance/egress door if it were opened or breached. The alarm points report direct to the Access Control System as well as to a Central Monitoring Station for emergency notification. There are Motion Detectors covering this area as well as one Panic Alarms as outlined in the security drawings. INTERIOR/EXTERIOR CCTV COVERAGE/ALARMS: The interior of the facility has CCTV coverage with the installation of IP video cameras placed in strategic locations as indicated on the Security Plan Drawings. The cameras will have horizontal angle of view with a minimum of 82 degrees, subject facial recognition for 50 feet, and situation awareness for an extended distance within the designated space. A combination of dome, bullet and fisheye cameras will be used throughout the interior of the facility as outlined on the security drawings. The exterior of the facility will be monitored by IP Video cameras. The cameras will cover the entire perimeter and have a varifocal lens, motion detection and tampering alarm. They are environmental for weather conditions, vandal resistant, with Integral IR illumination. KELTIC GREEN, INC. - SECURITY PLAN The strategic locations indicated on the Security Plan, cover all entrances and egress to/from the facility as well as the parking area. Should note that all the entrance and egress doorways also have contact monitoring points reporting back to the Access Control System. Notification is also forwarded to a Central Monitoring Center. All windows are monitored by Glass Break Monitoring Points" and complimented by Motion Detectors as noted on the Security Plan drawings, with video monitoring inclusive to identify unauthorized entry and/or person(s). There are five (5) doors at the facility which can be used as entrance/egress points. Each door has a "Contact Monitoring Point" which is connected to the Access Control System, with each door having a "fixed CCTV" monitoring all entry and exit from the facility. SECURITY ACCESS CONTROLLED SYSTEM LOCATION: The Security Access Controlled System and the Video Management System will be in the office area noted as "IDF" (Intermediate Distribution Frame) room. This room is protected by authorized "Card Access" with limited access and level of security as determined by the Chief of Security. The system operates on the proprietary internet and has cellular back-up in case of emergency. In the event of a power failure the system has a UPS backup sufficient to keep the equipment in this room operational. The system has the ability to record all authorized entries as well as denied entries and intrusion alarms. An audit trail of the system identifies the date, time, door, and person who is granted or denied access. The failure identification system shall notify a Central Monitoring Station, of all panic alarms, perimeter alarms and motion detector alarms, who shall notify a designated Keltic employee within five minutes after a failure either by telephone, e-mail or text message. The Access Control System is password protected and has internal event archiving which is saved indefinitely. The Video Management System will store video for a minimum of 90 days. All photos are date and time stamped, can be printed, or exported still images via.jpg.bmp, and .gif. Cameras have been placed in all areas that contain marijuana, at all entry/exit points and the parking areas. The cameras will be directed to monitor all safes, vaults, and areas where marijuana is processed, prepared, stored, handled, dispensed or transported. The cameras will capture a clear and certain identification of any person(s) entering or exiting the Dispensary. The failure identification system shall notify a Central Monitoring Station of any failure in the video surveillance system. KELTIC GREEN, INC. - SECURITY PLAN LIGHTING: The outside perimeter of the facility along with any parking areas will be sufficiently lit to facilitate video surveillance and safety for staff and visitors. SECURITY SYSTEM MONITORING BY THE POLICE DEPARTMENT: If requested, the Watertown Police Department will have the ability to access the Video Management System to monitor any activities inside or outside of the facility in real time. TRANSPORTATION PROCEDURES: Our transportation procedures will meet or exceed all Cannabis Control Commission regulatory requirements. Agents transporting marijuana or marijuana products to Keltic will: • Weigh, inventory, and account for on video all marijuana to be transported prior to it leaving the origination location; • Re -weigh, re -inventory, and account for on video all marijuana transported, within eight hours after arrival at the Watertown Dispensary. • Document and report any unusual discrepancy in weight or inventory to the CCC and Watertown Police Department within twenty-four (24) hours; • Complete a shipping manifest in a form and manner determined by the CCC, for retention by the origination location, and carry a copy of said manifest with the products being transported; and • Securely transmit a copy of the manifest to the Watertown Dispensary prior to transport. During transport, at least one (1) courier will remain with the vehicle at all times when the vehicle contains marijuana. Transportation shall be made in unmarked delivery vehicles at the rear door of the facility using the designated access route during daylight hours. Onsite security will assist with maintaining visual surveillance of the area during transport. For transportation: • Routes are randomized. • Times will not set up on a weekly timed schedule, and for security reasons, the days of the week and times are randomized to thwart any possibility of robbery. KELTIC GREEN, INC. - SECURITY PLAN • Prior to arrival of the transportation vehicle to the facility, on- site security will conduct a visual sweep of the rear of the building to ensure there are no suspicious individuals/vehicles loitering in that area. Immediate notification to the Watertown Police Department shall be made if any suspicious person or vehicle is observed. ONSITE SECURITY PERSONNEL: The facility will be staffed with a minimum of (1) onsite uniformed security agent during all hours of operation. If requested by the Watertown Police Department, additional security may include a local police detail. NO CONSUMPTION OF MARIJUANA: Consumption of marijuana products inside and outside of the facility is strictly prohibited by Keltic's policies and by Massachusetts law. Appropriate signage shall be placed inside of the Dispensary lobby and exit areas notifying patrons of this. Onsite Security personnel shall patrol the facility exterior and parking lot, to include the exterior parking area, during all hours of operation to ensure compliance. Any patron observed violating this policy shall be requested to cease and leave the property. The Watertown Police Department shall be immediately notified whenever any unlawful consumption or suspected diversion is occurring on or around the property. Identified violators shall be added to a "Banned Customer List" through our electronic ID verification system. CROWD CONTROL/TRAFFIC MEASURES: Keltic shall work closely with the Watertown Police Department to develop a plan for crowd/traffic management upon opening and for as long as necessary thereafter. A Watertown Police detail will be hired as necessary to assist with monitoring any potential "queuing" or loitering outside of the facility along with assisting with parking/traffic control. It is important to note that the dispensary vestibule has been expanded to accommodate more customers inside and minimize any line queuing outside the dispensary. Keltic will also implement an appointment only system upon opening along with offering a pre-order/pickup system to assist with reducing wait times and expediting customer sales. PREVENTION OF DIVERSION: Keltic staff members shall be trained to prevent loitering and ensure that only individuals engaging in activity expressly permitted by regulations are allowed to remain on the premises. Staff KELTIC GREEN, INC. - SECURITY PLAN members shall contact the police if they observe suspicious individuals in person or on camera loitering outside the premises. Examples would include; someone who appears to be under the influence of alcohol or drugs; a group of younger people approaching the area of the premises, but only one person enters to purchase marijuana. Such observations could indicate the potential diversion of marijuana to persons less than 21 years of age. If such observations are made, staff members shall notify the dispensary manager, police officer on detail or call the business line of the police department to investigate. VISIBILITY OF MARIJUANA PRODUCTS: No marijuana or marijuana products will be visible from outside of the facility. INCIDENT REPORTING: Green will immediately notify law enforcement authorities of any security breach including, but not limited to, discovery of discrepancies identified during inventory, diversion or loss of marijuana products, any loss or unauthorized alteration of records related to marijuana, suspicious actions within the marijuana establishment, failure of an alarm system, activation of an alarm system, or any criminal acts. Keltic Green will provide written notice to the Commission within ten calendar days of any incident that occurs on the premises. Keltic will maintain records and documentation of any security incident for at least one year. KELTIC GREEN, INC. - SECURITY PLAN MS MS OFFICE OFFICE IDF INVENTORY STAFF AREA 16 15 18 1_8 O 105 SF 105 SF 55 SF DC 133 SF DC- 223 SF pp O PIN E HUA PIN MS STAFF HALL 3 O- ■ STAFF TOILET � —$ SF I�,T■ ul 0 51 SF LI RECEPTION I ICM 45 SF HUA DISPENSARY 11 MS 1096 SF N# SECURE GOB VESTIBULE MS 243 SF O �EXI' 35 35 1 E1,RY ExF 2 1 y I POINTS OF SALE 12 350 SF LEGEND: HUA HOLD UP ALARM BUTTON DC DOOR CONTACT GB GLASS BREAK DETECTOR KP KEYPAD STATION MS MOTION SENSOR ICM INTERCOM STATION SYSTEM MASTER IC INTERCOM STATION GENERAL STORAGE I SECURE DIRECTION OF TRAVEL ELECTRONIC ACCESS CONTROL 13A SF 1 PIN SYSTEMS DOOR AC 'PIN"- DUAL FACTOR CARD READER DC SECURE DIRECTION OF TRAVEL AC ELECTRONIC ACCESS CONTROL PIN > SYSTEMS DOOR SECUR-ONES KP SECURE M C RECEIVING -4 u 340 SF MS F fY. DC _ AS i nOi AU i SECURITY TECHNOLOGIES eNrav W W W.ASTRONAUTSECURITY.COM 3 888-55-ASTRO itl� 1° KELTIC ARSENALST. 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WATERTOWN, MA sm wn VIDEO SURVEILLANCE PLAN OS/08/19 R�.ao TV.Artr KELTIC BUSINESS PLAN MESSAGE FROM THE CEO: Keltic Green, Inc. is pleased and grateful for the opportunity to propose an Adult -Use Retail Marijuana Establishment in the Town of Watertown, Massachusetts. Keltic has selected the Town of Watertown, and specifically this site, as a key market center for its Massachusetts campaign to open and operate three licensed adult -use retail marijuana establishments. Keltic is excited to connect with the community, public officials, and the Town of Watertown. The plan to transform and revitalize the current property is just the beginning. Keltic's goal is to create a business which will bring significant revenue to the Town of Watertown, create diverse employment opportunities with preference to Watertown residents and perfect the model for operating a state of the art first class adult -use retail marijuana establishment. Sincerely, Justin Smith CEO, Keltic Green Inc. 1 KELTIC GREEN INC. - BUSINESS PLAN EXECUTIVE SUMMARY MISSION STATEMENT: Keltic's mission is to create a safe and clean community environment to provide consistent, high quality cannabis and cannabis products to consumers who are 21 years of age or older at its proposed adult -use retail marijuana establishment (the "Marijuana Establishment") in the Town of Watertown, Massachusetts (the "Town" or "Watertown"). Keltic believes people, product, and process make any business thrive. Our impressive location coupled with our state-of-the-art user experience and customer service will be in a class of its own. Our inventory will be diverse and comprised of the highest quality cannabis and cannabis infused products available in Massachusetts. Our packaging will be subtle yet attractive, informative, user friendly, and recyclable. As a result, Keltic customers will feel the difference when they enter our location. With these key elements in place, Keltic will ensure sustainable business growth for years to come and prove to be an exemplary business partner for the Town of Watertown. Keltic is committed to incorporating its core values of customer service and care, hospitality, honesty, integrity and community outreach in all aspects of its business operations, while providing Keltic's customers with the highest quality products available in the state. LICENSE TYPE' Keltic is applying for a Certificate of Registration from the Massachusetts Cannabis Control Commission (the "Commission") to operate as an Adult -Use Retail Marijuana Establishment in Watertown. WHAT DRIVES US' Keltic's goals include: 1. Serving customers 21 years of age or older with a wide variety of high quality, consistent, laboratory -tested cannabis and derivatives; 2. Assisting Watertown and neighboring communities in offsetting the impact of Keltic's operations; 3. Hiring employees and contractors from Watertown and neighboring communities; 4. Hiring employees and contractors from communities that have been disproportionally impacted by the war on drugs; 5. Having a diverse and socially representative pool of employees; 6. Empowering the next generation of entrepreneurs and leaders through hiring, training and teaching; 7. Running an environmentally friendly Marijuana Establishment in the Commonwealth of Massachusetts through the use of efficient cultivation methods; and utilizing recyclable packaging; 8. Creating branded marijuana products that are safe, effective, consistent and high quality; 1 KELTic GREEN INC. - BUSINESS PLAN and 9. Creating a brand that goes beyond cannabis sales. Our company has a vision to make Keltic a household name. Its location, products, and staff will ensure its success and long-term growth. Keltic is poised to capture this market opportunity. 2 KELTic GREEN INC. - BUSINESS PLAN EXECUTIVE TEAM GENERAL: Keltic has put together an impressive team to implement the operations of the Marijuana Establishment and intends to create twenty to twenty-five full-time staff positions within the first three years of operation. Members of Keltic's executive management team have spent the last eighteen months preparing, training, and learning all facets of the retail marijuana industry. Keltic's team is committed to continuing their education and training on an ongoing basis to ensure success. No individual on the Keltic team is a controlling person with more than three licenses in any class of license. Justin William Smith, Founder/Chief Executive Officer (CEO): Keltic Green, Inc. was established in 2018 by Justin Smith, following a successful fifteen -year career in the real estate sales and development industry. Justin is excited to apply those skills to the emerging cannabis market in Massachusetts. Justin is determined to develop Keltic into a first- class high -end company. Justin is a Boston area native, and a graduate of the Bromfield School in Harvard, Massachusetts. Justin went on to earn a bachelor's degree in business and entrepreneurship from the Sawyer School of Management at Suffolk University in Boston, Massachusetts. Justin was aware from a young age that his path to success would be one cleared by him. During his four years at Suffolk University, Justin consolidated his full-time class schedule into two days a week, leaving the other days reserved for work. Justin learned how to manage his time effectively and maximize his potential, and the potential of others. Justin has vast experience in buying, developing and selling real estate. Justin possesses the skills and vision to realize an opportunity and effectively create a team to implement business strategies which will ensure success. Through Justin's dynamic approach to business, he has honed skills in personnel management, project planning, market forecasting and financial management. Justin has been responsible for locating key investments and identifying their potential. He uses his negotiating and managerial skills to effectively procure lucrative real estate transactions. These development opportunities are then developed and sold to an end user. Justin also has direct sales experience in retail sales. In addition, through the ownership and management of several companies, Justin has gained the experience to build and manage teams, and to lead them in executing a common vision together. Tyler O'Hazo, Chief Oueratim Officer (COO): Tyler O'Hazo has a combined twenty-one years of experience in real estate appraisal company management and sales. A University of Connecticut graduate, Tyler earned a Bachelor of Arts in Psychology. Considering the nature of his degree and his intrinsic desire to collaborate with people, Tyler pursued a career as a licensed residential real estate appraiser. He later advanced to a certified residential real estate appraiser where he earned the credentials to sponsor, train, and KELTic GREEN INC. - BUSINESS PLAN manage a large staff of other appraisers. A lifelong resident of Litchfield County, Tyler is an expert in the analysis and valuation of antique, equestrian, and water influence as well as architecturally significant homes from within the hills of western Connecticut, one of the most complex real estate markets on the eastern seaboard. With previous experience assisting clientele in appraisal projects designed for financial reporting, probate, tax assessment appeal, land donation, consulting, municipal data collection, and complex litigation, Tyler has expanded his real estate services to include the representation of buyers and sellers with a direct approach that is balanced with patience, integrity and enthusiasm. He has earned recognition as a member of the appraisal roster for the Federal Housing Authority as well as the Department of Housing and Urban Development. Tyler is also honored to assist members of the Armed Forces through his role as designated appraiser for the Department of Veterans Affairs. Following his twenty-one years of experience in the valuation of a wide variety of property types, and as the previous managing partner of O'Hazo Appraisal Services, LLC, Tyler transitioned to his current role in real estate sales at Sotheby's International Realty. Tyler also acts as the niche division director of sales at Mullen Construction, a Connecticut based multi -million -dollar construction company that builds community mausoleums. His current role involves new product roll -out for a brand-new niche division, key account management, customer relationship development, contract negotiations, and budget responsibilities. He also manages supply chains during all phases of construction projects. Tyler has become a leader within this new position, increasing revenues for the niche division by 200% for the year 2018. Tyler also implements marketing strategies for clients, vendors, and suppliers at national and regional conferences. He continues to build new business by securing key clients, increasing product distribution to grow market share, and designing marketing strategies. An active community member, Tyler volunteers for Friends of Futbol International, a nonprofit organization that provides funds and support to assist young soccer players in undeveloped areas all over the world. Additionally, Tyler has been appointed to the Washington Conservation Commission, is a member of the Litchfield County Blues Soccer Team within the SASL Soccer League and a supporting member of numerous local land trust organizations. Kerry Ann O'Hazo, Chief Financial Officer (CFO): Kerry Ann O'Hazo is currently Chief Financial Officer for Mullen Construction, a Connecticut based multi -million -dollar construction company that builds community mausoleums. Prior to her recent promotion to CFO, she managed the office and was director of sales for more than fifteen years for this successful design -build construction firm. Kerry Ann's management duties include maintaining company -wide accounting and reporting functions, tracking annual sales for Connecticut, New York, New Jersey and Massachusetts. She is also responsible for weekly payroll processes for forty employees. Her management of accounts payable/receivable and expense control procedures including bank and account reconciliation, cash receipts, disbursements, billings, invoicing, bank deposits and inventory verification will prove invaluable in her role as CFO at Keltic. KELTic GREEN INC. - BUSINESS PLAN She also serves as Mullen Construction's director of sales and marketing and regularly attends national and regional trade conferences to promote the company. This role allows her to display her expertise in client/customer service since she routinely acts as a liaison between owners, employees, and clients to ensure proper lines of communication critical in securing new contracts and maintaining successful relationships with current and past clients. She works closely with graphic designers to maintain the company website, produce promotional items and create a full marketing program to brand and promote Mullen's business. Prior to working at Mullen Construction, Kerry Ann was the bar manager at restaurant/inn on Lake Waramaug in Warren, CT for two years. She was responsible for running all aspects of the establishment, such as maintaining a clean work environment, and ensuring that product stocking, restaurant set-up, and inventory procedures were followed in order to deliver exceptional customer service. She also reconfigured and implemented a brand-new wine inventory system and spreadsheet for better inventory tracking and greatly improved on the monthly profit and loss liquor costs. Kerry Ann is a Connecticut Notary Public and is qualified to certify documents, administer oaths and affirmations. In her spare time, she volunteers for a non-profit organization called Futbol Friends International which raises money in order to bring the sport of soccer to under privileged children around the world. She also maintains their website and is the social media and communications coordinator for this great organization. Chief Michael J. Allen, Head of Security: Keltic is proud to have Michael Allen as Keltic's Head of Security. Michael is a military veteran and the former police chief of the Rochester, New Hampshire Police Department. Michael has over thirty years of experience in law enforcement and security and three years of experience in the marijuana industry, having set up and managed security protocols in numerous cannabis dispensaries and cultivation sites. Michael has a master's degree in project management and public safety management from Granite State College and is also a graduate of the FBI National Academy. In addition, Michael is a Certified Crime Prevention Through Environmental Design ("CPTED") Instructor. CPTED is defined as a multi -disciplinary approach for reducing crime through urban and environmental design and the management and use of built environments. His expertise in CPTED is just one of many of skillsets Michael will utilize to assist Keltic in achieving its security goals. KELTIC'S TEAM IS FREE FROM DISQUALIFYING CRIMINAL CONVICTIONS: Each member of Keltic's Executive Team, as well as its Head of Security, is free from any disqualifying criminal convictions. As attested to in Keltic's Background Packet, Justin Smith (CEO), Tyler O'Hazo (COO), Kerry Ann O'Hazo (CFO), and Michael Allen (Head of Security) have not been subject to any of the following actions: criminal actions, civil or administrative actions, past or pending legal enforcement, past or pending denial, suspension, or revocation of a KELTic GREEN INC. - BUSINESS PLAN license or registration, past discipline or unresolved complaint, actions against a license to prescribe or distribute, nor have any of the individuals listed above previously attempted to obtain a license or registration to operate a marijuana establishment. KELTic GREEN INC. - BUSINESS PLAN COMPANY DESCRIPTION STRUCTURE' Keltic is a Massachusetts domestic for -profit corporation that is applying for a Certificate of Registration from the Commission to operate a Marijuana Establishment in the Commonwealth. Keltic will file, in a form and manner specified by the Commission, an application for licensure as a Marijuana Establishment consisting of three packets: the Application of Intent; the Background Check; and the Management and Operations Profile. OPF,R A TIONC: Keltic will be located in Watertown and has leased a facility located at 390 Arsenal Street. The facility encompasses a total of 4,200 square feet, with approximately 1,827 square feet dedicated exclusively to retail. Keltic will establish inventory controls and procedures for reviewing comprehensive inventories of marijuana products and finished, stored marijuana, conduct a monthly inventory of marijuana products and finished, stored marijuana, conduct a comprehensive annual inventory at least once every year after the date of the previous comprehensive inventory and promptly transcribe inventories if taken by use of an oral recording device. Keltic will utilize state of the art software to help monitor thousands of products, including the state required Metrc systems, which will be supported by Biotrack. Using both products will allow Keltic to optimize product intake and output. A brief summary of Metrc and Biotrack's capabilities are set forth below. METRC (Marijuana Enforcement Tracking Reporting and Compliance) Metrc has developed and deployed a turnkey system which provides end to end tracking and tracing of marijuana plants and products. This solution was specifically designed for government agencies in charge of legalized marijuana enforcement. Metrc was deployed in December 2013 for the State of Colorado's Marijuana Enforcement Division. To date, the system has registered over 20,000 users and tracked well over 5,000,000 plants and 3,800,000 pack Biotrack Biotrack is the largest and most experienced seed -to -sale cannabis software provider in the industry. This software is currently used in thirty-four states, Washington D.C., Puerto Rico, Jamaica, Canada, Colombia, Australia, and New Zealand. In addition, Biotrack is capable of fulling integrating with Metrc's software to ensure that Keltic can automatically report all our required compliance data to the state's METRC tracking system. KELTic GREEN INC. - BUSINESS PLAN In addition to the foregoing, Keltic also intends to use the following technology to assist in product management and inventory tracking: 1. Dispensary Point of Sale Business Solution: Keltic's point of sale software was designed specifically for Keltic's business operations; 2. Data Driven Customer Relationship Mana ems: Out -of -the -Box Customer Relationship Management ("CRM") tools to reward loyal customers and referrals. Keltic will setup targeted email and text campaigns based on our customer's favorite products, last visit date, purchase history, birthdays and more. Keltic will also create individual customer profiles to help treat all our customers like regulars, keep track of special preferences, purchase history, rewards points and more. 3. DataOwl Technology: Keltic also plans to use DataOwl to assist with online ordering, menu displays and integrated CRM Tools. Keltic intends to use DataOwl, which creates an in-store technology network tapped directly into its cannabis point of sale system to accumulate information from your customers, products, and operations to create unparalleled insights into Keltic's business operations. MARIJUANA TESTING: No marijuana product, including marijuana, will be sold or otherwise marketed that is not tested by Independent Testing Laboratories, except as allowed under 935 CMR 500.000. MAINTAINING RECORDS: Keltic will maintain records which will be available for inspection by the Commission upon request. The records will be maintained in accordance with generally accepted accounting principles and maintained for at least 12 months. INSURANCE: Keltic will obtain and maintain general liability insurance coverage for no less than $1,000,000 per occurrence and $2,000,000 in aggregate, annually, and product liability insurance coverage for no less than $1,000,000 per occurrence and $2,000,000 in aggregate, annually, except as provided in 935 CMR 500.105(10)(b) or otherwise approved by the Commission. The deductible for each policy will be no higher than $5,000 per occurrence. Prior to commencing operations, Keltic will provide proof of having an escrow account in an amount equal to its licensure fee payable to the Marijuana Regulation Fund. The bond will ensure payment of the cost incurred for the destruction of cannabis goods necessitated by a violation of St. 2016, c. 334, as amended by St. 2017, c. 55 or 935 CMR 500.000 or the cessation of operation of Keltic. KELTic GREEN INC. - BUSINESS PLAN ENVIRONMENTAL: Keltic will provide adequate lighting, ventilation, temperature, humidity, space, and equipment, in accordance with applicable provisions of 935 CMR 500.105 and 500.110. All recyclables and waste, including organic waste composed of or containing finished marijuana and marijuana products, will be stored, secured, and managed in accordance with applicable state and local statutes, ordinances, and regulations. Organic material, recyclable material, solid waste, and liquid waste containing marijuana or by-products of marijuana processing will be disposed of in compliance with all applicable state and federal requirements. Keltic Green will demonstrate consideration of the factors for Energy Efficiency and Conservation outlined in 935 CMR 500.105(15) as part of its operating plan and application for licensure. EMPLOYEE COMPLIANCE: Keltic Green and its agents will comply with all local rules, regulations, ordinances, and bylaws. SECURITY' Keltic has contracted with Armstrong Security, who has designed the security systems for Keltic's Watertown retail dispensary. Armstrong will implement, and monitor the systems, and has created a comprehensive security plan to ensure that the facility is a safe and secure environment for employees and the local community. The security plan has been sent to Watertown Chief of Police Michael Lawn for review. Keltic's state-of-the-art security system will consist of perimeter windows, as well as duress, panic, and holdup alarms connected to local law enforcement for efficient notification and response in the event of a security threat. The system will also include a failure notification system that will immediately alert the executive management team if a system failure occurs. A redundant alarm system will be installed to ensure that active alarms remain operational if the primary system is compromised. Interior and exterior HD video surveillance of all areas that contain marijuana, entrances, exits, and parking lots will be operational 24n and available to the Town of Watertown Police Department. These surveillance cameras will remain operational even in the event of a power outage. The exterior of the dispensary and surrounding area will be sufficiently lit, and foliage will be minimized to ensure clear visibility of the area at all times. Only Keltic's registered agents and other authorized visitors (e.g. contractors, vendors) will be allowed access to the facility, and a visitor log will be maintained in perpetuity. All agents and visitors will be required to visibly display an ID badge, and Keltic will maintain a current list of individuals with access. Keltic will have security personnel on -site during business hours. NO ON -SITE CONSUMPTION: KELTic GREEN INC. - BUSINESS PLAN On -site consumption of marijuana by Keltic's employees and visitors will be prohibited. BENEFITS TO THE MUNICIPALITY: Keltic looks forward to working cooperatively with the Town of Watertown to ensure that Keltic operates as a responsible, contributing member of Watertown's business community. Keltic looks forward to establishing a mutually beneficial relationship with Watertown in exchange for permitting it to site and operate in the Town. The Town of Watertown stands to benefit in various ways, including but not limited to the following: 1. Jobs: An Adult -Use Marijuana Retailer will add 20-25 full time jobs, in addition to hiring qualified, local contractors and vendors. 2. Monetary Benefits: A Host Community Agreement with significant monetary payments will provide the Town with additional financial benefits beyond local property taxes. 3. Access to Quality Product: Keltic will provide qualified consumers in the Commonwealth with access to high quality marijuana and marijuana products that are tested for cannabinoid content and contaminants. Keltic has worked to source the highest quality products from one of the leading manufacturer's in Massachusetts. 4. Control: In addition to the Commission, the Watertown Police Department and other municipal departments will have oversight over Keltic's security systems and processes. 5. Responsibility: Keltic's team is comprised of experienced professionals who will be thoroughly background checked and scrutinized by the Commission. 6. Economic Development: Keltic's renovation of the building will revitalize the Town of Watertown and contribute to the overall economic development of the local community. KELTic GREEN INC. - BUSINESS PLAN LOCATION OVERVIEW: Keltic's location for its proposed Marijuana Establishment is located at 390 Arsenal Street (the "Property"). The Vacant Property is an ideal location for a Marijuana Establishment, as the 4,200 sq. ft. building offers ample parking, with minimal traffic impact, and the site's proximity to the highway allows for easy access. The lot and building at the Property are deteriorating and will continue to do so if it remains unused, abandoned, and without a new tenant to redevelop the site. Additionally, due to the long vacancy, there have been numerous incidents of disturbance and public safety issues at the Property. Keltic aims to address these issues by rehabilitating the Property by creating a safe, welcoming, and active business that will help rejuvenate the neighborhood. Keltic has a signed long-term lease on the Property, with the hope of hope of being invited to negotiate a Host Community Agreement with Watertown and becoming a permanent and substantial contributing member of Watertown's already vibrant business community on Arsenal Street. Keltic is committed to making substantial interior and exterior improvements to the Property as seen in the pictures below and the additional pictures included in Exhibit A of the Business Plan. SUPPORT OF MUNICIPALITY: Keltic understands the importance of obtaining the support of its District Councilor for its proposed location. Accordingly, Keltic's Team is prepared to have several upcoming meetings with Public Officials regarding its proposed use of the Property. Keltic is looking forward to sharing its vision for the Property with Town Council and welcomes their input and feedback. Keltic will work cooperatively with Town officials and take any steps necessary to ensure that its site satisfies the purpose and intent of the Town's Zoning Ordinance. ZONING: Keltic Green, Inc. ("Keltic") intends to remain compliant with the local zoning requirements set forth in the Watertown's Cannabis Zoning Ordinance at all times. Keltic's proposed Adult -Use Marijuana Retail Establishment will be located at 390 Arsenal Street in Watertown, which is in the Regional Mixed Use District ("RMUD") Zoning District. Pursuant to the zoning ordinances Section 5.01 set forth in the Town of Watertown's Zoning Ordinance, Adult Use Marijuana Establishments (Section 8.04) are permitted to operate in the RMUD Zoning District after obtaining a special permit from the Town Council. KELTiC GREEN INC. - BUSINESS PLAN Keltic's proposed site complies with 935 CMR 500.110(3) because the property is not located within 500 feet of an existing public park, public or private school providing education to children in kindergarten or grades 1 through 12 or the Charles River Reservation. The nearest pre-existing school or park is 711' from the nearest point of the property line located at 390 Arsenal Street and the Arsenal Park, located at 485 Arsenal Street. Keltic will obtain all required approvals from the Town to ensure it is compliant with the setback requirements for a Marijuana Retailer set forth in Section 8.04 of Watertown's Zoning Ordinance. Keltic also plans to pursue a special permit from the Town Planning Board if it obtains a successful vote to proceed from the Town Council. Keltic will also apply for any other local permits required to operate as a Marijuana Retailer at the proposed location. In addition, Keltic will comply with all dimensional controls set forth in Sections 5.01 of Watertown's Zoning Ordinance, and all conditions and standards set forth in any local permit required to operate as a Marijuana Retailer at Keltic's proposed location. CURRENT VIEW, 390 ARSENAL STREET, WATERTOWN, MA r. x kA- lit. ee -isms ssm MOON d6wmi aiwm INNo Ilan ■N ■■■ NNE W a M= ■■w ■mu W KELTic GREEN INC. - BUSINESS PLAN PROPOSED EXTERIOR RENDERING, 390 ARSENAL STREET, WATERTOWN, MA 1r PROPOSED INTERIOR VIEW, 390 ARSENAL STREET, WATERTOWN, MA KELTiC GREEN INC. - BUSINESS PLAN PROPOSED FLOORPLAN, 390 ARSENAL STREET, WATERTOWN, MA o. o ® o ,lsF � I � zsasF ,335E ,_ „BSF =F "�. �z. now oFe7 p® P118 6B901LEf Ak Ro c` ac. �<"RE �\ KELTiC GREEN INC. — BUSINESS PLAN MARKET RESEARCH MASSACHUSETTS INDUSTRY: According to a study by New Frontier, in Massachusetts, adult use retail sales are expected to increase from $457 million in 2018 to $1.4 billion in 2025. Unlike other places where cannabis is legal, Massachusetts is within driving distance of some of the most populous places in the country and is poised to become a cannabis tourist destination. CUSTOMERS' Keltic will only sell marijuana and marijuana products to customers ages 21 years and older that provide a valid identification. Keltic's intended customers are residents of the Town of WATERTOWN and the neighboring municipalities. Such neighboring municipalities include Belmont, Newton, Waltham, and Cambridge. COMPETITORS' Keltic's main competition will include up to two additional adult -use retail marijuana establishments that will be located throughout Watertown. COMPETITIVE ADVANTAGE: Keltic's competitive advantages over their competition include their team, experience, location and competitive advantages described in detail below. Keltic Team — Keltic's team is devoted to the success of the company. The Keltic brand will set itself apart from the market. Keltic's core belief is that the proper people, product and process will ensure success. Its impressive location coupled with state-of-the-art user experience and customer service will be in a class of its own. Keltic's inventory will be diverse and comprised of the highest quality cannabis products available in the state. Our packaging will be subtle yet attractive, informative, user friendly and recyclable. With these key brand elements in place, Keltic will ensure sustainable business growth for years to come and prove to be the best business partner for the Town of Watertown. Experience - Keltic's team has collective experience managing very fast paced and everchanging markets. The team also has vast experience with contracts, purchasing, distribution of goods, team management, as well as the financial background necessary to manage a retail company and all its needs. Keltic also understands local, state and federal laws, and can consistently navigate and comply with the evolving regulatory landscape. Location - Keltic's proposed location at 390 Arsenal Street, is in RMUD Zoning District. The 4,200 square foot building has ample parking and is easily accessible from the highway. Keltic intends to operate a sustainable and profitable business at the site, which KELTic GREEN INC. - BUSINESS PLAN will contribute both financially and socially to the Watertown community. Keltic will transform the existing structure and site and create an inviting safe customer experience. The location will enable the Keltic team to successfully meet its goals. Immediate Access to Premium Products - Keltic has entered into a distribution agreement with Sanctuary Medicinals, Inc. ("Sanctuary"), a premier vertically integrated cultivation leader in Massachusetts. Pursuant to Keltic's agreement with Sanctuary, upon receipt of its local and state approvals to operate a Marijuana Establishment, Keltic will immediately have access to a steady supply of Sanctuary's premium marijuana and products. REGULATIONS' Keltic is a Marijuana Establishment, consistent with the objectives of St. 2016, c. 334, as amended by St. 2017, c. 55 and 935 CMR 500.000. Keltic will be registered to do business in the Commonwealth as a domestic business corporation or another domestic business entity. Keltic will maintain the corporation in good standing with the Massachusetts Secretary of the Commonwealth and the Department of Revenue. Keltic will apply for all state and local permits and approvals required to renovate and operate the facility. Keltic will also work cooperatively with various municipal departments to ensure that the proposed facility complies with all state and local codes, rules and regulations with respect to design, renovation, operation, and security. KELTic GREEN INC. - BUSINESS PLAN PRODUCTS / SERVICE PRODUCTS AND SERVICE: In addition to traditional sativa, indica, and hybrid cannabis flower, Keltic will offer a wide range of products that will allow it to serve customers with a wide variety of needs. Products Keltic intends to offer include, but will not be limited to: 1. Concentrates 2. Topical Salves 3. Creams and Lotions 4. Patches 5. Oral Mucosal and Sublingual Dissolving Tablets 6. Tinctures 7. Sprays 8. Inhalation Ready to Use CO2 Extracted Hash Oils 9. Pre -Dosed Oil Vaporizers 10. Ingestion Capsules 11. Infused Food and Beverages 12. Paraphernalia PRICING STRUCTURE: Keltic's pricing structure will vary based on market conditions. Keltic plans to offer its customers products of superior quality and will price its products accordingly. RESEARCH AND DEVELOPMENT: Keltic has been proactively engaged in research and development activities for the past year and half and will continue to rely on research and development activities to ensure it is offering a premier retail experience to its customers. KELTic GREEN INC. - BUSINESS PLAN MARKETING AND SALES GROWTH STRATEGY' Keltic's plan to grow the company includes: 1. Strong and consistent branding; 2. Intelligent, targeted, and compliant marketing programs; 3. A compelling loyalty program; 4. An exemplary customer in-store experience; and 5. A caring and thoughtful staff made of consummate professionals. Our employees will be required to train for their role, three months prior to commencing business. Keltic intends to locate two other dispensaries in Massachusetts and is currently working on obtaining local support for the locations. In total, Keltic aspires to earn three total licenses to operate retail Marijuana Establishments in the Commonwealth. Through these co -branded locations, Keltic will strive to expand its business and maximize its customer base in the Commonwealth. COMMUNICATION: Keltic will engage in reasonable marketing, advertising, and branding practices that do not jeopardize the public health, welfare, or safety of the general public, or promote the diversion of marijuana or marijuana use in individuals younger than 21 years old. Any such marketing, advertising, and branding created for viewing by the public will include the statement: "Please Consume Responsibly," in a conspicuous manner on the face of the advertisement and will include a minimum of two of the warnings, located at 935 CMR 500.105(4)(a), in their entirety in a conspicuous manner on the advertisement. All marketing, advertising, and branding produced by or on behalf of Keltic will include the following warning, including capitalization, in accordance with M.G.L. c. 94G, § 4(al/z)(xxvi): "This product has not been analyzed or approved by the Food and Drug Administration (FDA). There is limited information on the side effects of using this product, and there may be associated health risks. Marijuana use during pregnancy and breast-feeding may pose potential harms. It is against the law to drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There may be health risks associated with consumption of this product. Marijuana can impair concentration, coordination, and judgment. The impairment effects of edible marijuana may be delayed by two hours or more. In case of accidental ingestion, contact poison control hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA." Keltic will seek marketing opportunities at events only where 85% or more of the audience is reasonably expected to be 21 years of age or older, as determined by reliable, current audience composition data. At these events, Keltic will market its products and services to reach a wide range of qualified consumers. KELTic GREEN INC. - BUSINESS PLAN Keltic will communicate with customers through: 1. A company run website; 2. A company blog; 3. Popular cannabis discovery networks such as WeedMaps and Leafly; 4. Popular social media platforms such as Instagram, Facebook, Twitter, and SnapChat; and 5. Opt -in direct communications. Keltic will provide a catalogue and a printed list of the prices and strains of marijuana available to consumers and will post the same catalogue and list on its website and in the retail store. SALES: Keltic will sell its product and service by engaging customers with knowledgeable in-store personnel and an array of products displayed in an upscale modern retail environment. Our staff will be trained to efficiently to: 1. Greet all customers and check them in as they enter the secure waiting vestibule; 2. The staff member will help identify the customer needs and arrange for a 1 on 1 service with the next available budtender; 3. Once the customer enters the dispensary floor, they will be able to interact with their budtender, to see, smell, and discuss their purchase. Budtenders will be equipped with all of Keltic's products. The products will be in a secure glass case. Customers will be able to see and smell what they are purchasing; 4. The budtender will assist to create a purchase order with the customer utilizing iPads. The order will be generated and sent to the point of sale counter; 5. At the point of sale, the Keltic cashier will go over the order with the customer and complete the purchase. The product will be placed in a discrete bag and stapled at the top; and 6. The customer will then be escorted to the exit where they can enter back into the general parking area and obtain transportation. Keltic will ensure that all marijuana products that are provided for sale to consumers are sold in tamper or child -resistant packaging. Packaging for marijuana products sold or displayed for consumers, including any label or imprint affixed to any packaging containing marijuana products or any exit packages, will not be attractive to minors. Packaging for marijuana products sold or displayed for consumers in multiple servings will allow a consumer to easily perform the division into single servings and include the following statement on the exterior of the package in a printed font that is no smaller than ten -point Times New Roman, Helvetica, or Arial, including capitalization: "INCLUDES MULTIPLE SERVINGS." Keltic will not sell multiple serving beverages and each single serving of an edible marijuana product contained in a multiple -serving package will be marked, stamped, or otherwise imprinted with the symbol issued by the Commission under 935 CMR 500.105(5) that indicates that the single serving is a marijuana product. At no point will an individual serving size of any marijuana product contain more than five (5) milligrams of delta -nine tetrahydrocannabinol. KELTic GREEN INC. - BUSINESS PLAN Loco• Keltic has developed a logo to be used in labeling, signage, and other materials such as letterhead and distributed materials. The logo is discreet, unassuming, and does not use medical symbols, images of marijuana, related paraphernalia, or colloquial references to cannabis or marijuana. An image of the logo can be found below: TV.Ptr KELTIC KELTIC GREEN INC. - BUSINESS PLAN FINANCIAL STRENGTH AND PROJECTIONS FINANCIAL STRENGTH: Keltic has the financial stability, capability and ample funding sources to fulfill the commitments set forth in this Business Plan. As demonstrated in Table 1 and Graph 1 below, Keltic's available funding more than exceeds in proposed start-up expenses and will allow it to remain a stable and sustained source of marijuana and marijuana products over the long term. As shown in more detail in Section 7 of the Application of Intent, Keltic currently has a bank account with over $1,000,000.00 in available funds to finance its operations and access to additional funds, if needed. After the first year of operations, it is expected that Keltic will be able to trim expenses through realizing business efficiencies, gaining operational experience and industry knowledge. Table 1. Start-up Expenses CAPEX FrWr 1 Quarter 2 Quarter 3 Quarter 4 Land & Development 0 0 0 0 Space improvements (finishing/painting, 150,000 0 0 0 kitchen, office space, bathrooms, etc.) Security system (cameras, alarms, 20,000 0 0 0 monitoring etc.) Furniture, Display Counters, 50,000 0 0 0 Refrigerators, Freezers, Multiple POS/ Cash Registers, Computers, Commercial Label Printer, Storage Hardware and Shelving Cost for Computer Software (Accounting 2,000 0 0 0 Software, Payroll Software, CRM Software, Microsoft Office, QuickBooks Pro) OPEX Direct Costs 143,996 304,386 350,455 396,524 Initial & General Costs 50,400 3,900 3,900 3,900 Operating Expenses, including salaries 83,201 113,949 127,773 128,221 Marketing & Sales Expenses 24,230 26,314 26,314 26,314 Misc. 2,707 4,079 4,102 4,124 Total 526,535 452,628 512,543 559,083 KELTic GREEN INC. - BUSINESS PLAN Graph 1. Cash Flow Forecast Cash Flow Forecast $10,000 10,000 $9,000 9,000 $8,000 r 8,000 $7,000 7,000 $6,000 6,000 $5,000 5,000 $4,000 4,000 $3,000 3,000 $2,000 2,000 $1,000 1,000 $0 - Year 1 Year 2 Year 3 Year 4 Year 5 Operational Cash Flow ♦Ending Period Cash Flow 5 YEAR OUTLOOK: From a total investment of $1,000,000 million, Keltic is expected to generate nearly $14 million in gross revenues with net income of nearly $8 million in Year 2, its first full year of operations. Revenues are expected to grow to nearly $15 million in Year 3 and $17 million in Year 5, with net income of nearly $7.3 million and over $9.3 million, respectively (See Table 2 and Graph 2 below). Table 2. Financial Projections Adult Use Year 1 Year 2 Year 3 Year 4 Year 5 Serviceable Market 120,181 120,181 120,181 120,181 120,181 Consumer Population 7.5% 8.0% 8.5% 9.0% 9.5% Total Consumers/month 9,014 9,614 10,215 10,816 11,417 Daily average customer count 300 320 341 361 381 Average Customer/ Hour 9am-9pm 25 27 28 30 32 Average sales ticket $ 115.00 $ 115.00 $ 115.00 $ 115.00 $ 115.00 Daily Sales Average Total $ 34,552.04 $ 36,855.51 $ 39,158.98 $ 41,462.45 $ 43,765.91 Total Pounds Purchased 1,944 2,073 2,203 2,332 2,462 Cannabis Sales $ 12,438,734 $ 13,267,982 $ 14,097,231 $ 14,926,480 $ 15,755,729 Other Sales (paraphernalia, etc) $ 373,162 $ 398,039 $ 422,917 $ 447,794 $ 472,672 Total Revenue $ 12,811,896 $ 13,666,022 $ 14,520,148 $ 15,374,275 $ 16,228,401 Cultivation Charge (COGS) $ 6,219,367 $ 5,804,742 $ 5,286,462 $ 4,664,525 $ 4,431,299 Gross Profit $ 6,592,529 $ 7,861,280 $ 9,233,687 $ 10,709,750 $ 11,797,102 Operating Expenses (17% of Gross Profit) $ 1,120,730 $ 1,336,418 $ 1,569,727 $ 1,820,657 $ 2,005,507 HCA Payment $ 384,357 $ 409,981 $ 435,604 $ 461,228 $ 486,852 Net Income $ 5,087,442 $ 6,114,881 $ 7,228,355 $ 8,427,864 $ 9,304,743 Graph 2. Revenue & Profit Forecast Revenue & Profit Forecast $18,000 0 $16,000 $14,000 $12,000 $10,000 $8,000 $6,000 $4,000 $2,000 $0 Year 1 Year 2 Year 3 Year 4 Year 5 Revenue � Gross Profit Net Income MUNICIPAL PAYMENTS: As demonstrated in Table 3 below, Keltic anticipates that its Marijuana Establishment will generate a significant amount of money for the Town as a result of the Host Community Agreement payments and tax revenue from the marijuana excise tax. Table 3. Municipal Payments Assumptions Year 1 Year 2 Year 3 Year 4 Year 5 Wholesale Avg Cost $/Ib $ 3,200 $ 2,800 $ 2,400 $ 2,000 $ 1,800 Wholesale Avg Cost per $/oz $ 200.00 $ 175.00 $ 150.00 $ 125.00 $ 112.50 Dispensary Avg $/Ib $ 6,400.00 $ 6,400.00 $ 6,400.00 $ 6,400.00 $ 6,400.00 Dispensary Avg Selling flower/MIP $/oz* $ 400.00 $ 400.00 $ 400.00 $ 400.00 $ 400.00 Paraphernalia Margin 50% 50% 50% 50% 50% Paraphernalia Sales 3% 3% 3% 3% 3% Municipality 3% excise tax $ 373,162.01 $ 398,039.47 $ 422,916.94 $ 447,794.41 $ 472,671.87 HCA Payment 3% $ 384,356.87 $ 409,980.66 $ 435,604.45 $ 461,228.24 $ 486,852.03 Total Municipality payment $ 757,518.87 $ 808,020.13 $ 858,521.39 $ 909,022.64 $ 959,523.90 FINAL REMARKS Keltic has the experience and know-how to safely and efficiently serve customers with high quality, consistent, laboratory -tested medical grade marijuana and marijuana products. Keltic hopes to bring its high -quality standards to adult -use customers in Watertown to provide them with an unforgettable retail marijuana experience. Keltic's state-of-the-art security will help ensure a safe and secure environment for both customers and staff and will help deter and prevent diversion. As outlined in this Business Plan, Keltic is well -positioned and poised to contribute to the growth of the Massachusetts marijuana market and the Town of Watertown, as a whole. In doing so, Keltic looks forward to working cooperatively with Watertown to maximize and spread the benefits that this market will ultimately yield. KELTic GREEN INC. - BUSINESS PLAN EXHIBIT A PROPOSED EXTRIOR VIEW 1, 390 ARSENAL STREET, WATERTOWN PROPOSED EXTRIOR VIEW 2,390 ARSENAL STREET, WATERTOWN KELTIC GREEN INC. - BUSINESS PLAN - EXHIBIT A PROPOSED EXTRIOR VIEW 3,390 ARSENAL STREET, WATERTOWN PROPOSED ENTRY / WAITING AREA VIEW 1, 390 ARSENAL STREET, WATERTOWN KELTIC GREEN INC. - BUSINESS PLAN - EXHIBIT A PROPOSED DISPENSARY FLOOR VIEW 1, 390 ARSENAL STREET, WATERTOWN PROPOSED DISPENSARY FLOOR VIEW 2,390 ARSENAL STREET, WATERTOWN KELTIC GREEN INC. - BUSINESS PLAN - EXHIBIT A KELTIC GREEN INC. - BUSINESS PLAN - EXHIBIT A VV.JtT KELTIC DISPENSING PROCEDURES In accordance with 935 CMR 500.140(3), access to Keltic Green, Inc.'s ("Keltic") facility is limited to individuals 21 years of age and older. Upon a customer's entry into Keltic's premises, a Keltic agent will immediately inspect the customer's proof of identification and determine the individual's age. An individual will not be admitted to the premises unless the retailer has verified that the individual is 21 years of age or older by an individual's proof of identification. At the door, a designated staff member will collect valid customer identification and confirm a minimum age of 21 years old, failing the confirmation of 21 years of age or older, an individual will be prohibited from entering the premises. Once inside the retail area, customers will enter a queue to obtain individualized service where they may select any of the products available to them with the help of a Keltic agent. Upon checkout, customers will be required to confirm their identities and age a second time. Check out also activates the seed -to -sale tracking system that is compliant with 935 CMR 500.105(8). Per M.G.L. c. 94G § 7, sales are limited to one ounce of marijuana flower or five grams of marijuana concentrate per transaction. All required taxes will be collected at the point of sale. Once a customer has selected a product for purchase, a Keltic agent will collect the chosen items from the designated product storage area. A Keltic agent will then scan each product barcode into the point of sale system. In the event of a flower sale, staff will weigh the chosen amount of flower and then place it in a tamper-resistant/child-resistant, resealable package that is compliant with 935 CMR 500.105(5). A Keltic agent will affix a label, as generated by the point of sale system, indicating the date, strain name, cannabinoid profile, and all applicable warnings detailed in 935 CMR 500.105. In the event a Keltic agent determines an individual would place themselves or the public at risk, the agent will refuse to sell any marijuana products to the consumer. Keltic will use the point of sale security system to accept payment and complete sales. The system can back up and securely cache each sale for inspection. KELTIC GREEN, INC. - DISPENSING PROCEDURES Pursuant to 935 CMR 500.140(6)(d), Keltic will conduct a monthly analysis of its equipment and sales data to determine that no software has been installed that could be utilized to manipulate or alter sales data and that no other methodology has been employed to manipulate or alter sales data. If any such malware is found, Keltic will immediately report the occurrence to the Commission and assist in any subsequent investigation into the matter. Keltic will maintain a record of the monthly analyses and will make it available for inspection by the Commission upon request. Further, Keltic will cooperate with the Commission and the Department of Revenue to ensure compliance with any and all taxes in accordance with the laws of the Commonwealth and 935 CMR 500.000. Keltic places a premium on cleanliness, hygiene, and proper product storage to achieve and maintain successful operation of the business. In addition to regularly sanitizing surfaces with products kept separately and away from marijuana products Keltic staff will ensure personal hygiene including washing hands throughout the day and before handling or dispensing any marijuana products. All products available for sale and consumption will be tested for impurities and subjected to Keltic Green's policies governing quality control per 935 CMR 500.105. In compliance with 935 CMR 5001.140(8), Keltic will provide educational materials designed to help consumers make informed marijuana product purchases. Kehic's educational materials will describe the varying types of products available at Keltic, as well as the types and methods of consumption. The materials will offer education on cannabis titration: the method of using the smallest amount of a given marijuana product necessary to bring about the desired effect. Additional topics discussed in consumer materials will include potency; proper dosing; the delayed effects of edible marijuana products; and substance abuse and related treatment programs, marijuana tolerance, dependence, and withdrawal. KELTIC GREEN, INC. - DISPENSING PROCEDURES KELTIC INVENTORY PROCEDURES Keltic Green, Inc. ("Keltic") will maintain real-time inventory in compliance with 935 CMR 500.105(8), including maintaining inventory of: marijuana ready for dispensing; all marijuana products; and all damaged, defective, expired, or contaminated marijuana and marijuana products awaiting disposal. All marijuana products will be tagged and tracked within Keltic's seed -to -sale tracking system. Keltic will utilize a real-time seed -to -sale tracking system, which will provide the electronic tracking of individual marijuana plants, including during cultivation, growth, harvest and preparation of marijuana products (as applicable), and final sale. Kehic's tracking system will utilize unique batch identification numbers to accurately track inventory. Keltic will: • Establish inventory controls and procedures for the conduct of inventory reviews, and comprehensive inventories of finished and stored marijuana; • Conduct a monthly inventory of finished and stored marijuana; • Conduct a comprehensive annual inventory at least once every year after the date of the previous comprehensive inventory; and • Promptly transcribe inventories if taken by use of an oral recording device. The record of each inventory will include, at a minimum, the date of the inventory, a summary of the inventory findings, and the names, signatures, and titles of the individuals who conducted the inventory. All inventory records will be kept in accordance with Keltic's record keeping procedures. Keltic's agents will document and Keltic will report any unusual discrepancy in weight or inventory to the Commission and law enforcement authorities not more than 24 hours after the discovery of such a discrepancy. Keltic will only sell and market inventory that is capable of being tested by Independent Testing Laboratories, except as allowed under 935 CMR 500.000. KELTIC GREEN, INC. - INVENTORY PROCEDURES Tv.JtT KELTIC MAINTAINING OF FINANCIAL RECORDS Keltic Green, Inc.'s ("Keltic") operating policies and procedures ensure financial records are accurate and maintained in compliance with the Commission's Adult Use of Marijuana regulations (935 CMR 500). Financial records maintenance measures include policies and procedures requiring that: • Confidential information will be maintained in a secure location, kept separate from all other records, and will not be disclosed without the written consent of the individual to whom the information applies, or as required under law or pursuant to an order from a court of competent jurisdiction; provided however, the Commission may access this information to carry out its official duties. • All recordkeeping requirements under 935 CMR 500.105(9) are followed, including: o Keeping written business records, available for inspection, and in accordance with generally accepted accounting principles, which will include manual or computerized records of. ■ Assets and liabilities; ■ Monetary transactions; ■ Books of accounts, which will include journals, ledgers, and supporting documents, agreements, checks, invoices, and vouchers; ■ Sales records including the quantity, form, and cost of marijuana products; and ■ Salary and wages paid to each employee and any executive compensation, bonus, benefit, or item of value paid to any individual affiliated with a marijuana establishment, including members, if any. • All sales recording requirements under 935 CMR 500.140(6) are followed, including: o Utilizing a point -of -sale (POS) system approved by the Commission, in consultation with the DOR, and a sales recording module approved by DOR; KELTIC GREEN, INC. - MAINTAINING OF FINANCIAL RECORDS o Conducting a monthly analysis of its equipment and sales date, and maintaining records, available to the Commission upon request, that the monthly analysis has been performed; o Complying with 830 CMR 62C.25.1: Record Retention and DOR Directive 16-1 regarding recordkeeping requirements; o Adopting separate accounting practices at the point -of -sale for marijuana and marijuana product sales, and non -marijuana sales; o Maintaining such records that would allow for the Commission and the DOR to audit and examine the point -of -sale system used in order to ensure compliance with Massachusetts tax laws and 935 CMR 500; and • Additional written business records will be kept, including, but not limited to, records of: o Compliance with liability insurance coverage or maintenance of escrow requirements under 935 CMR 500.105(10) and all bond or escrow requirements under 935 CMR 500.105(16); o Fees paid under 935 CMR 500.005 or any other section of the Commission's regulations; and o Fines or penalties, if any, paid under 935 CMR 500.550 or any other section of the Commission's regulations. KELTIC GREEN, INC. - MAINTAINING OF FINANCIAL RECORDS KELTIC PERSONNEL POLICIES INCLUDING BACKGROUND CHECKS Overview Keltic Green Inc. ("Keltic Green") will securely maintain personnel records, including registration status and background check records. Keltic Green will keep, at a minimum, the following personnel records: • Job descriptions for each employee and volunteer position, as well as organizational charts consistent with the job descriptions; • A personnel record for each marijuana establishment agent; • A staffing plan that will demonstrate accessible business hours and safe conditions; • Personnel policies and procedures; and • All background check reports obtained in accordance with 935 CMR 500.030. Agent Personnel Records Personnel records for each agent will be maintained for at least twelve (12) months after termination of the agent's affiliation with Keltic Green and will include, at a minimum, the following: • All materials submitted to the Commission pursuant to 935 CMR 500.030(2); • Documentation of verification of references; • The job description or employment contract that includes duties, authority, responsibilities, qualifications, and supervision; • Documentation of all required training, including training regarding privacy and confidentiality requirements, and the signed statement of the individual indicating the date, time, and place he or she received said training and the topics discussed, including the name and title of presenters; • Documentation of periodic performance evaluations; • A record of any disciplinary action taken; • Notice of completed responsible vendor and eight -hour related duty training; and • Results of initial background investigation, including CORI reports. Personnel records will be kept in a secure location to maintain confidentiality and be only accessible to the agent's manager or members of the executive management team. After -Hours Contacts KELTic GREEN INC. - PERSONNEL POLICIES INCLUDING BACKGROUND CHECKS Justin Smith / Keltic CEO 617.257.7799 Business Hours (Subject to Approval b. t�pecial Permit Granting Authority)1 Monday: 8:00 a.m. to 10:00 p.m. Tuesday: 8:00 a.m. to 10:00 p.m. Wednesday: 8:00 a.m. to 10:00 p.m. Thursday: 8:00 a.m. to 11:00 p.m. Friday: 8:00 a.m. to 11:00 p.m. Saturday: 8:00 a.m. to 11:00 p.m. Sunday: 9:00 a.m. to 10:00 p.m. Aizent Background Checks • In addition to completing the Commission's agent registration process, all agents hired to work for Keltic Green will undergo a detailed background investigation prior to being granted access to a Keltic Green facility or beginning work duties. • Background checks will be conducted on all agents in their capacity as employees or volunteers for Keltic Green pursuant to 935 CMR 500.100 and will be used by the Director of Security, who will be registered with the Department of Criminal Justice Information Systems pursuant to 803 CMR 2.04: iCORI Registration and the Commission for purposes of determining the suitability of individuals for registration as a marijuana establishment agent with the licensee. • For purposes of determining suitability based on background checks performed in accordance with 935 CMR 500.101(1), Keltic Green will consider: a. All conditions, offenses, and violations are construed to include Massachusetts law or like or similar law(s) of another state, the United States or foreign jurisdiction, a military, territorial or Native American tribal authority, or any other jurisdiction. b. All criminal disqualifying conditions, offenses, and violations include the crimes of attempt, accessory, conspiracy, and solicitation. Juvenile dispositions will not be considered as a factor for determining suitability. c. Where applicable, all look -back periods for criminal conditions, offenses, and violations included in 935 CMR 500.802 commence upon the date of disposition; provided, however, that if disposition results in incarceration in any institution, the look -back period will commence upon release from incarceration. • Suitability determinations will be made in accordance with the procedures set forth in 935 CMR 500.800. In addition to the requirements established in 935 CMR 500.800, Keltic Green will: a. Comply with all guidance provided by the Commission and 935 CMR 500.802: Tables B through D to determine if the results of the background are grounds for Mandatory Disqualification or Presumptive Negative Suitability Determination. ' Make sure that this matches what is in the Security Plan. KELTic GREEN INC. — PERSONNEL POLICIES INCLUDING BACKGROUND CHECKS b. Consider whether offense(s) or information that would result in a Presumptive Negative Suitability Determination under 935 CMR 500.802. In the event a Presumptive Negative Suitability Determination is made, Keltic Green will consider the following factors: i. Time since the offense or incident; ii. Age of the subject at the time of the offense or incident; iii. Nature and specific circumstances of the offense or incident; iv. Sentence imposed and length, if any, of incarceration, if criminal; V. Penalty or discipline imposed, including damages awarded, if civil or administrative; vi. Relationship of offense or incident to nature of work to be performed; vii. Number of offenses or incidents; viii. Whether offenses or incidents were committed in association with dependence on drugs or alcohol from which the subject has since recovered; ix. If criminal, any relevant evidence of rehabilitation or lack thereof, such as information about compliance with conditions of parole or probation, including orders of no contact with victims and witnesses, and the subject's conduct and experience since the time of the offense including, but not limited to, professional or educational certifications obtained; and X. Any other relevant information, including information submitted by the subject. Consider appeals of determinations of unsuitability based on claims of erroneous information received as part of the background check during the application process in accordance with 803 CMR 2.17: Requirement to Maintain a Secondary Dissemination Log and 2.18: Adverse Employment Decision Based on CORI or Other Types of Criminal History Information Received from a Source Other than the DCJIS. • All suitability determinations will be documented in compliance with all requirements set forth in 935 CMR 500 et seq. and guidance provided by the Commission. • Background screening will be conducted by an investigative firm holding the National Association of Professional Background Screeners (NAPBSO) Background Screening Credentialing Council (BSCC) accreditation and capable of performing the searches required by the regulations and guidance provided by the Commission. • References provided by the agent will be verified at the time of hire. • As a condition of their continued employment, agents, volunteers, contractors, and subcontractors are required to renew their Program ID cards annually and submit to other background screening as may be required by Keltic Green or the Commission. KELTic GREEN INC. - PERSONNEL POLICIES INCLUDING BACKGROUND CHECKS �J KELTIC PLAN FOR OBTAINING MARIJUANA OR MARIJUANA PRODUCTS Keltic Green, Inc. ("Keltic") is currently not affiliated with any entity holding a license to cultivate marijuana or manufacture marijuana products in the Commonwealth of Massachusetts pursuant to 935 CMR 500.000 et seq. As such, Keltic plans to purchase marijuana and marijuana products from those entities licensed to cultivate and manufacture marijuana and marijuana products under 935 CMR 500.000 et seq. Keltic will ensure that all marijuana and marijuana products purchased from licensed marijuana cultivators and product manufacturers are in compliance with 935 CMR 500.160(9), requiring marijuana and marijuana products be tested by an Independent Testing Laboratory and deemed to comply with the standards required under 935 CMR 500.160 prior to the sale or marketing for adult use of any such marijuana or marijuana product. KELTIC GREEN, INC. - PLAN FOR OBTAINING MARIJUANA OR MARIJUANA PRODUCTS Tv.JtT KELTIC PLAN FOR RESTRICTING ACCESS TO AGE 21 AND OLDER Pursuant to 935 CMR 500.050(5)(b), Keltic Green, Inc. ("Keltic") will only be accessible to consumers 21 years of age or older with a verified and valid, government -issued photo ID. Upon entry into the premises of the marijuana establishment by an individual, a Keltic agent will immediately inspect the individual's proof of identification and determine the individual's age, in accordance with 935 CMR 500.140(2). In the event Keltic discovers any of its agents intentionally or negligently sold marijuana to an individual under the age of 21, the agent will be immediately terminated, and the Commission will be promptly notified, pursuant to 935 CMR 500.105(1)(1). Keltic Green will not hire any individuals who are under the age of 21 or who have been convicted of distribution of controlled substances to minors, pursuant to 935 CMR 500.030(1). Pursuant to 935 CMR 500.105(4), Keltic will not engage in any marketing, advertising or branding practices that are targeted to, deemed to appeal to or portray minors under the age of 21. Keltic will not engage in any advertising, marketing and branding by means of television, radio, internet, mobile applications, social media, or other electronic communication, billboard or other outdoor advertising, including charitable, sporting or similar events, unless at least 85% of the audience is reasonably expected to be 21 years of age or older as determined by reliable and current audience composition data. Keltic will not manufacture or sell any edible products that resemble a realistic or fictional human, animal or fruit, including artistic, caricature or cartoon renderings, pursuant to 935 CMR 500.150(1)(b). In accordance with 935 CMR 500.105(4)(a)(5), any marketing, advertising and branding materials for public viewing will include a warning stating, "For use only by adults 21 years of age or older. Keep out of the reach of children. Marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of marijuana. Please Consume Responsibly." Pursuant to 935 CMR 500.105(6)(b), Keltic packaging for any marijuana or marijuana products will not use bright colors, resemble existing branded products, feature cartoons or celebrities commonly used to market products to minors, feature images of minors or other words that refer to products commonly associated with minors or otherwise be KELTIC GREEN, INC. - PLAN FOR RESTRICTING ACCESS TO AGE 21 AND OLDER attractive to minors. Keltic's website will require all online visitors to verify they are 21 years of age or older prior to accessing the website, in accordance with 935 CMR 500.105(4)(b)(13). KELTIC GREEN, INC. - PLAN FOR RESTRICTING ACCESS TO AGE 21 AND OLDER vq.ptr KELTIC PLAN TO REMAIN COMPLIANT WITH LOCAL ZONING Keltic Green, Inc. ("Keltic") intends to remain compliant with the local zoning requirements set forth in the Watertown's Cannabis Zoning Ordinance at all times. Kehic's proposed Adult -Use Marijuana Retail Establishment will be located at 390 Arsenal Street in Watertown, which is in the Industrial 1 ("I- I") Zoning District. Pursuant to the zoning ordinances Section 5.03 "Notes to Table of Use Regulations, sub -section 16" set forth in the Town of Watertown's Zoning Ordinance, Adult Use Marijuana Establishments (Section 8.04) are permitted to operate in the I-1 Zoning District after obtaining a special permit from the City Council. Keltic's proposed site complies with 935 CMR 500.110(3) because the property is not located within 500 feet of an existing public park, public or private school providing education to children in kindergarten or grades 1 through 12 or the Charles River Reservation. The nearest pre-existing school or park is 711' from the nearest point of the property line located at 390 Arsenal Street and the Arsenal Park, located at 485 Arsenal Street. Keltic will obtain all required approvals from the Town to ensure it is compliant with the setback requirements for a Marijuana Retailer set forth in Section 8.04 of Watertown's Zoning Ordinance. Keltic also plans to pursue a special permit from the Town Planning Board if it obtains a successful vote to proceed from the Town Council. Keltic will also apply for any other local permits required to operate as a Marijuana Retailer at the proposed location. In addition, Keltic will comply with all dimensional controls set forth in Sections 5.03.16 of Watertown's Zoning Ordinance, and all conditions and standards set forth in any local permit required to operate as a Marijuana Retailer at Keltic's proposed location. V9.1tT KELTIC PLAN TO REMAIN COMPLIANT WITH LOCAL ZONING Keltic Green, Inc. ("Keltic") intends to remain compliant with the local zoning requirements set forth in the Watertown's Cannabis Zoning Ordinance at all times. Keltic's proposed Adult -Use Marijuana Retail Establishment will be located at 390 Arsenal Street in Watertown, which is in the RMUD Zoning District. Pursuant to the zoning ordinances Section 5.01 set forth in the Town of Watertown's Zoning Ordinance, Adult Use Marijuana Establishments (Section 8.04) are permitted to operate in the RMUD Zoning District after obtaining a special permit from the City Council. Keltic's proposed site complies with 935 CMR 500.110(3) because the property is not located within 500 feet of an existing public park, public or private school providing education to children in kindergarten or grades 1 through 12 or the Charles River Reservation. The nearest pre-existing school or park is 711' from the nearest point of the property line located at 390 Arsenal Street and the Arsenal Park, located at 485 Arsenal Street. Keltic will obtain all required approvals from the Town to ensure it is compliant with the setback requirements for a Marijuana Retailer set forth in Section 8.04 of Watertown's Zoning Ordinance. Keltic also plans to pursue a special permit from the Town Planning Board if it obtains a successful vote to proceed from the Town Council. Keltic will also apply for any other local permits required to operate as a Marijuana Retailer at the proposed location. In addition, Keltic will comply with all dimensional controls set forth in Sections 5.01 of Watertown's Zoning Ordinance, and all conditions and standards set forth in any local permit required to operate as a Marijuana Retailer at Keltic's proposed location. vq.ptr KELTIC PREVENTION OF DIVERSION Keltic Green, Inc.'s ("Keltic") operating policies and procedures ensure prevention of diversion, theft, and illegal or unauthorized conduct pursuant to the Commission's Adult Use of Marijuana regulations codified in 935 CMR 500. Considerations regarding diversion prevention measures include, but are not limited to, marijuana establishment agent and consumer accountability, and identifying, recording, and reporting diversion, theft, or loss. Marijuana in the process of transport, analysis, or retail sale is to be stored and tracked in a manner that prevents diversion, theft, or loss. Specifically, diversion measures include policies and procedures requiring that: • Identification is verified on the premises to ensure that only individuals 21 years or older are permitted in Keltic's adult -use marijuana establishment. • Providing samples or giving away marijuana to consumers is prohibited. • Employees are made aware of crime prevention techniques pursuant to 935 CMR 500.105(1)(b). • Any marijuana establishment agent who has diverted marijuana is immediately dismissed, and this is reported to law enforcement and to the Commission pursuant to 935 CMR 500.105(1)(1). • All employees involved in the handling and sale of marijuana for adult use complete a responsible vendor training program with a curriculum covering diversion prevention and prevention of sales to minors and comply with all other marijuana establishment agent training requirements under 935 CMR 500.105(2). • Display samples of each product offered for sale are displayed in secure, locked cases, subject to the requirements of 935 CMR 500.110. • Keltic only engages in reasonable marketing, advertising, and branding practices that do not promote the diversion of marijuana and comply with all other marketing and advertising requirements under 935 CMR 500.105(4). • Warning statements required by the Commission's regulations are affixed to all applicable products, and that Keltic's labels comply with all other labeling of marijuana and marijuana products requirements under 935 CMR 500.105(5). KELTIC GREEN, INC. - PREVENTION OF DIVERSION • Tamper or child -resistant packaging is used for applicable marijuana products, and that Keltic's products comply with all other packaging of marijuana and marijuana products requirements under 935 CMR 500.105(6). • Keltic maintain real-time inventory, and tracking and tagging all marijuana and marijuana products, using a seed -to -sale methodology in a form and manner to be approved by the Commission. • Records are kept for inventory, seed -to -sale tracking for all marijuana products, personnel (including documentation of the completion of required training), and waste disposal, and that Keltic comply with all other record keeping requirements under 935 CMR 500.105(9). • Marijuana that is outdated, damaged, deteriorated, mislabeled, or contaminated, or whose containers or packaging have been opened or breached, is stored in a separate area, until such products are destroyed; and that Keltic comply with all other storage requirements under 935 CMR 500.105(11). • Two or more marijuana establishment agents witness and document how the marijuana waste is disposed or otherwise handled, and that Keltic comply with all other waste disposal requirements under 935 CMR 500.105(12). • All transported marijuana products are linked to the seed -to -sale tracking program, that all vehicles transporting marijuana are staffed with a minimum of two marijuana establishment agents, and that any vehicle accidents, diversions, or other reportable incidents that occur during transport are reported to the Commission and law enforcement within 24 hours, and that Keltic comply with all other transportation requirements under 935 CMR 500.105(13). • All security requirements under 935 CMR 500.110 are followed, including: o Implementing sufficient safety measures to deter and prevent unauthorized entrance into areas containing marijuana and theft of marijuana at Keltic's adult - use marijuana retail location; o Adopting procedures to prevent loitering and to ensure that only individuals engaging in activity expressly or by necessary implication permitted by the Commission's regulations and its enabling statute are allowed to remain on the premises; o Storing all finished marijuana products in a secure, locked safe or vault in such a manner as to prevent diversion, theft, and loss; o Restricting access to employees, agents or volunteers specifically permitted by Keltic, agents of the Commission, state and local law enforcement and emergency personnel, and all other limited access areas requirements under 935 CMR 500.110(4); o Implementing an adequate security system to prevent and detect diversion, theft or loss of marijuana, notifying law enforcement and the Commission within 24 hours KELTIC GREEN, INC. - PREVENTION OF DIVERSION of a diversion, theft or loss of any marijuana product, and all other security and alarm requirements under 935 CMR 500.110(5); and o Obtaining, at Keltic's own expense, a security system audit by a vendor approved by the Commission, and all other security audits requirements under 935 CMR 500.110(8). • All other operating requirements for retail sale under 935 CMR 500.140 are followed, including: o Limiting sales to one ounce of marijuana or five grams of marijuana concentrate to a consumer per transaction; o Utilization of a point -of -sale (POS) system approved by the Commission, in consultation with the DOR; o Providing educational materials to consumers stating that they may not sell marijuana to any other individual and which include information regarding penalties for possession and distribution of marijuana in violation of Massachusetts law. KELTIC GREEN, INC. - PREVENTION OF DIVERSION Tv.JtT KELTIC PROPOSED TIMELINE 935 CMR 500.101(1)(c) A proposed timeline for achieving operation of the Marijuana Establishment and evidence that the Marijuana Establishment will be ready to operate within the proposed timeline after notification by the Commission that the applicant qualifies for licensure. Date Event 3/11/2019 Legal Interest in the Property Obtained TBD Held Community Outreach Meeting*** TBD Obtained Host Community Agreement TBD Submitted Application to Commission Commission Receives Confirmation from +60 Days After Submission of Complete Application Host Community of Compliance with Zoning Bylaws +90 Days After Submission of Complete Received Provisional Certificate from Application Commission; Begin Registering Agents +105 Days After Submission of Complete Connect with METRC and Request the Application Process for Obtaining Administrator Credentials +l 20 Days After Submission of Complete Receive Special Permit from Municipality Application +150 Days After Submission of Complete Receive Municipal Building Permit Application KELTIC GREEN, INC. - PROPOSED TIMELINE +160 Days After Submission of Complete Submission of Architectural Review to Application Commission +190 Days After Submission of Complete Approval of Architectural Review by Application Commission + 200 Days After Submission of Complete Begin Facility Build Out/Renovation Application Set Up IT + 260 Days After Submission of Complete Application + 270 Days After Submission of Complete Finish Facility Build Out/Renovation Application Receive Certificate of Occupancy +280 Days After Submission of Complete Application +285 Days After Submission of Complete Security Monitoring Tested and Facility Application Evaluated for Compliance with 935 CMR 500.000; Request Commission Inspection of Facility Commission Inspection of Facility +300 Days After Submission of Complete Application + 330 Days After Submission of Complete Receive Final License from Commission Application +360 Days After Submission of Complete Receive Commence Operations from Application Commission and Acquire Marijuana from Licensed Cultivators and Product Manufacturers) +365 Days After Submission of Complete Begin Sales to Consumers Application * * * Within six months prior to filing the Application of Intent ' The period of time between receiving a Final License and receiving Commence Operations from the Commission includes, inter alia, ensuring appropriate packaging and labeling; registering with the Department of Revenue for tax purposes; and receiving/entering adult -use product into Metrc and complying with all Metrc requirements. KELTIC GREEN, INC. — PROPOSED TIMELINE Tv.JtT KELTIC QUALIFICATIONS AND TRAINING Keltic Green, Inc. ("Keltic") will ensure that all employees hired to work at a Keltic facility will be qualified to work as a marijuana establishment agent and properly trained to serve in their respective roles in a compliant manner. Qualifications In accordance with 935 CMR 500.030, a candidate for employment as a marijuana establishment agent must be 21 years of age or older. In addition, the candidate cannot have been convicted of a criminal offense in the Commonwealth involving the distribution of controlled substances to minors, or a like violation of the laws of another state, the United States, or foreign jurisdiction, or a military, territorial, or Native American tribal authority. Keltic will also ensure that its employees are suitable for registration consistent with the provisions of 935 CMR 500.802. In the event that Keltic discovers any of its agents are not suitable for registration as a marijuana establishment agent, the agent's employment will be terminated, and Keltic will notify the Commission within one (1) business day that the agent is no longer associated with the establishment. Training As required by 935 CMR 500.105(2), and prior to performing job functions, each of Keltic's agents will successfully complete a comprehensive training program that is tailored to the roles and responsibilities of the agent's job function. Agent training will at least include the Responsible Vendor Program and eight (8) hours of on -going training annually. On or after July 1, 2020, all of Keltic's current owners, managers, and employees will have attended and successfully completed a Responsible Vendor Program operated by an education provider accredited by the Commission to provide the annual minimum of two hours of responsible vendor training to marijuana establishment agents. Keltic's new, non -administrative employees will complete the Responsible Vendor Program within 90 days of the date they are hired. Keltic's KELTIC GREEN, INC. - QUALIFICATIONS AND TRAINING owners, managers, and employees will then successfully complete the program once every year thereafter. Keltic will also encourage administrative employees who do not handle or sell marijuana to take the responsible vendor program on a voluntary basis to help ensure compliance. Keltic's records of responsible vendor training program compliance will be maintained for at least four (4) years and made available during normal business hours for inspection by the Commission and any other state licensing authority upon request. As part of the Responsible Vendor program, Keltic's agents will receive training on a variety of topics relevant to marijuana establishment operations, including but not limited to the following: 1. Marijuana's effect on the human body, including physical effects based on different types of marijuana products and methods of administration, and recognizing the visible signs of impairment; 2. Best practices for diversion prevention and prevention of sales to minors; 3. Compliance with tracking requirements; 4. Acceptable forms of identification, including verification of valid photo identification and medical marijuana registration and confiscation of fraudulent identifications; 5. Such other areas of training determined by the Commission to be included; and 6. Other significant state laws and rules affecting operators, such as: • Local and state licensing and enforcement; • Incident and notification requirements; • Administrative and criminal liability and license sanctions and court sanctions; • Waste disposal and health and safety standards; • Patrons prohibited from bringing marijuana onto licensed premises; • Permitted hours of sale and conduct of establishment; • Permitting inspections by state and local licensing and enforcement authorities; • Licensee responsibilities for activities occurring within licensed premises; • Maintenance of records and privacy issues; and • Prohibited purchases and practices. KELTIC GREEN, INC. - QUALIFICATIONS AND TRAINING Tv.JtT KELTIC QUALITY CONTROL AND TESTING Quality Control Keltic Green, Inc. ("Keltic") will comply with the following sanitary requirements: 1. Any Keltic agent whose job includes contact with marijuana or nonedible marijuana products, including packaging, is subject to the requirements for food handlers specified in 105 CMR 300.000, and all edible marijuana products will be prepared, handled, and stored in compliance with the sanitation requirements in 105 CMR 500.000, and with the requirements for food handlers specified in 105 CMR 300.000. 2. Any Keltic agent working in direct contact with preparation of marijuana or nonedible marijuana products will conform to sanitary practices while on duty, including: a. Maintaining adequate personal cleanliness; and b. Washing hands thoroughly in an adequate hand -washing area before starting work, and at any other time when hands may have become soiled or contaminated. 3. Keltic's hand -washing facilities will be adequate and convenient and will be furnished with running water at a suitable temperature. Hand -washing facilities will be located in Keltic's production areas and where good sanitary practices require employees to wash and sanitize their hands, and will provide effective hand -cleaning and sanitizing preparations and sanitary towel service or suitable drying devices; 4. Keltic's facility will have sufficient space for placement of equipment and storage of materials as is necessary for the maintenance of sanitary operations; 5. Keltic will ensure that litter and waste is properly removed and disposed of so as to minimize the development of odor and minimize the potential for the waste attracting and harboring pests. The operating systems for waste disposal will be maintained in an adequate manner pursuant to 935 CMR 500.105(12); 6. Keltic's floors, walls, and ceilings will be constructed in such a manner that they may be adequately kept clean and in good repair; 7. Keltic's facility will have adequate safety lighting in all processing and storage areas, as well as areas where equipment or utensils are cleaned; KELTIC GREEN, INC. - QUALITY CONTROL AND TESTING 8. Keltic's buildings, fixtures, and other physical facilities will be maintained in a sanitary condition; 9. Keltic will ensure that all contact surfaces, including utensils and equipment, will be maintained in a clean and sanitary condition. Such surfaces will be cleaned and sanitized as frequently as necessary to protect against contamination, using a sanitizing agent registered by the US Environmental Protection Agency (EPA), in accordance with labeled instructions. Equipment and utensils will be so designed and of such material and workmanship as to be adequately cleanable; 10. All toxic items will be identified, held, and stored in a manner that protects against contamination of marijuana products; 11. Keltic will ensure that its water supply is sufficient for necessary operations, and that such water supply is safe and potable; 12. Keltic's plumbing will be of adequate size and design, and adequately installed and maintained to carry sufficient quantities of water to required locations throughout the marijuana establishment. Plumbing will properly convey sewage and liquid disposable waste from the marijuana establishment. There will be no cross -connections between the potable and waste water lines; 13. Keltic will provide its employees with adequate, readily accessible toilet facilities that are maintained in a sanitary condition and in good repair; 14. Keltic will hold all products that can support the rapid growth of undesirable microorganisms in a manner that prevents the growth of these microorganisms; and 15. Keltic will store and transport finished products under conditions that will protect them against physical, chemical, and microbial contamination, as well as against deterioration of finished products or their containers. Keltic's vehicles and transportation equipment used in the transportation of marijuana products or edibles requiring temperature control for safety will be designed, maintained, and equipped as necessary to provide adequate temperature control to prevent the marijuana products or edibles from becoming unsafe during transportation, consistent with applicable requirements pursuant to 21 CFR 1.908(c). Keltic will ensure that Keltic's facility is always maintained in a sanitary fashion and will comply with all applicable sanitary requirements. Keltic will follow established policies and procedures for handling voluntary and mandatory recalls of marijuana products. Such procedures are sufficient to deal with recalls due to any action initiated at the request or order of the Commission, and any voluntary action by Keltic to remove defective or potentially defective marijuana products from the market, as well as any action undertaken to promote public health and safety. KELTIC GREEN, INC. - QUALITY CONTROL AND TESTING Any inventory that becomes outdated, spoiled, damaged, deteriorated, mislabeled, or contaminated will be disposed of in accordance with the provisions of 935 CMR 500.105(12), and any such waste will be stored, secured, and managed in accordance with applicable state and local statutes, ordinances, and regulations. KELTIC GREEN, INC. - QUALITY CONTROL AND TESTING Tv.JtT KELTIC SECURITY PLAN STATEMENT FROM KELTIC GREEN INC.'S CHIEF OF SECURITY: My name is Mike Allen and I am the Chief of Security for Keltic Green, Inc. ("Keltic"). I have provided security consulting services for the past 2 1/2 years to marijuana establishments in both New Hampshire and Massachusetts since retiring as Police Chief from the City of Rochester, NH Police Department in December of 2016. I am submitting the following proposed security plan (the "Plan) on behalf of Keltic for your review. The Plan was developed in accordance with 935 CMR 500.000 Cannabis Control Commission regulations, Watertown Local Ordinances, security industry best practices using the principles of Crime Prevention Through Environmental Design (CPTED), and my 30+ years of law enforcement, military and security experience. Our proposal is to locate a Marijuana Retail Establishment at 390 Arsenal Street, Watertown, MA. I am hopeful that the Plan outlined below meets all the requirements of your office and am confident Keltic will have a minimal impact on public safety services in the City of Watertown. On behalf of Keltic, I look forward to working cooperatively with the Watertown Police Department to incorporate suggestions and feedback into the Plan to ensure the safest experience for employees, customers, and the City. Respectfully Submitted, Michael J. Allen Chief of Security Keltic Green Inc. KELTIC GREEN, INC. - SECURITY PLAN HOURS OF OPERATION (Subject to Approval by the Special Permit Granting Authority): Monday: 8:00 a.m. to 10:00 p.m. Tuesday: 8:00 a.m. to 10:00 p.m. Wednesday: 8:00 a.m. to 10:00 p.m. Thursday: 8:00 a.m. to 11:00 p.m. Friday: 8:00 a.m. to 11:00 p.m. Saturday: 8:00 a.m. to 11:00 p.m. Sunday: 9:00 a.m. to 10:00 p.m. AFTER-HOURS CONTACT INFORMATION: Justin Smith, CEO - 617 257 7799 SECURITY LEVELS: The site plan review of the facility has been reviewed physically and electronically for the purposes of providing, designing, and commissioning a new Electronic Security Access Control System that includes Perimeter Monitoring, Panic Alarms, Motion Detectors, and Intrusion Detection System. A Video Management System (VMS), has been selected to monitor, record, and archive video on a Network Video Recorder (NVR). Astronaut Security is the preferred security integrator for Keltic and assisted in the design and engineering of the proposed security system. The facility was reviewed and delineated into three levels of security access to provide the highest level of security which meets or exceeds the standards of the Cannabis Control Commission and the City of Watertown. Employee access to different levels is based solely on need, and their access credentials are programmed accordingly. Level 1 The facility will be open to the general public for the recreational sale of product. The general public, employees, visitors, and vendors will be required to enter the facility through one entrance which is monitored by CCTV cameras as outlined in the security drawings. All perspective customers will "check in" at the lobby/vestibule area with valid photo identification for KELTIC GREEN, INC. - SECURITY PLAN presentation to the receptionist. The receptionist will process the identification through an electronic ID verification system for the purpose of validation. A panic alarm is also located at the receptionist counter. Customers must present a valid form of identification containing a photograph and date of birth. Acceptable forms of ID include a driver's license, government -issued ID card, military identification card, or a passport. In the event dispensary agents observe suspicious behavior by a customer while at the dispensary, the Dispensary Manager and/or the Director of Security will be notified and no sale will be issued. Immediate notification to the Watertown Police Department shall be made if agents observe behavior indicating suspected diversion. Examples of such behavior include: Customer appears to be under the influence of drugs or alcohol. Customer makes threats. Customer is suspected of attempting to purchase product for anyone that appears to be under the age of 21. Dispensary agents will refuse to dispense to a customer if there is concern the customer or public would be placed at risk. All employees will have company issued photo ID badges, with specific levels of access based on their job description and responsibilities. A "card reader" will control employee access to permissible facility levels. Employees are subjected to a vetting process before employment. No cell phones, cameras or other recording devices are allowed to be used within the facility to take video or photographs. Cell phones will only be allowed for communications purposes. Keltic staff will notify any customer who appears to be taking photographs or video and to cease such behaviors for security reasons. This is a "No Smoking" facility, to include any/all type of electronic inhaling devices. Signage will be posted in the vestibule indicating these restrictions. Level 2 To enter this designated security level, everyone is required to enter through a card access - controlled door. This level requires ALL EMPLOYEES to be displaying a company PHOTO ID Badge and all Vendors/ Contractors to be displaying an ID Badge. All Vendors/Contractors are required to be escorted by a dispensary agent. All outside vendors, contractors, and customers shall always be escorted by a dispensary agent authorized to enter the limited access Level #2 areas to view the product on display. They will be greeted at the door of the lobby, once their valid photo identification has been approved by KELTIC GREEN, INC. - SECURITY PLAN the receptionist. All contractors and vendors will be required to sign in and out, wear a visitor/vendor ID Badge, and always escorted by their designated dispensary agent. This area is open to the general public but limits the access and free movement to other sections of the facility. Members of the general public will be escorted by a Dispensary Agent in order to maintain a controlled environment. This entire area is monitored by CCTV cameras, and motion detectors as outlined in the security drawings. Should note at the "Point of Sale" area (POS) there are Panic Alarms for immediate Emergency Notification to the Watertown Police Department. Wireless panic buttons will also be carried by the on -duty manager and on -site security officers. Level 3 To enter this designated level of access, all person(s) are required to present a Level #3 company issued photo ID access badge which is pre-programmed for Level #3 access. Level #3 is equipped with dual authentication card readers. This is the highest level of security within the facility and limited to those who need to be in the area based on their job description and responsibilities. By equipping the area with Biometrics/keypad reader, this eliminates the possibility of using another person's ID badge to gain access to this area. The area is monitored by CCTV cameras. Entrance/egress from this area is continuously monitored by the CCTV cameras as well as perimeter alarm contact points on the entrance/egress door if it were opened or breached. The alarm points report direct to the Access Control System as well as to a Central Monitoring Station for emergency notification. There are Motion Detectors covering this area as well as one Panic Alarms as outlined in the security drawings. INTERIOR/EXTERIOR CCTV COVERAGE/ALARMS: The interior of the facility has CCTV coverage with the installation of IP video cameras placed in strategic locations as indicated on the Security Plan Drawings. The cameras will have horizontal angle of view with a minimum of 82 degrees, subject facial recognition for 50 feet, and situation awareness for an extended distance within the designated space. A combination of dome, bullet and fisheye cameras will be used throughout the interior of the facility as outlined on the security drawings. The exterior of the facility will be monitored by IP Video cameras. The cameras will cover the entire perimeter and have a varifocal lens, motion detection and tampering alarm. They are environmental for weather conditions, vandal resistant, with Integral IR illumination. KELTIC GREEN, INC. - SECURITY PLAN The strategic locations indicated on the Security Plan, cover all entrances and egress to/from the facility as well as the parking area. Should note that all the entrance and egress doorways also have contact monitoring points reporting back to the Access Control System. Notification is also forwarded to a Central Monitoring Center. All windows are monitored by Glass Break Monitoring Points" and complimented by Motion Detectors as noted on the Security Plan drawings, with video monitoring inclusive to identify unauthorized entry and/or person(s). There are five (5) doors at the facility which can be used as entrance/egress points. Each door has a "Contact Monitoring Point" which is connected to the Access Control System, with each door having a "fixed CCTV" monitoring all entry and exit from the facility. SECURITY ACCESS CONTROLLED SYSTEM LOCATION: The Security Access Controlled System and the Video Management System will be in the office area noted as "IDF" (Intermediate Distribution Frame) room. This room is protected by authorized "Card Access" with limited access and level of security as determined by the Chief of Security. The system operates on the proprietary internet and has cellular back-up in case of emergency. In the event of a power failure the system has a UPS backup sufficient to keep the equipment in this room operational. The system has the ability to record all authorized entries as well as denied entries and intrusion alarms. An audit trail of the system identifies the date, time, door, and person who is granted or denied access. The failure identification system shall notify a Central Monitoring Station, of all panic alarms, perimeter alarms and motion detector alarms, who shall notify a designated Keltic employee within five minutes after a failure either by telephone, e-mail or text message. The Access Control System is password protected and has internal event archiving which is saved indefinitely. The Video Management System will store video for a minimum of 90 days. All photos are date and time stamped, can be printed, or exported still images via.jpg.bmp, and .gif. Cameras have been placed in all areas that contain marijuana, at all entry/exit points and the parking areas. The cameras will be directed to monitor all safes, vaults, and areas where marijuana is processed, prepared, stored, handled, dispensed or transported. The cameras will capture a clear and certain identification of any person(s) entering or exiting the Dispensary. The failure identification system shall notify a Central Monitoring Station of any failure in the video surveillance system. KELTIC GREEN, INC. - SECURITY PLAN LIGHTING: The outside perimeter of the facility along with any parking areas will be sufficiently lit to facilitate video surveillance and safety for staff and visitors. SECURITY SYSTEM MONITORING BY THE POLICE DEPARTMENT: If requested, the Watertown Police Department will have the ability to access the Video Management System to monitor any activities inside or outside of the facility in real time. TRANSPORTATION PROCEDURES: Our transportation procedures will meet or exceed all Cannabis Control Commission regulatory requirements. Agents transporting marijuana or marijuana products to Keltic will: • Weigh, inventory, and account for on video all marijuana to be transported prior to it leaving the origination location; • Re -weigh, re -inventory, and account for on video all marijuana transported, within eight hours after arrival at the Watertown Dispensary. • Document and report any unusual discrepancy in weight or inventory to the CCC and Watertown Police Department within twenty-four (24) hours; • Complete a shipping manifest in a form and manner determined by the CCC, for retention by the origination location, and carry a copy of said manifest with the products being transported; and • Securely transmit a copy of the manifest to the Watertown Dispensary prior to transport. During transport, at least one (1) courier will remain with the vehicle at all times when the vehicle contains marijuana. Transportation shall be made in unmarked delivery vehicles at the rear door of the facility using the designated access route during daylight hours. Onsite security will assist with maintaining visual surveillance of the area during transport. For transportation: • Routes are randomized. • Times will not set up on a weekly timed schedule, and for security reasons, the days of the week and times are randomized to thwart any possibility of robbery. KELTIC GREEN, INC. - SECURITY PLAN • Prior to arrival of the transportation vehicle to the facility, on- site security will conduct a visual sweep of the rear of the building to ensure there are no suspicious individuals/vehicles loitering in that area. Immediate notification to the Watertown Police Department shall be made if any suspicious person or vehicle is observed. ONSITE SECURITY PERSONNEL: The facility will be staffed with a minimum of (1) onsite uniformed security agent during all hours of operation. If requested by the Watertown Police Department, additional security may include a local police detail. NO CONSUMPTION OF MARIJUANA: Consumption of marijuana products inside and outside of the facility is strictly prohibited by Keltic's policies and by Massachusetts law. Appropriate signage shall be placed inside of the Dispensary lobby and exit areas notifying patrons of this. Onsite Security personnel shall patrol the facility exterior and parking lot, to include the exterior parking area, during all hours of operation to ensure compliance. Any patron observed violating this policy shall be requested to cease and leave the property. The Watertown Police Department shall be immediately notified whenever any unlawful consumption or suspected diversion is occurring on or around the property. Identified violators shall be added to a "Banned Customer List" through our electronic ID verification system. CROWD CONTROL/TRAFFIC MEASURES: Keltic shall work closely with the Watertown Police Department to develop a plan for crowd/traffic management upon opening and for as long as necessary thereafter. A Watertown Police detail will be hired as necessary to assist with monitoring any potential "queuing" or loitering outside of the facility along with assisting with parking/traffic control. It is important to note that the dispensary vestibule has been expanded to accommodate more customers inside and minimize any line queuing outside the dispensary. Keltic will also implement an appointment only system upon opening along with offering a pre-order/pickup system to assist with reducing wait times and expediting customer sales. PREVENTION OF DIVERSION: Keltic staff members shall be trained to prevent loitering and ensure that only individuals engaging in activity expressly permitted by regulations are allowed to remain on the premises. Staff KELTIC GREEN, INC. - SECURITY PLAN members shall contact the police if they observe suspicious individuals in person or on camera loitering outside the premises. Examples would include; someone who appears to be under the influence of alcohol or drugs; a group of younger people approaching the area of the premises, but only one person enters to purchase marijuana. Such observations could indicate the potential diversion of marijuana to persons less than 21 years of age. If such observations are made, staff members shall notify the dispensary manager, police officer on detail or call the business line of the police department to investigate. VISIBILITY OF MARIJUANA PRODUCTS: No marijuana or marijuana products will be visible from outside of the facility. INCIDENT REPORTING: Green will immediately notify law enforcement authorities of any security breach including, but not limited to, discovery of discrepancies identified during inventory, diversion or loss of marijuana products, any loss or unauthorized alteration of records related to marijuana, suspicious actions within the marijuana establishment, failure of an alarm system, activation of an alarm system, or any criminal acts. Keltic Green will provide written notice to the Commission within ten calendar days of any incident that occurs on the premises. Keltic will maintain records and documentation of any security incident for at least one year. KELTIC GREEN, INC. - SECURITY PLAN vq.ptr KELTIC TRANSPORTATION OF MARIJUANA General Overview Keltic Green, Inc. ("Keltic") will ensure that all transported marijuana and products are properly tracked through seed -to -sale tracking software. Keltic will properly track and label all marijuana and marijuana products in the form and manner deemed acceptable by the Commission. Keltic will only transport marijuana from licensed facilities to other licensed Marijuana Establishments as permitted by Keltic's license. There will be no advertising, marketing or branding, including, but not limited to, vinyl -wrapped vehicles, signs, logos or markings, indicating that the vehicle is being used to transport marijuana on transportation vehicles or company cars. In the event that any marijuana product is undeliverable or refused by the destination, Keltic or its supplier will ensure that it will be transported back to Keltic's originating distribution facility. Keltic will staff all vehicles transporting marijuana and marijuana products with at least two Keltic agents, one of whom will remain in the vehicle at all times that the vehicle contains marijuana or marijuana products. Prior to departing the premises to transport marijuana products, Keltic will make a video record of weighing, inventorying, and accounting for all marijuana products to be transported. When receiving transported marijuana, within eight hours after arrival, Keltic will re -weigh, re - inventory, and account for, on video, all marijuana and marijuana products received. When videotaping the weighing, inventorying, and accounting of marijuana and marijuana products before transportation or after receipt, Keltic will ensure that the video shows each product being weighed, the weight, and the manifest. Prior to departure from a distribution facility, Keltic's supplier(s) will package marijuana and marijuana products in sealed, labeled, and tamper -resistant or child -resistant packaging, and ensure that marijuana and marijuana products remain as such during transportation. All vehicles and transportation equipment used in the transportation of marijuana products requiring temperature control for safety must be designed, maintained, and equipped as necessary KELTIC GREEN, INC. - TRANSPORTATION OF MARIJUANA to provide adequate temperature control to prevent the marijuana or marijuana products from becoming unsafe during transportation, consistent with applicable requirements pursuant to 21 CFR 1.908(c). Any vehicle used to transport marijuana or marijuana products will be owned or leased by Keltic or a marijuana transporter, will be properly registered, inspected and insured in the Commonwealth, and equipped with an alarm system. In the case of an emergency stop during the transportation of marijuana or marijuana products, Keltic will maintain a log describing the reason for the stop, the duration of the stop, the location of the stop, and any activities of its personnel exiting the vehicle. Keltic will ensure that all routes used for the transportation of marijuana or marijuana products are randomized and remain within the Commonwealth. Storage Requirements Keltic will transport marijuana and marijuana products in secure, locked storage compartments that are a part of the vehicle transporting the marijuana products and cannot be easily removed. Storage and transportation of finished products will be under conditions that will protect them against physical, chemical, and microbial contamination, while also protecting against deterioration of finished products or their containers. Marijuana and marijuana products will not be visible from the outside of the vehicle. If and when Keltic transports marijuana or marijuana products to more than one Marijuana Establishment at a time, the marijuana and marijuana products for each marijuana establishment will be kept in a separate locked storage compartment during transportation, and separate manifests will be maintained for each marijuana establishment. If and when Keltic is transporting marijuana and marijuana products to multiple marijuana establishments, Keltic will obtain permission from the Commission to adopt reasonable alternative safeguards. When transporting marijuana and marijuana products, no other products will be transported or stored in the vehicle nor will firearms be located in the vehicle or on transporting agents. Communications Any vehicle used by Keltic to transport marijuana and marijuana products will contain a global positioning system (GPS) monitoring device that is: 1) not a mobile device that is easily removable; 2) attached to the vehicle at all times that the vehicle contains marijuana and marijuana products; and 3) monitored by Keltic during transport of marijuana and marijuana products. Keltic will obtain an inspection from the Commission prior to initial transportation of marijuana and marijuana products and after any alteration to the locked storage compartment. Each Keltic agent transporting marijuana products will have access to a secure form of communication with personnel at Keltic at all times that the vehicle contains marijuana and marijuana products. Keltic will utilize either two-way digital or analog radio, cellular phones, or satellite phones for these purposes dependent upon the transportation area, base capabilities, cellular signal coverage, antenna coverage, and frequency of transportation. KELTIC GREEN, INC. - TRANSPORTATION OF MARIJUANA Prior to and immediately after leaving Keltic's premises, Keltic agents will be required to use a secure form of communication to contact agents at the Keltic facility to test communications and GPS operability. In the event that communications or the GPS system fail while on route, the Keltic agents transporting marijuana or marijuana products must return to the originating Keltic location until the communication system or GPS system is once again operational. Marijuana establishment agents transporting marijuana or marijuana products will be required to contact the Keltic facility when stopping at and leaving any scheduled location, and regularly throughout the trip, at least every 30 minutes. Keltic will ensure that there is a Keltic agent assigned to monitoring the GPS unit and secure form of communication, who will be required to log all official communications with marijuana establishment agents transporting marijuana products. All manifests used in the transportation of marijuana will be filled out Keltic agents in triplicate, with the original manifest remaining with Keltic, a second copy provided to the destination marijuana establishment upon arrival, and a copy to be kept with the Keltic agent during transportation and returned to the marijuana establishment or marijuana transporter upon completion of the transportation. Keltic will securely transmit the manifest to the destination marijuana establishment via facsimile or email prior to departure. Upon arrival at the destination marijuana establishment, Keltic's agents will compare the manifest produced by a Keltic agent and the copy transmitted by facsimile or email to the destination marijuana establishment. Each manifest will include, at a minimum, the originating marijuana establishment name, address, and registration number; the names and registration numbers of the agents who transported the marijuana products; the name and registration number of the marijuana establishment agent who prepared the manifest; the destination marijuana establishment name, address, and registration number; a description of the marijuana and marijuana products being transported, including the weight and form or type of the product; the mileage of the transporting vehicle at departure from Keltic and mileage upon arrival at destination marijuana establishment, as well as mileage upon return to Keltic; the date and time of departure from Keltic Green and arrival at destination marijuana establishment for each transportation; a signature line for the marijuana establishment agent who receives the marijuana products; the weight and inventory before departure and upon receipt; the date and time that the transported products were re -weighed and re -inventoried; the name of the marijuana establishment agent at the destination marijuana establishment who re -weighed and re -inventoried products; and the vehicle make, model, and license plate number. Keltic will maintain the manifest inside of its vehicle throughout the entire transportation process until delivery is complete. All transportation manifests will be retained by Keltic for a minimum of one year and will be available for inspection by the Commission upon request. KELTIC GREEN, INC. - TRANSPORTATION OF MARIJUANA Should any unusual discrepancy occur in weight or inventory, Keltic agents will document and report the discrepancy to the Commission and law enforcement authorities not more than 24 hours after the discovery of such a discrepancy. Keltic agents will report to the Commission and law enforcement authorities any vehicle accidents, diversions, losses, or other reportable incidents that occur during transport, not more than 24 hours after such accidents, diversions, losses, or other reportable incidents. Each agent transporting or otherwise handling marijuana or marijuana products for Keltic will be registered as a marijuana establishment agent and have a driver's license in good standing issued by the Massachusetts Registry of Motor Vehicles for all classes of vehicle the marijuana establishment agent will operate for Keltic prior to transporting or otherwise handling Keltic's marijuana or marijuana products. All Keltic agents will carry their registration cards at all times when transporting marijuana or marijuana products for Keltic and will produce their registration card to the Commission or law enforcement officials upon request. Keltic will use best management practices to reduce energy and water usage, engage in energy conservation, and mitigate other environmental impacts wherever possible. Representatives of the Commission, other Commonwealth agencies, and emergency responders responding in the course of an emergency will have access to all Keltic transportation vehicles as necessary. KELTIC GREEN, INC. - TRANSPORTATION OF MARIJUANA vq.ptr KELTIC TRANSPORTATION OF MARIJUANA General Overview Keltic Green, Inc. ("Keltic") will ensure that all transported marijuana and products are properly tracked through seed -to -sale tracking software. Keltic will properly track and label all marijuana and marijuana products in the form and manner deemed acceptable by the Commission. Keltic will only transport marijuana from licensed facilities to other licensed Marijuana Establishments as permitted by Keltic's license. There will be no advertising, marketing or branding, including, but not limited to, vinyl -wrapped vehicles, signs, logos or markings, indicating that the vehicle is being used to transport marijuana on transportation vehicles or company cars. In the event that any marijuana product is undeliverable or refused by the destination, Keltic or its supplier will ensure that it will be transported back to Keltic's originating distribution facility. Keltic will staff all vehicles transporting marijuana and marijuana products with at least two Keltic agents, one of whom will remain in the vehicle at all times that the vehicle contains marijuana or marijuana products. Prior to departing the premises to transport marijuana products, Keltic will make a video record of weighing, inventorying, and accounting for all marijuana products to be transported. When receiving transported marijuana, within eight hours after arrival, Keltic will re -weigh, re - inventory, and account for, on video, all marijuana and marijuana products received. When videotaping the weighing, inventorying, and accounting of marijuana and marijuana products before transportation or after receipt, Keltic will ensure that the video shows each product being weighed, the weight, and the manifest. Prior to departure from a distribution facility, Keltic's supplier(s) will package marijuana and marijuana products in sealed, labeled, and tamper -resistant or child -resistant packaging, and ensure that marijuana and marijuana products remain as such during transportation. All vehicles and transportation equipment used in the transportation of marijuana products requiring temperature control for safety must be designed, maintained, and equipped as necessary KELTIC GREEN, INC. - TRANSPORTATION OF MARIJUANA to provide adequate temperature control to prevent the marijuana or marijuana products from becoming unsafe during transportation, consistent with applicable requirements pursuant to 21 CFR 1.908(c). Any vehicle used to transport marijuana or marijuana products will be owned or leased by Keltic or a marijuana transporter, will be properly registered, inspected and insured in the Commonwealth, and equipped with an alarm system. In the case of an emergency stop during the transportation of marijuana or marijuana products, Keltic will maintain a log describing the reason for the stop, the duration of the stop, the location of the stop, and any activities of its personnel exiting the vehicle. Keltic will ensure that all routes used for the transportation of marijuana or marijuana products are randomized and remain within the Commonwealth. Storage Requirements Keltic will transport marijuana and marijuana products in secure, locked storage compartments that are a part of the vehicle transporting the marijuana products and cannot be easily removed. Storage and transportation of finished products will be under conditions that will protect them against physical, chemical, and microbial contamination, while also protecting against deterioration of finished products or their containers. Marijuana and marijuana products will not be visible from the outside of the vehicle. If and when Keltic transports marijuana or marijuana products to more than one Marijuana Establishment at a time, the marijuana and marijuana products for each marijuana establishment will be kept in a separate locked storage compartment during transportation, and separate manifests will be maintained for each marijuana establishment. If and when Keltic is transporting marijuana and marijuana products to multiple marijuana establishments, Keltic will obtain permission from the Commission to adopt reasonable alternative safeguards. When transporting marijuana and marijuana products, no other products will be transported or stored in the vehicle nor will firearms be located in the vehicle or on transporting agents. Communications Any vehicle used by Keltic to transport marijuana and marijuana products will contain a global positioning system (GPS) monitoring device that is: 1) not a mobile device that is easily removable; 2) attached to the vehicle at all times that the vehicle contains marijuana and marijuana products; and 3) monitored by Keltic during transport of marijuana and marijuana products. Keltic will obtain an inspection from the Commission prior to initial transportation of marijuana and marijuana products and after any alteration to the locked storage compartment. Each Keltic agent transporting marijuana products will have access to a secure form of communication with personnel at Keltic at all times that the vehicle contains marijuana and marijuana products. Keltic will utilize either two-way digital or analog radio, cellular phones, or satellite phones for these purposes dependent upon the transportation area, base capabilities, cellular signal coverage, antenna coverage, and frequency of transportation. KELTIC GREEN, INC. - TRANSPORTATION OF MARLTUANA Prior to and immediately after leaving Keltic's premises, Keltic agents will be required to use a secure form of communication to contact agents at the Keltic facility to test communications and GPS operability. In the event that communications or the GPS system fail while on route, the Keltic agents transporting marijuana or marijuana products must return to the originating Keltic location until the communication system or GPS system is once again operational. Marijuana establishment agents transporting marijuana or marijuana products will be required to contact the Keltic facility when stopping at and leaving any scheduled location, and regularly throughout the trip, at least every 30 minutes. Keltic will ensure that there is a Keltic agent assigned to monitoring the GPS unit and secure form of communication, who will be required to log all official communications with marijuana establishment agents transporting marijuana products. All manifests used in the transportation of marijuana will be filled out Keltic agents in triplicate, with the original manifest remaining with Keltic, a second copy provided to the destination marijuana establishment upon arrival, and a copy to be kept with the Keltic agent during transportation and returned to the marijuana establishment or marijuana transporter upon completion of the transportation. Keltic will securely transmit the manifest to the destination marijuana establishment via facsimile or email prior to departure. Upon arrival at the destination marijuana establishment, Keltic's agents will compare the manifest produced by a Keltic agent and the copy transmitted by facsimile or email to the destination marijuana establishment. Each manifest will include, at a minimum, the originating marijuana establishment name, address, and registration number; the names and registration numbers of the agents who transported the marijuana products; the name and registration number of the marijuana establishment agent who prepared the manifest; the destination marijuana establishment name, address, and registration number; a description of the marijuana and marijuana products being transported, including the weight and form or type of the product; the mileage of the transporting vehicle at departure from Keltic and mileage upon arrival at destination marijuana establishment, as well as mileage upon return to Keltic; the date and time of departure from Keltic Green and arrival at destination marijuana establishment for each transportation; a signature line for the marijuana establishment agent who receives the marijuana products; the weight and inventory before departure and upon receipt; the date and time that the transported products were re -weighed and re -inventoried; the name of the marijuana establishment agent at the destination marijuana establishment who re -weighed and re -inventoried products; and the vehicle make, model, and license plate number. Keltic will maintain the manifest inside of its vehicle throughout the entire transportation process until delivery is complete. All transportation manifests will be retained by Keltic for a minimum of one year and will be available for inspection by the Commission upon request. KELTIC GREEN, INC. - TRANSPORTATION OF MARLTUANA Should any unusual discrepancy occur in weight or inventory, Keltic agents will document and report the discrepancy to the Commission and law enforcement authorities not more than 24 hours after the discovery of such a discrepancy. Keltic agents will report to the Commission and law enforcement authorities any vehicle accidents, diversions, losses, or other reportable incidents that occur during transport, not more than 24 hours after such accidents, diversions, losses, or other reportable incidents. Each agent transporting or otherwise handling marijuana or marijuana products for Keltic will be registered as a marijuana establishment agent and have a driver's license in good standing issued by the Massachusetts Registry of Motor Vehicles for all classes of vehicle the marijuana establishment agent will operate for Keltic prior to transporting or otherwise handling Keltic's marijuana or marijuana products. All Keltic agents will carry their registration cards at all times when transporting marijuana or marijuana products for Keltic and will produce their registration card to the Commission or law enforcement officials upon request. Keltic will use best management practices to reduce energy and water usage, engage in energy conservation, and mitigate other environmental impacts wherever possible. Representatives of the Commission, other Commonwealth agencies, and emergency responders responding in the course of an emergency will have access to all Keltic transportation vehicles as necessary. KELTIC GREEN, INC. - TRANSPORTATION OF MARLTUANA BYLAWS OF Keltic Green Inc. BYLAWS OF Keltic Green Inc. ARTICLE I: GENERAL Section 1.01 Name and Purposes. The name of the Corporation is KELTIC GREEN INC. (the "Corporation"). The purpose of the Corporation shall be as set forth in the Corporation's Articles of Organization as adopted and filed with the Office of the Secretary of State of the Commonwealth of Massachusetts (as now in effect or as hereafter amended or restated from time to time, the "Articles of Organization") pursuant to Chapter 156D of the Massachusetts General Laws, as now in effect and as hereafter amended, or the corresponding provision(s) of any future Massachusetts General Law ("Chapter 1561)"). Section 1.02 Articles of Organization. These Bylaws ("Bylaws"), the powers of the Corporation and its shareholders and Board of Directors, and all matters concerning the conduct and regulation of the business of the Corporation, shall be subject to the provisions in regard thereto that may be set forth in the Articles of Organization. In the event of any conflict or inconsistency between the Articles of Organization and these Bylaws, the Articles of Organization shall control. Section 1.03 Corporate Seal. The Board of Directors may adopt and alter the seal of the Corporation. The seal of the Corporation, if any, shall, subject to alteration by the Board of Directors, bear its name, the word "Massachusetts" and the year of its incorporation. Section 1.04 Fiscal Year. The fiscal year of the Corporation shall commence on January 1, and end on the following December 31 of each year, unless otherwise determined by the Board of Directors. Section 1.05 Location of Principal Office of the Corporation. The principal office of the Corporation shall be located at such place within the Commonwealth of Massachusetts as shall be fixed from time to time by the Board of Directors, and if no place is fixed by the Board of Directors, such place as shall be fixed by the President. ARTICLE II: SHAREHOLDERS Section 2.01 Place of Meeting. Meetings of the shareholders shall be held at anyplace within or without the Commonwealth of Massachusetts that may be designated by the Board of Directors. Absent such designation, meetings shall be held at the principal office. The Board of Directors may, in its discretion, determine that the meeting may be held solely by means of remote electronic communication. If authorized by the Board of Directors, and subject to any guidelines and procedures adopted by the Board of Directors, shareholders not physically present at a meeting of shareholders, may participate in a meeting of shareholders by means of electronic transmission by and to the Corporation or electronic video screen communication; and, may be considered present in person and may vote at a meeting of shareholders, whether held at a designated place or held solely by means of electronic transmission by and to the Corporation or electronic video screen communication, subject to the conditions imposed by applicable law. Section 2.02 Annual Meeting. The annual meeting of shareholders of this Corporation shall be held on such date and at such time as may be designated from time to time by the Board BYLAWS II KELTIC GREEN INC. PAGE 1 OF 15 of Directors. At the annual meeting, Directors shall be elected, and any other business may be transacted that is within the power of the shareholders and allowed by law; provided, however, that unless the notice of meeting, or the waiver of notice of such meeting, sets forth the general nature of any proposal to (i) approve or ratify a contract or transaction with a Director or with a corporation, firm or association in which a Director has an interest; (ii) amend the Articles of Organization of this Corporation; (iii) approve a reorganization or merger involving this Corporation; (iv) elect to wind up and dissolve this Corporation; or (v) effect a plan of distribution upon liquidation otherwise than in accordance with the liquidation preferences of outstanding shares with liquidation preferences, no such proposal may be approved at an annual meeting. Section 2.03 Special Shareholders' Meetings. Special meetings of the shareholders, for any purpose whatsoever, may be called at any time by the President, the Board of Directors or by shareholders entitled to cast not less than ten percent (10%) of the corporation's voting power. Any person entitled to call a special meeting of shareholders (other than the Board of Directors) may make a written request to the Chair of the Board (if any), President, Vice President (if any) or Secretary, specifying the general purpose of such meeting and the date, time and place of the meeting, which date shall be not less than fifteen (15) days nor more than sixty (60) days after the receipt by such officer of the request. Within twenty (20) days after receipt of the request, the officer receiving such request forthwith shall cause notice to be given to the shareholders entitled to vote at such meeting, stating that a meeting will be held on the date and at the time and place requested by the person or persons requesting a meeting and stating the general purpose of the meeting. If such notice is not given twenty (20) days after receipt by the officer of the request, the person or persons requesting the meeting may give such notice. No business shall be transacted at a special meeting unless its general nature shall have been specified in the notice of such meeting; provided, however, that any business may be validly transacted if the requirements for such validity, as provided in Section 2.12 of these Bylaws, are met. Section 2.04 Shareholder Nominations and Proposals. For business (including, but not limited to Director nominations) to be properly brought before an annual or special meeting by a shareholder, the shareholder or shareholders of record intending to propose the business (the "Proposing Shareholder") must have given written notice of the Proposing Shareholder's nomination or proposal, either by personal delivery or by the United States mail to the Secretary of the Corporation. In the case of an annual meeting, the Proposing Shareholder must give such notice to the Secretary of the Corporation no earlier than one hundred and twenty (120) calendar days and no later than ninety (90) calendar days before the date such annual meeting is to be held. If the current year's meeting is called for a date that is not within thirty (30) days of the anniversary of the previous year's annual meeting, notice must be received not later than ten (10) calendar days following the day on which public announcement of the date of the annual meeting is first made. In no event will an adjournment or postponement of an annual meeting of shareholders begin a new time period for giving a Proposing Shareholder's notice as provided above. For business to be properly brought before a special meeting of shareholders, the notice of meeting sent by or at the direction of the person calling the meeting must set forth the nature of the business to be considered. A shareholder or shareholders who have made a written request for a special meeting pursuant to Section 2.03 of these Bylaws may provide the information required for notice of a shareholder proposal under this Section 2.04 simultaneously with the written request for the BYLAWS II KELTIC GREEN INC. PAGE 2 OF 15 meeting submitted to the Secretary or within ten (10) calendar days after delivery of the written request for the meeting to the Secretary. A Proposing Shareholder's notice shall include as to each matter the Proposing Shareholder proposes to bring before either an annual or special meeting: (a) The name(s) and address(es) of the Proposing Shareholder(s). (b) The classes and number of shares of capital stock of the Corporation held by the Proposing Shareholder. (c) If the notice regards the nomination of a candidate for election as Director: (i) The name, age, business and residence address of the candidate; (ii) The principal occupation or employment of the candidate; and (iii) The class and number of shares of the Corporation beneficially owned by the candidate. (d) If the notice is in regard to a proposal other than a nomination of a candidate for election as Director, a brief description of the business desired to be brought before the meeting and the material interest of the Proposing Shareholder of such proposal. Section 2.05 Notice of Shareholders' Meeting. Except as otherwise provided by law, written notice stating the place, day and hour of the meeting, and, in case of a special meeting, the nature of the business to be transacted at the meeting, shall be given at least ten (10) days and not more than sixty (60) days before the meeting. In the case of an annual meeting, notice will include matters the Corporation's Board of Directors intends, at the time of the giving of the first of such notices, to present to the shareholders for action, and in the case of a meeting at which Directors are to be elected, the names of nominees that the Board of Directors, at the time of the giving of the first of such notices, intends to present to the shareholders for election. Proof that notice was given shall be made by affidavit of the Secretary, assistant Secretary, transfer agent or Director, or of the person acting under the direction of any of the foregoing, who gives such notice, and such proof of notice shall be made part of the minutes of the meeting. Such affidavit shall be prima facie evidence of the giving of such notice. It shall not be necessary to state in a notice of any meeting of shareholders as a purpose thereof any matter relating to the procedural aspects of the conduct of such meeting. Notice shall be given personally, by electronic transmission or by mail, by or at the direction of the Secretary, or the officer or person calling the meeting, to each shareholder entitled to vote at the meeting. If remote participation in the meeting has been authorized by the Board of Directors, the notice shall also provide a description of the means of any electronic transmission by and to the Corporation or electronic video screen communication by which shareholders may be considered present and may vote and otherwise participate at the meeting. If mailed, the notice shall be deemed to be given when deposited in the United States mail addressed to the shareholder at the shareholder's address as it appears on the share transfer records BYLAWS II KELTIC GREEN INC. PAGE 3 OF 15 of the Corporation, with postage thereon prepaid. Notice may be given to the shareholder by electronic transmission. Notice by electronic transmission is deemed given when the notice satisfies any of the following requirements: (a) Transmitted to a facsimile number provided by the shareholder for the purpose of receiving notice. (b) Transmitted to an electronic mail address provided by the shareholder for the purpose of receiving notice. (c) Posted on an electronic network, with a separate notice sent to the shareholder at the address provided by the shareholder for the purpose of alerting the shareholder of a posting. (d) Communicated to the shareholder by any other form of electronic transmission consented to by the shareholder. Notice shall not be given by electronic transmission to a shareholder after either (i) the Corporation is unable to deliver two (2) consecutive notices to such shareholder by such means or (ii) the inability to deliver such notices to such shareholder becomes known to any person responsible for giving such notices. Any person entitled to notice of a meeting may file a written waiver of notice with the Secretary either before or after the time of the meeting. The participation or attendance at a meeting of a person entitled to notice constitutes waiver of notice, except where the person objects, at the beginning of the meeting, to the lawfulness of the convening of the meeting and except that attendance is not a waiver of any right to object to conducting business at a meeting that is required to be included in the notice of the meeting, but not so included. Section 2.06 Reserved Section 2.07 Fixing the Record Date. For the purpose of determining shareholders entitled to notice of or to vote at any meeting of shareholders or any adjournment thereof, the record date shall be the date specified by the Board of Directors in the notice of the meeting. If no date is specified by the Board of Directors, the record date shall be the close of business on the day before the notice of the meeting is mailed to shareholders. If no notice is sent, the record date shall be the date set by the law applying to the type of action to be taken for which a record date must be set. In the case of action by written consent of the shareholders without a meeting, the record date shall be (a) the date fixed by the board of directors or (b) the date that the first shareholder signs the written consent if no date has been fixed by the board. A record date fixed under this Section may not be more than seventy (70) days before the meeting or action requiring a determination of shareholders. A determination of shareholders entitled to notice of or to vote at a shareholders' meeting is effective for any adjournment of the meeting unless the Board of Directors fixes a new record date. Section 2.08 Quorum of and Action by Shareholders. A quorum shall be present for action on any matter at a shareholder meeting if a majority of the votes entitled to be cast on the BYLAWS II KELTIC GREEN INC. PAGE 4 OF 15 matter by a voting group is represented at the meeting in person or by proxy. A voting group includes all shares of one (1) or more classes or series that are entitled, by law or the Articles of Organization, to vote and to be counted together collectively on a matter at a meeting of shareholders. Once a quorum for a voting group has been established at a meeting, the shareholders in that voting group represented in person or by proxy at the meeting are deemed present for quorum purposes for the remainder of the meeting and for any adjournment unless: a. The shareholder attends the meeting solely to object to defective notice or the conduct of the meeting on other grounds and does not vote the shares or take any other action at the meeting. b. The meeting is adjourned and a new record date is set for the adjourned meeting. The shareholders in a voting group represented in person or by proxy at a meeting of shareholders, even if not comprising a quorum, may adjourn the meeting as to the voting group until a time and place as may be determined by a vote of the holders of a majority of the shares of the voting group represented in person or by proxy at that meeting. If the meeting is adjourned for more than one hundred and twenty (120) days after the date fixed for the original meeting, a new record date must be fixed by the Board of Directors; notice of the meeting must be given to the shareholders who are members of the voting group as of the new record date, and a new quorum for the meeting must be established. Section 2.09 Reserved Section 2.10 Conduct of Meetings. The Board of Directors may adopt by resolution rules and regulations for the conduct of meetings of the shareholders as it shall deem appropriate. At every meeting of the shareholders, the President, or in his or her absence or inability to act, a Director or officer designated by the Board of Directors, shall serve as the presiding officer. The Secretary or, in his or her absence or inability to act, the person whom the presiding officer of the meeting shall appoint secretary of the meeting, shall act as secretary of the meeting and keep the minutes thereof. The presiding officer shall determine the order of business and, in the absence of a rule adopted by the Board of Directors, shall establish rules for the conduct of the meeting. The presiding officer shall announce the close of the polls for each matter voted upon at the meeting, after which no ballots, proxies, votes, changes or revocations will be accepted. Polls for all matters before the meeting will be deemed to be closed upon final adjournment of the meeting. Section 2.11 Voting of Shares. Unless otherwise provided by law or in the Articles of Organization, each shareholder entitled to vote is entitled to one (1) vote for each share of common stock. Any holder of shares entitled to vote on any matter may vote part of such shares in favor of the proposal and refrain from voting the remaining shares or vote them against the proposal. If a shareholder fails to specify the number of shares such shareholder is voting affirmatively, it will be conclusively presumed that the shareholder's approving vote is with respect to all shares such shareholder is entitled to vote. BYLAWS II KELTIC GREEN INC. PAGE 5 OF 15 Section 2.12 Consent of Absentees. The transactions of any meeting of shareholders, however called or noticed, are as valid as though had at a meeting duly held after regular call and notice, if a quorum is present either in person or by proxy, and if, either before or after the meeting, each of the persons entitled to vote, not present in person or by proxy, signs a written waiver of notice, or a consent to the holding of such meeting, or an approval of the minutes thereof. The waiver notice, or consent need not specify the business transacted or purpose of the meeting, except as required by Chapter 156D. All such waivers, consents or approvals shall be filed with the corporate records or made a part of the minutes of the meeting. Section 2.13 Voting by Proxy or Nominee. Every person entitled to vote or execute consents may do so either in person or by one (1) or more agents authorized by a written proxy executed by the person or such person's duly authorized agent and filed with the Secretary of the Corporation. A proxy is not valid after the expiration of eleven (11) months from the date of its execution, unless the person executing it specifies therein the length of time for which it is to continue in force. Except as set forth below, any proxy duly executed is not revoked, and continues in full force and effect, until an instrument revoking it, or a duly executed proxy bearing a later date, executed by the person executing the prior proxy and presented to the meeting, is filed with the Secretary of the Corporation, or unless the person giving the proxy attends the meeting and votes in person, or unless written notice of the death or incapacity of the person executing the proxy is received by the Corporation before the vote by such proxy is counted. A proxy that states on its face that it is irrevocable will be irrevocable for the period of time specified in the proxy, if held by a person (or nominee of a person) specified by law to have sufficient interest to make such proxy irrevocable and only so long as he shall have such interest, subject to Chapter 156D, § 7.22. Section 2.14 Action by Shareholders Without a Meeting. Any action, that, under any provision of Chapter 156D may be taken at a meeting of the shareholders, may be taken without a meeting and without prior notice if a consent in writing, setting forth the action so taken, shall be signed by the holders of the outstanding shares having not less than the minimum number of votes that would be necessary to authorize or take such action at a meeting at which all shares are entitled to vote thereon were present and voted; provided, however, that unless the consents of all shareholders entitled to vote have been solicited in writing, notice shall be given (in the same manner as notice of meetings is to be given), and within the time limits prescribed by law, of such action to all shareholders entitled to vote who did not consent in writing to such action; and provided, further, that Directors may be elected by written consent only if such consent is unanimously given by all shareholders entitled to vote, except that action taken by shareholders to fill one (1) or more vacancies on the Board other than a vacancy created by the removal of a Director, may be taken by written consent of a majority of the outstanding shares entitled to vote. Section 2.15 Automatic Divestiture. If, during anytime while the Corporation holds a local or state marijuana business license, any of the following occur to a shareholder or to a member of an entity that is a shareholder of the Corporation, all interests of that shareholder in the Corporation (the "Affected Shareholder") will automatically and immediately terminate, and the Affected Shareholder will cease to be a shareholder: (a) The Affected Shareholder is charged with or convicted of any criminal offense, if a conviction of the offense in question would, pursuant to the applicable laws and regulations, disqualify the Affected Shareholder from having an ownership interest in BYLAWS II KELTIC GREEN INC. PAGE 6 OF 15 a marijuana business; however, where an Affected Shareholder is only charged with a criminal offense and not convicted, and where the applicable cannabis regulatory body and any other local or state licensing authority upon request have agreed to defer pursuing any action against the Corporation's marijuana business license(s) based upon such charges, or where any such actions of the applicable cannabis regulatory body and local licensing authorities are subject to a stay order, then the Affected Shareholder's shares shall not be subject to divestiture under this Section 2.15; (b) The Affected Shareholder or any entity that it owns or controls incurs a revocation of any Massachusetts marijuana business license, and it is determined by the Board that such revocation has a material adverse effect upon the issuance or continued good standing of the Corporation's marijuana business license; (c) The applicable cannabis regulatory body or local licensing authority issues a formal recommendation stating that the Affected Shareholder is unfit to have an ownership or economic interest in a marijuana business; (d) The applicable cannabis regulatory body or local licensing authority issues a formal recommendation against the issuance to the Corporation of a marijuana business license or revokes a marijuana business license, which recommendation cites the participation of the Affected Shareholder as a material factor in the decision, or the applicable cannabis regulatory body or local licensing authority conditions the issuance of a marijuana business license on the Corporation removing the Affected Shareholder in the Corporation; (e) The applicable cannabis regulatory body or local licensing authority advises the Corporation in writing, or it is otherwise determined by court order, that a decision on the Corporation's marijuana business license is being delayed beyond one (1) year following the filing of the Corporation's application for a marijuana business license, and the Corporation is advised before or after said date that the sole reason for such delay is the participation of or concerns about the Affected Shareholder; (f) The Affected Shareholder demonstrates a repeated failure to attend meetings with the applicable cannabis regulatory body or any local licensing authority as required for Corporation business to be conducted. As used herein, repeated failure to attend shall be demonstrated by failure to attend any meeting without good cause, or any two (2) meetings with any licensing authority. (g) The Affected Shareholder fails to provide information to the applicable cannabis regulatory body which is requested by or required by the applicable cannabis regulatory body. (h) If the Affected Shareholder is a partnership or other business entity and not a natural person, a member of the Affected Shareholder is disqualified from obtaining an ownership interest in a licensed marijuana business by final written determination of the applicable cannabis regulatory body, unless, unless such member is divested from the Affected Shareholder in a timely manner. BYLAWS II KELTIC GREEN INC. PAGE 7 OF 15 Section 2.16 Redemption of Shares Following Automatic Divestiture. (a) The Corporation shall continue in existence notwithstanding the automatic termination of any Affected Shareholder pursuant to Section 2.15 above. Notwithstanding any provision of this Agreement to the contrary, if the Affected Shareholder is a corporate entity and the occurrence of any of the events enumerated in Section 2.15, above, is due to a member, shareholder, manager, director or officer of the Affected Shareholder, the Affected Shareholder shall have an option to reclaim its shares and shall be restored to its ownership position before the divestiture events occurred if the Board, a court of law or the applicable cannabis regulatory boy provides a written assurance or order that Affected Shareholder has removed the member, shareholder, manager, director or officer that caused any of the events enumerated in Section 2.15, above, pursuant to the terms of the Affected Shareholder's governing documents. (b) The Corporation shall be liable for the terminated ownership interest of the Affected Shareholder as follows: (i) The Corporation and the Affected Shareholder shall determine the fair market value of the Affected Shareholder's shares by a mutually agreed upon third party appraisal. (ii) If the Affected Shareholder and the Corporation cannot agree on a third -party appraisal, they shall both individually choose and pay for their own appraisal and the differences, if any, between the two valuations of the Affected Shareholder's shares shall be averaged and used for calculating the Payoff Note (as defined herein). (iii) Once the value of the Affected Shareholder's shares is determined in relation to the Corporation's fair market value, the Corporation shall deliver a note (the "Payoff Note") to the Affected Shareholder for [fifty percent (50%)] of the asset value of Affected Shareholder's shares. The Payoff Note may be payable over a five (5) year period and may bear interest at a rate equal to the prime rate of interest as announced from time to time by the Wall Street Journal or may be discounted (using the same rate) to present value if an earlier payoff is required under the applicable laws and regulations. The terms of the Payoff Note may include equal monthly payments and shall be reasonable and customary for a transaction of this type. The Corporation may sell the Affected Shareholder's shares, in accordance with the terms of these Bylaws, to finance the Payoff Note or for any other lawful reason. ARTICLE III: DIRECTORS Section 3.01 Number of Directors; Identity of Initial Directors. The authorized number of Directors of the Corporation shall be one (1) until changed by an amendment to these Bylaws duly adopted in accordance with these Bylaws by the vote or written consent of a majority of the outstanding shares entitled to vote. The initial Director shall be Justin Smith. BYLAWS II KELTIC GREEN INC. PAGE 8 OF 15 Section 3.02 Powers. All corporate power shall be exercised by or under the authority of, and the business and affairs of the Corporation shall be managed under the direction of, the Board of Directors, except such powers expressly conferred upon or reserved to the shareholders, and subject to any limitations set forth by law, by the Articles of Organization or by these Bylaws. Section 3.03 Term of Office. Directors shall hold office until the next annual meeting of shareholders and until their successors are elected. Section 3.04 Vacancies and Newly Created Directorships. Vacancies and newly created directorships, whether resulting from an increase in the size of the Board of Directors, from the death, resignation, disqualification or removal of a Director or otherwise, may be filled by election at an annual or special meeting of shareholders called for that purpose or/solely by the affirmative vote of a majority of the remaining Directors then in office, even though less than a quorum of the Board of Directors. A Director elected to fill a vacancy shall be elected for the unexpired term of his or her predecessor in office. Section 3.05 Removal. The Board of Directors may declare vacant the office of a Director who has been declared of unsound mind by an order of the court or convicted of a felony, or who has been barred from ownership of a marijuana business by a final decision of an applicable state or local licensing authority, or otherwise in a manner provided by law. Any or all of the Directors may be removed from office at any duly called meeting without cause by a vote of the shareholders entitled to elect them. If one (1) or more Directors are so removed at a meeting of shareholders, the shareholders may elect new Directors at the same meeting. Section 3.06 Resignation. A Director may resign effective on giving written notice to the President, unless the notice specifies a later effective date. Section 3.07 Meetings of Directors. (a) Regular Meetings. A regular annual meeting of the Board shall be held immediately after, and at the same place as, the annual meeting of shareholders for the purpose of electing officers and transacting any other business. The Board may provide for other regular meetings from time to time by resolution. (b) Special Meetings. Special meetings of the Board for any purpose or purposes may be called at any time by the President, Vice President (if any), Chairman of the Board, the Secretary, by any two (2) Directors or by one (1) Director in the event that there is only one (1) Director. Notice of the time and place of special meetings shall be delivered by mail, electronic delivery or orally. If notice is mailed, it shall be deposited in the United States mail at least two (2) days before the time of the meeting. In the case the notice is delivered either orally or by electronic delivery shall be delivered at least forty- eight (48) hours before the time of the meeting. Any oral notice given personally or by telephone may be communicated either to the Director or to a person at the office of the Director whom the person giving notice has reason to believe will promptly communicate it to the Director. The notice need not specify the purpose of the meeting nor the place if it is to be held at the principal office of the Corporation. BYLAWS II KELTIC GREEN INC. PAGE 9 OF 15 (c) Place of Meetings. Meetings of the Board may be held at any place within or without the Commonwealth of Massachusetts that has been designated in the notice. If a place has not been stated in the notice or there is no notice, meetings shall be held at the principal office of the Corporation unless another place has been designated by a resolution duly adopted by the Board. Section 3.08 Electronic Participation. Members of the Board may participate in a meeting through conference telephone, electronic video screen communication or other electronic transmission by and to the Corporation. Participation in a meeting by conference telephone or electronic video screen communication constitutes presence in person as long as all Directors participating can hear one another. Participation by other electronic transmission by and to the Corporation (other than conference telephone or electronic video screen communication) constitutes presence in person at the meeting as long as participating Directors can communicate with other participants concurrently, each Director has the means to participate in all matters before the Board, including the ability to propose or object to a specific corporate action, and the Corporation implements some means of verifying that each person participating is entitled to participate and all votes or other actions are taken by persons entitled to participate. Section 3.09 Quorum of and Action by Directors. A majority of the authorized number of Directors constitutes a quorum of the Board for the transaction of business. Every act or decision done or made by a majority of the Directors present at a meeting duly held at which a quorum is present is the act of the Board of Directors, unless Chapter 156D or the Articles of Organization require a greater number. A meeting at which a quorum is initially present may continue to transact business notwithstanding the withdrawal of Directors, if any action is approved by at least a majority of the Directors who constitute the required quorum for such meeting. A quorum of the Directors may adjourn any Directors' meeting to meet again at a stated time and place. In the absence of quorum, a majority of the Directors present may adjourn from time to time. Notice of the time and place of a meeting that has been adjourned for more than twenty-four (24) hours shall be given to the Directors not present at the time of the adjournment. Section 3.10 Compensation. Directors may receive compensation for their services, and the Board of Directors may authorize payment of a fixed fee and expenses of attendance, if any, for attendance at any meeting of the Board of Directors or committee thereof. A Director shall not be precluded from serving the Corporation in any other capacity and receiving compensation for services in that capacity. The Directors may, from time to time, establish compensation policies of the Corporation consistent with this Section 3.10. Section 3.11 Action by Directors Without a Meeting. Any action required or permitted to be taken by the Board of Directors or any committee thereof under Chapter 156D may be taken without a meeting if, prior or subsequent to the action, a consent or consents thereto by all of the Directors in office, or all the committee members then appointed, is filed with the Secretary to be filed with the minutes of the proceedings of the Board of Directors. Such action by written consent shall have the same force and effect as a unanimous vote of such Directors. Section 3.12 Committees of the Board of Directors. The Board of Directors, by resolution adopted by a majority of authorized Directors, may designate one (1) or more committees, each consisting of two (2) or more Directors, to serve at the pleasure of the Board and BYLAWS II KELTIC GREEN INC. PAGE 10 OF 15 to exercise the authority of the Board of Directors to the extent provided in the resolution establishing the committee and permitted by law. The Board of Directors may adopt governance rules for any committee consistent with these Bylaws. The provisions of these Bylaws applicable to meetings and actions of the Board of Directors shall govern meetings and actions of each committee, with the necessary changes made to substitute the committee and its members for the Board of Directors and its members. A committee of the Board of Directors does not have the authority to: shares. (a) Approve actions that require approval of the shareholders or the outstanding (b) Fill vacancies on the Board or in any committee. (c) Amend or repeal bylaws or adopt new bylaws. (d) Amend or repeal any resolution of the Board of Directors that by its terms is not so amendable or repealable. (e) Make a distribution to shareholders, except at a rate, in a periodic amount or within a price range set forth in the Articles of Organization or determined by the Board. The Board of Directors, by resolution adopted by the majority of authorized Directors, may designate one (1) or more Directors as alternate members of any committee who may replace any absent or disqualified member at any meeting of the committee or for the purposes of any written action by the committee. The designation of a committee of the Board of Directors and the delegation thereto of authority shall not operate to relieve the Board of Directors, or any member thereof, of any responsibility imposed by law. ARTICLE IV: OFFICERS Section 4.01 Po4donsandFledion. TheofficasoftheCoiporationshallbeelectedbytheBoa dotDitectors and shall be a President, a Secretary, a Treasurer and all other officers as may from time to time be determined by the Board of Directors. At the discretion of the Board of Directors, the Corporation may also have other officers, including but not limited to one (1) or more Vice Presidents or assistant Vice Presidents, one (1) or more assistant Secretaries, a Chief Financial Officer and a Chief Operations Officer, as may be appointed by the Board of Directors, with such authority as may be specifically delegated to such officers by the Board of Directors. Any two (2) or more offices may be held by the same person. Each officer shall serve until a successor is elected and qualified or until the earlier death, resignation or removal of that officer. Vacancies or new offices shall be filled at the next regular or special meeting of the Board of Directors. Section 4.02 Removal and Resignation. Any officer elected or appointed by the Board of Directors may be removed with or without cause by the affirmative vote of the majority of the BYLAWS II KELTIC GREEN INC. PAGE 11 OF 15 Board of Directors. Removal shall be without prejudice to the contract rights, if any, of the officer so removed. Any officer chosen by the Board of Directors may resign at any time by giving written notice to the Corporation. Unless a different time is specified in the notice, the resignation shall be effective upon its receipt by the President, the Secretary or the Board. Section 4.03 Powers and Duties of Officers. The powers and duties of the officers of the Corporation shall be as provided from time to time by resolution of the Board of Directors or by direction of an officer authorized by the Board of Directors to prescribe the duties of other officers. In the absence of such resolution, the respective officers shall have the powers and shall discharge the duties customarily and usually held and performed by like officers of corporations similar in organization and business purposes to the Corporation subject to the control of the Board of Directors. ARTICLE V: INDEMNIFICATION OF DIRECTORS AND OFFICERS Section 5.01 Indemnification of Officers or Directors. The Corporation shall, to the extent permitted by Chapter 156D, indemnify all persons who have served or may serve at any time as officers or Directors of the Corporation and their heirs, executors, administrators, successors and assigns, from and against any and all loss and expense, including amounts paid in settlement before or after suit is commenced, and reasonable attorney's fees, actually and necessarily incurred as a result of any claim, demand, action, proceeding or judgment that may have been asserted against any such persons, or in which these persons are made parties by reason of their being or having been officers or Directors of the Corporation. This right of indemnification shall not exist in relation to matters as to which it is adjudged in any action, suit or proceeding that these persons are liable for negligence or misconduct in the performance of duty. Section 5.02 Non -Exclusivity of Indemnification Rights and Authority to Insure. The foregoing rights of indemnification and advancement of expenses shall be in addition to and not exclusive of any other rights to which any person may be entitled pursuant to any agreement with the Corporation, or under any statute, provision of the Articles of Organization or any action taken by the Directors or shareholders of the Corporation. The Corporation may buy and maintain insurance to protect itself and any agent against any expense asserted against them or incurred by an agent, whether or not the Corporation could indemnify the agent against the expense under applicable law or the provisions of this Article V. ARTICLE VI: SHARE CERTIFICATES AND TRANSFER Section 6.01 Share Certificates. Shares of the Corporation may, but need not, be represented by certificates. Each certificate issued shall bear all statements or legends required by law to be affixed thereto. For all shares issued or transferred without certificates, the Corporation shall within a reasonable time after such issuance or transfer send the shareholder a written statement of the information required on share certificates pursuant to Chapter 156D, § 6.25(b) & (c) and § 6.27. Shareholders can request and obtain a statement of rights, restrictions, preferences and privileges regarding classified shares or a class of shares with two (2) or more series, if any, from BYLAWS II KELTIC GREEN INC. PAGE 12 OF 15 the Corporation's principal office. Each certificate issued shall bear all statements or legends required by law to be affixed thereto. Every certificate for shares shall be signed by (i), the President, or a Vice President and (ii) the Chief Financial Officer, an assistant Treasurer, the Secretary or any assistant Secretary. Section 6.02 Transfers of Shares. [No shares of Common Stock of the Corporation may be subject to Transfer (as defined herein) without the approval of no less than [unanimous consent] of the Board. Notwithstanding any other provision of these Bylaws, each shareholder agrees that it will not, directly or indirectly, Transfer any of its shares or share equivalents, and the Corporation agrees that it shall not issue any shares or share equivalents if such Transfer would cause the Corporation to be unfit for licensure by the applicable cannabis regulatory body or otherwise subject to the applicable cannabis regulatory body for disciplinary action. In any event, the Board may refuse the Transfer of shares to any person if such Transfer would have a material adverse effect on the Corporation as a result of any regulatory or other restrictions imposed by any governmental authority.] Transfer of shares of the Corporation shall be made only on the books of the Corporation by the registered holder thereof or by such other person as may under law be authorized to endorse such shares for Transfer, or by such shareholder's attorney thereunto authorized by power of attorney duly executed and filed with the Secretary or transfer agent of the Corporation. Except as otherwise provided by law, upon surrender to the Corporation or its Transfer agent of a certificate for shares duly endorsed or accompanied by proper evidence of succession, assignment or authority to Transfer, it shall be the duty of the Corporation to issue a new certificate to the person entitled thereto, cancel the old certificate and record the transaction upon its books. "Transfer" means to, directly or indirectly, sell, transfer, assign, pledge, encumber, hypothecate or similarly dispose of, either voluntarily or involuntarily, by operation of law or otherwise, or to enter into any contract, option or other arrangement or understanding with respect to the sale, transfer, assignment, pledge, encumbrance, hypothecation or similar disposition of, any shares owned by a person or any interest (including a beneficial interest) in any shares or share equivalents owned by a person. Section 6.03 Registered Shareholders. The Corporation may treat the holder of record of any shares issued by the Corporation as the holder in fact thereof, for purposes of voting those shares, receiving distributions thereon or notices in respect thereof, transferring those shares, exercising rights of dissent with respect to those shares, exercising or waiving any preemptive right with respect to those shares, entering into agreements with respect to those shares in accordance with the laws of the Commonwealth of Massachusetts or giving proxies with respect to those shares. Section 6.04 Lost, Stolen, or Destroyed Certificates. The Board of Directors may issue a new share certificate in place of any certificate it previously issued that the shareholder alleges to have been lost, stolen or destroyed provided that the shareholder or the shareholder's legal representative of the lost, stolen or destroyed certificate shall give the Corporation a bond or other adequate security sufficient to indemnify the Corporation against any potential claim against the BYLAWS II KELTIC GREEN INC. PAGE 13 OF 15 Corporation because of the alleged loss, theft or destruction of any such certificate or the issuance of such new certificate. ARTICLE VII: CORPORATE RECORDS AND INSPECTION Section 7.01 Records. The Corporation shall maintain adequate and correct books and records of account, minutes of the proceedings of the shareholders, Board of Directors and committees of the Board of Directors, and a record of its shareholders, including names and addresses of all shareholders and the number and class of shares held, along with any other records required by law. The Corporation shall keep such record of its shareholders at its principal office, as fixed by the Board of Directors from time to time, or at the office of its transfer agent or registrar. The Corporation shall keep its books and records of account and minutes of the proceedings of the shareholders, Board of Directors and committees of the Board of Directors at its principal office, or such other location as shall be designated by the Board of Directors from time to time. Section 7.02 Inspection of Books and Records. The Corporation's accounting books and records and minutes of proceedings of the shareholders, Board of Directors and committees of the Board of Directors shall, to the extent provided by law, be open to inspection of Directors, shareholders and voting trust certificate holders, in the manner provided by law. Section 7.03 Certification and Inspection of Bylaws. The Corporation shall keep in its principal office the original or a copy of these Bylaws as amended or otherwise altered to date, which shall be open to inspection by the shareholders at all reasonable times during office hours. ARTICLE VIII: MISCELLANEOUS Section 8.01 Checks, Drafts, Etc. All checks, drafts or other instruments for payment of money or notes of the Corporation shall be signed by an officer or officers or any other person or persons as shall be determined from time to time by resolution of the Board of Directors. Section 8.02 Conflict with Applicable Law or Articles of Organization. Unless the context requires otherwise, the general provisions, rules of construction and the definitions of Chapter 156D shall govern the construction of these Bylaws. These Bylaws are adopted subject to any applicable law and the Articles of Organization. Whenever these Bylaws may conflict with any applicable law or the Articles of Organization, such conflict shall be resolved in favor of such law or the Articles of Organization. Section 8.03 Invalid Provisions. If any one (1) or more of the provisions of these Bylaws, or the applicability of any provision to a specific situation, shall be held invalid or unenforceable, the provision shall be modified to the minimum extent necessary to make it or its application valid and enforceable, and the validity and enforceability of all other provisions of these Bylaws and all other applications of any provision shall not be affected thereby. Section 8.04 Emergency Management of the Corporation. In anticipation of or during an emergency, as defined in Chapter 156D, § 3.03(d), the Board, in order to conduct the ordinary business affairs of the Corporation, shall modify procedures, including, but not limited to, calling a board meeting, quorum requirements for such board meeting and designation of additional or BYLAWS II KELTIC GREEN INC. PAGE 14 OF 15 substitute Directors; provided, that such modifications may not conflict with the Articles of Organization. In anticipation of or during an emergency, the Corporation shall be able to take any and all of the following actions to conduct the Corporation's ordinary business affairs and operations: (a) Modify lines of succession to accommodate the incapacity of any Director, officer, employee or agent resulting from the emergency. (b) Relocate the principal office or designate alternative principal offices or regional offices. (c) Give notice to Directors in any practicable matter under the circumstances, including but not limited to publication and radio, when notice of a board meeting cannot be given in a manner prescribed by these Bylaws. (d) Deem that one (1) or more officers present at a board meeting is a Director as necessary to achieve a quorum for that meeting. Section 8.05 Reports. The Corporation shall provide all shareholders with notice of the availability of annual financial reports of the Corporation before the earlier of the annual meeting of the shareholders or one hundred and twenty (120) days after the close of the fiscal year. Such financial reports shall be prepared and provided to the shareholders upon request in compliance with Chapter 156D, § 16.20. Section 8.06 Advisement of Counsel. THE CULTIVATION, PRODUCTION AND SALE OF CANNABIS IS ILLEGAL UNDER FEDERAL LAW. NEITHER PARTY, NOR ATTORNEYS FOR COMPANY, HAVE MADE ANY REPRESENTATION TO THE CONTRARY. ARTICLE IX: AMENDMENT OF BYLAWS Section 9.01 Amendment by Shareholders. Shareholders may adopt, amend or repeal these Bylaws by the vote or written consent of the holders of a majority of the outstanding shares entitled to vote, except as otherwise provided by law, these Bylaws or the Articles of Organization. Section 9.02 Amendment by Directors. Subject to the rights of shareholders as provided in Article IX, and the statutory limitations of Chapter 156D, the Board of Directors may adopt, amend or repeal these Bylaws. [SIGNATURE PAGE TO FOLLOW] BYLAWS II KELTIC GREEN INC. PAGE 15 OF 15 CERTIFICATE OF SECRETARY OF Keltic Green Inc. The undersigned, Justin Smith, hereby certifies that he is the duly elected and acting CEO of KELTIC GREEN INC., a Massachusetts corporation (the "Corporation"), and that the foregoing Bylaws were adopted as the Bylaws of the Corporation as of , 2018, and that the same do now constitute the Bylaws of the Corporation. IN WITNESS WHEREOF, the undersigned has executed this certificate on behalf of the Corporation as of this day of , 2018. KELTIC GREEN INC. By: Name: Justin Smith Title: CEO BYLAWS II KELTIC GREEN INC. SIGNATURE PAGE