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HomeMy Public PortalAboutNatSelects AJO Holdings_Application_7 Feb 2017 &I [ C APPLICATION FOR A SPECIAL PERMIT ®pr For a MEDICAL MARIJUANA TREATMENT CENTER NS AJO HOLDINGS INC. d/b/a Natural Selections 67 Dana Street#1 Cambridge, MA 02138 c/o Michael P. Ross, Esq. Prince Lobel Tye LLP One International Place, Suite 3700 ,p Boston, MA 02110 Applicant 9�22z' Property Location: 9 23 Elm Street, Building 2 Watertown, MA 02472 Prepared by: Michael P. Ross, Esq. Prince Lobel Tye LLP One International Place, Suite 3700 Boston, MA 02110 Telephone: (617) 456-8000 Facsimile: (617) 456-8100 February 7, 2017 d TABLE OF CONTENTS APPLICATION TO THE ZONING BOARD OF APPEALS For a Special Permit For a MEDICAL MARIJUANA TREATMENT CENTER Property Location: 23 Elm Street, Building 2 Watertown, MA 02472 Special Permit Application Form Tab 1 Written Supporting Statement Tab 2 Property Photographs Tab 3 Facility Security Program Tab 4 Security System Narrative and Diagram Tab 5 Draft Policies and Procedures Tab 6 Site Plan and Floor Plan Tab 7 Trip Generation Study Tab 8 i PLANNING BOARD WATERTOW N, MA 1 PERMIT APPLICATION FORM 6}0 Planning Board and Zoning Board of Appeals 149 Main Street Watertown, MA 0247 (617)972-6427 vnvtv.wateamai-ma.gov TO BE COMPLETED BY STAFF Case Number: Notice to ADDlicant: An application may be denied for outstanding taxes or charges to the Town (Watertown Ordinance, Chapter ❑ Fees received: XVII). Upon deeming the submittal complete,the application will f"mil c'loi lc'�i.nup be stamped/filed at the Town Clerk's office by DCD&P Staff. R c,p ii' d ❑ Complete submittal: X Date: Tow,Treasurer's Approval(As required by Ch.40,Section 57) TO BE COMPLETED BY APPLICANT Site Address: List application requests below: I23 Elm Street, Building 2, Watertown, MA Special Permit(SP) N Variance(V) e Site Plan Review(SR) SP/SR Parcel ID#s:1236 4 G Special Permit Finding(SPF) For an amendment to previous relief,provide case#s: Zoning District: Regional Mixed Use (RMUD) SR(Site Plan Review)meeting date,if required: Petitioner(s): NS AJO Holdings, Inc., d/b/a (Natural Selections) Phone: (617) 610-0761 Address: 67 Dana Street#1, Cambridge, MA 02138 Email: aidan423@gmail.com Sign tu��A � l y� Date: 2/7/2017 Owner(s):Christopher Lucy, Trustee of 23 Elm Street Trust Phone: (617) 756-1758 Address:107 South Street Unit 3B, Boston MA 02111 Email: chrisbuell1998@gmail.com ISignature(s): C g_n bb,4, Lo,, Date: 2/7/2017 Agent: Michael Ross Esq., Prince, el Tye LLP v Phone/Email: (617) 456-8149 Other Contacts: Phone/Email: The Petitioner must be the fee simple owner or hold sujjicient "interest"in the subject property(in which case evidence must be pro- vided as to the nature of the property interest and the fee owner shall co-sign this application. For legal entities such as corporations, LLC,etc, list the type and legal status ofownership, the name of trustees/officer members, their affiliation and contact information- NATURE OF REQUEST Applicable Sections of Zoning Ordinance(Sped Sections)ofthe ZONING ORDINANCE from which relief is sought): Petitioner seeks relief from Section 9.05 of the Watertown Zoning Ordinance. Brief description of the project as it relates to the zoning relief requested—Include existing dimensions,proposed dimensions, and any non-conformities that exist: Petitioner seeks Special Permit relief from the Watertown Zoning Board of Appeals to allow the operation of its proposed Medical Marijuana Treatment Center(MMTC) at 23 Elm Street, Building 2 in Watertown. Petitioner will occupy approximately 2,755 sf of space within Building 2 and will include 22 off-street parking spaces to allow patients direct access to services at the MMTC. Please see Petitioner's Written Supporting Statement for more details about the proposed MMTC. THIS APPLICATION MUST BE SUBMITTED IN PERSON TO THE ZONING OFFICE The ZONING ORDINANCE can be,/bund online at m v watcamoi-ma.gov SUBMITTAL:REQUIREMENTS ® Signed Applications(3 original& 17 copies) ® Full Set of Plans,collated(20 Copies and PDF version) 1. Certified Plot Plan(for all applications) IN Written Supporting Statement{20 Copies} 2. Architectural Drawings(Floor,Elevations,etc. if applicable) ® Release/Indemnification Waiver(I copy signed) 3. Grading/Drainage Plan(if applicable) 4. Roof Plan(if applicable) X1 Newspaper Billing Authorization Form(1 copy signed) 5. Parking/Circulation Plan(if applicable) ❑ Any additional information relevant for review G. Landscape Plan(if applicable) 7. Site Utility Plan(if applicable) 8, Lighting Plan(if applicable) NOTE: THE APPLICATION WILL NOT BE CONSIDERED "COMPLETE" UNLESS ALL NECESSARY DOCUMENTS ARE SUBMITTED. FILLE7HE.APPLICABL ;PROJEC'f DATA°:BELOW ' ::; � . Data Required Existing Proposed Staff Comments A. Use(Article V, WZO) Industrial MMTC B. Dwelling Units 0 0 No Change C, Lot Size 10,000 sf 46,827 sf No Change D. Front Yard Setback 10 sf NIA No Change E. Rear Yard Setback 20 sf NIA No Change F. Side Yard Setback(left) I 15 sf NIA No Change G. Side Yard Setback(right) 15 sf NIA No Change . H. Building Coverage 75% 33.5% No Change 1. Impervious Coverage 85% NIA No Change " J. Height/it of Stories 55/5 1 No Change K. Lot Area per Unit NIA NIA No Change L. Gross Floor Area NIA 2,755 sf No Change , M, Floor Area Ratio(FAR) 1.0 .33 No Change N. Open Space 20% NIA No Change O.Parking Spaces I 5 8 22 Other data: THIS APPLICATION MUST BE SUBMITTED IN PERSON TO THE ZONING OFFICE ON THE 2ND FLOOR OF THE TOWN ADMINISTRATION BUILDING. Ae ZONING ORDINANCE can be fsunif online ca:Nvmv,w_at_eito`vn-ma,go_v_ 2 'Written Sup porting.StateMe Petition for Special Permit Finding(s) Sec. 4.06(a) (project must meet the following criterion) 1. Is the proposed change substantially more detrimental than the existing non-conforming use,structure,or building to the neighborhood?YES/NO, Explain why. The proposed change is not substantially more detrimental than the existing use. Please see Petitioner's Supporting Statement for more explanation. Petition for Special Perm it(s)IAmendment Sec. 9.05 (b) (project must meet all of the following criteria) 1. Is the subject site an appropriate location for such use,structure,and/or condition? YES/NO, Explain. Yes, the subject site is an appropriate location of the proposed MMTC. Please see Petitioner's Supporting Statement for more explanation. 2. Will the proposed use/structures adversely affect the neighborhood? YES/NO, Explain, No, the proposed MMTC will not adversely affect the neighborhood. Please see Petitioner's Supporting Statement for more explanation. 3. 1s there potential for nuisance or serious hazards to vehicle or pedestrians?YES/NO, Explain. There is no potential for nuisance or serious hazards to vehicles or pedestrians. Please see Petitioner's Supporting Statement for more explanation. 4. Will adequate and appropriate facilities be provided for the proper operation of(lie proposed use? YES/NO, Explain. Yes, adequate and appropriate facilities will be prodded for the proper operation of the proposed MMTC. Please see Petitioner's Supporting Statement for more explanation. Petition for Variance(s)/Amendment Sec.9.14(b) (project must meet all of the following criteria for a variance) I. Is the variance being sought due to circumstances related to the soil conditions,shape,or topography of such land or structures, and especially affecting such land or structures but not affecting generally the zoning district in which it is located? YES/NO, Explain. 2. Would enforcement of the Zoning Ordinance involve substantial hardship,financial or other? YESINO, Explain. 3. Would granting of the desired relief be a substantial detriment to the public good? YES/NO, Explain, 4. Would granting the desired relief nullify or substantially derogate from the intent of this Zoning Ordinance? YES/NO, Explain, IF NEEDED, ATTACH ADDITIONAL SHEETS OF PAPER TO THIS APPLICATION 3 Permission To Inspect Premises With RELEASE, INDEMNIFICATION, AND WAIVER For An Individual Christopher Lucy, Trustee of 23 Elm Street Trust and my successors and assigns, give and extend to the Zoning Board of Appeals of Watertown and to the Town of Watertown, a municipality in the County of Middlesex and the Commonwealth of Massachusetts, my express permission to come onto the premises owned by, occupied by or under the control of the above named individual, to any member or agent of the Zoning Board-of Appeals, Planning Board or respective staff members of Watertown for the purpose of conducting an inspection of the premises which has been brought to the attention of the Zoning Board'of Appeals or Planning Board of Watertown as a result of the petition that I have placed before it. The permission to conduct an inspection shall extend for the full time period during which the petition before the respective Boards of Watertown is pending and any related period of decision. I hereby forever discharge and release and will at all times, defend and save and hold harmless the Town of Watertown,the members of the Zoning Board of Appeals and Planning Board, and any of the officers, employees, and agents of either who direct or conduct said inspections from any and all claims, demands, civil action, suits, liabilities, judgments, or damages of any kind, including but not limited to those for alleged trespass, invasion of privacy or warrantless search, an.any'way arising out of any inspection by the Respective Board members or their agents or the Town's agents, and hereby waive any and all claims that I may now have or may ever have against the Town-or any of•its officers,employees or agents-for such inspections. I further state that I carefully read the foregoing Permission with Release, Indemnification, and Waiver and know the contents thereof,and I sign the same as my own free act. in witness whereof, I have hereunto-set my hand this 7th day of February 12017 Christopher Lucy,Trustee of 23 Elm Street Trust Signature Petitioners Name and Address COMMONWEALTH OF MASSACHUSETTS - County of Middlesex, /ss.. On this the T"- day of Q k nrin, 2-c)t-A , before me, ��Ylrt� �. ►J l�� �L�n Day Month Year 'Name of Notary Public Personally appeared: C �A n S �V.2>r -) . Lu(_ vu Names)of Signer(s) Proved tome through satisfactory evidence of identity.,which waslwere: AA-S Ll u t'r V_ Description of Evidence of Identity To be the person(s)whose name(s)was/were signed on the preceding or attached document in my presence,and who swore or affirmed to me that the contents of the document are truthful and accurate to t e best of his/her/their knowledge and belief, ��„utmu,Nr,r , ! / r )L ra`,� D'O rlr''ti. �— t EJ('p�R�•��• ,fture of otary Public Pfinlecf Name of Notary U ;k ° G�"•., Tp�ty'Pil.•.� mmissinn Expires: 4r��53gCN����► 46 Place Notary Seal Above Rev 3105 Icivetti zba { 1630 ' TOWN OF WATERTOWN Community Development & Planning 149 Main Street (617) 972-6417 Watertown, MA 92472 FAX(617)972-6484 www.ci.watettown.ma.us Authorization Form To: Debra Dillon, Legal Advertising Department Community Newspapers (Watertown Tab) From: Watertown Zoning Board of Appeals — Louise Civetti Watertown Planning Office RE: Billing Authorization Form I hereby authorize Community Newspaper Company to bill me directly for the attached Legal Notice(s) to be published for two consecutive weeks in the Watertown Tab on the following dates: and for the property located at: 23 Elm Street, Building 2 , Watertown, MA. Bill To: NS AJO Holdinqs, Inc. Address: 67 Dana Street#1 City/State/Zip: Cambridge, MA 02138 Telephone: Signature Date Attachment CC: Petitioner Planning Office 6106 Icivetti/applications/newspaper auth-Planning �I 45{ k t t :.{p X �L S i i ff1111 l Y�. ePRince LOBeL February 7, 2017 Watertown Zoning Board of Appeals 149 Main Street Watertown, MA 02472 Re: Application for Special Permit Property Address: 23 Elm Street, Watertown, MA 02472 (the "Property") Aoolicant: NS AJO Holdings, Inc. dlbla Natural Selections. Dear Honorable Members of the Zoning Board of Appeals: This firm represents NS AJO Holdings, Inc. dlbla Natural Selections ("Natural Selections") in connection with its application for a Special Permit from the Watertown Zoning Board of Appeals (the "Board") to allow the operation of its proposed Medical Marijuana Treatment Center (the "MMTC") at 23 Elm Street, Building 2, Watertown, MA 02472 (the "Proposed Site"). The Property is located in the Regional Mixed Use (RMUD) District and pursuant to Section 8.04 of the Town of Watertown Zoning Ordinance (the "Ordinance"), the use of the Property for a MMTC is permitted through the granting of a Special Permit and approval from the Board. Natural Selections` proposal satisfies the requirements for the grant of a Special Permit as set forth in Section 9.05 of the Ordinance. The Property operates as three (3) standalone buildings, Building 1, Building 2, and Building 3. Natural Selections seeks to operate its proposed MMTC in Building 2 at the Property, The MMTC will occupy approximately 2,755 square feet of space within Building 2 and will include 22 of-street parking spaces to allow patients direct access to services at the Proposed Site. Natural Selections is committed to benefiting Watertown through community and fiscal impact. Natural Selections is willing to enter into a Community Host Agreement with Watertown and has been invited to file a Siting Profile Application in connection with its application for a Provisional Certificate of Registration to operate a Registered Marijuana Dispensary (the "License") from the Massachusetts Department of Public Health (the "DPH") and to operate the proposed MMTC at the Proposed Site. Natural Selections has filed a total of three (3) applications with the DPH for three (3) separate dispensing locations, including the Proposed Site, and i one (1) cultivation and manufacturing location. The proposed MMTC will be a safe and inviting space for registered patients and caregivers to purchase medical Prince Lobel Tye LLP cannabis flower and manufactured infused products, while also receiving education One International Place and training in regard to responsible use of cannabis. suite 3700 I. Background Boston, MA 02110 TEL; 617 456 8000 Natural Selections is a Massachusetts-based non-profit committed to serving FAX; 617 456 8100 medical cannabis patients in Watertown, Massachusetts. Natural Selections is an www.princelobel.com r 2628406 EEE I ePRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 2 established organization committed to providing access to quality natural medicine on the basis of scientific research and development. Prior to incorporating in Massachusetts, members of the Natural Selections' team have successfully owned and operated a dispensary in Colorado ("Natural Selections, Colorado"), which has emerged as a leading cannabis organization with a strong reputation for its commitment to scientific research and development, community involvement, and high-quality, safe, and consistent products. Natural Selections has set forth the following objectives in establishing its organization: a. A compliant operation in good standing with regulators and 105 CMR 725.000 et. seq. (the "Regulations"), b. Safe, consistent and effective products of the highest quality, C. Commitment to serving and educating patients and caregivers, and d. Commitment to scientific research and development. Natural Selections has assembled a team of experienced professionals excited to dedicate their business and cultivation expertise to produce medical cannabis in Massachusetts. The team is led by lsador Mitzner, an experienced entrepreneur with decades of experience in the retail business, Aidan O'Donovan, an experienced cultivator and cannabis business owner, and Bob Aldworth, a financial professional with extensive experience in finance and operations from public and private companies. Additionally, David R Goodman, a board-certified physician from Newton, Massachusetts, will serve as Natural Selections' medical director and provide oversight and support to the MMTC to help maintain and continuously improve the quality of care provided to qualified and registered patients and caregivers. Natural Selections plans to build collaborative relationships with state and local governments, including Watertown, to ensure a seamless integration into the community it serves. Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local civic and community organizations that promote public health within the Watertown community. Additionally, Natural Selections will establish ongoing community dialogues and seminars in order to provide transparency about its operations and education about the responsible medical use of cannabis. The team has extensive experience in treating and servicing medical cannabis patients. Chief Operating Officer Aidan O'Donovan is the founder of a dispensary in Northglenn, Colorado. The business, which opened upon receipt of its license in 2014, specializes in cultivating and dispensing cannabis to Colorado patients suffering from a variety of illnesses. O'Donovan will lead the team in all elements of developing, implementing, and maintaining a cannabis operation. With regard to cultivation, he has extensive knowledge related to environmental control, indoor agricultural lighting mechanisms, media and nutrient additives, post harvest processing and quality control, and optimal strain selection. O'Donovan will be responsible for matching the •needs of patients with the most effective health 2629406 I PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 3 solutions, while ensuring that the operation is in compliance with regulators and the Regulations. O'Donovan's experience will also be critical to establish the business operations in a timely fashion to ensure that patients are provided with the treatments they need as quickly as possible. Natural Selections is committed to operating a highly secure and compliant MMTC in Watertown, Massachusetts. To this effect, Natural Selections has engaged Dan Linskey, the former Superintendent in-Chief of the Boston Police Department and current Managing Director of Kroll Investigations and Disputes, to serve as its Security Director. Linskey led the Boston Police Department through some of the most tragic and contentious events in the city's history, including the Boston Marathon Bombings and the Occupy Movement. He has strong relationships with local law enforcement agencies in Watertown and Boston, Massachusetts and will uphold Natural Selection's commitment to security as well as a seamless integration into the Watertown community. Natural Selections is committed to serving registered patients in Watertown and will assemble a board of advisors to ensure that its business is meeting the expectations of the community and operating in a true non-profit fashion. The team believes that Natural Selections will be instrumental in helping to create a strong cannabis industry in Massachusetts, where patients are guaranteed safe and secure access to medication in a manner compliant with all regulations outlined in the Regulations. Expertise in Design & Development Co-founders Isador Mitzner, Aidan O'Donovan, and Bob Aldworth have certain qualifications as it relates to designing and developing a cannabis dispensary/cultivation facility that will be invaluable to the operation. They have assembled a team of architectural, engineering, and security professionals to help bolster their own areas of expertise. Natural Selections intends to design and develop the MMTC while prioritizing efficiency, safety, community, and future development. Aidan O'Donovan, COO, is originally from Newton, Massachusetts. He has worked in the medical cannabis industry since 2009. In 2014, O'Donovan spearheaded the design and development of Natural Selections, Colorado's dispensary facility (2,700 square feet) and cultivation facility (8,000 square feet) in Colorado. He also assisted in the build-out of Spoonful of Sugar, a cannabis man ufacturinglprocessing lab and kitchen in Denver, Colorado in 2019. Natural Selections is committed to creating a sense of community through its MMTC, which will create a shared sense of responsibility among patients, caregivers, and employees. To this effect, Natural Selections will invest in a spacious and inviting design to ensure that patients feel comfortable within the MMTC and have sufficient time to discuss all questions and concerns with dispensary agents. O'Donovan will oversee the establishment of the facility. All 2628406 13 PRinceLL Watertown Zoning Board of Appeals February 7, 2017 Page 4 flooring, lighting, and colors schemes will be selected to create a natural, spacious feel. In addition to creating an inviting establishment for its patients, Natural Selections is committed to implementing extensive security measures that will comply with all regulations outlined under 105 CMR 725.110. Natural Selections operates in a high-risk environment and understands the high-risk level for theft and robbery. Natural Selections is committed to designing a space where prevention and deterrence will be achieved by means of physical security prevention measures, electronic security measures, and operational security measures. Natural Selections is committed to providing extensive training, information, and resources to its employees so they are prepared to prevent, report, deter, and when appropriate, respond to any violence that could occur on the premises. Dan Linskey will lead the Natural Selections team in designing and developing a secure MMTC. Mr. Linskey serves clients in diverse industries with uncommon experience in investigations, crisis response, and risk management, as well as personal, physical, and operational security strategies. Widely respected for his knowledge of the complexities inherent in law enforcement and homeland security, Dan has also consulted with numerous national and international government agencies on a broad range of challenges, including large-scale event management, crisis leadership, and preparedness and community engagement strategies. Mr. Linskey has extensive experience designing and implementing security systems rooted in Crime Prevention Through Environmental Design, Concentric Circles of Protection, and Integrated Design. Expertise in Operations Natural Selections is uniquely qualified to operate a cannabis dispensary facility in Massachusetts. Members of Natural Selections' team have been operating a dispensary and cultivation facility in Colorado for the past two years and have the skills and knowledge to develop the best cannabis products for registered patients in Massachusetts. Isador Mitzner, CEO, brings extensive retail and business operating experience to the team. He founded a clothing company, LAT Sportswear in 1978 in Atlanta. As the CEO and Owner of LAT sportswear, he spent three decades growing and expanding the business until its sale in 2012. Bob Aldworth, CFO, brings experience in finance and operations from public and private companies, ranging from a start-up to multi-national companies with annual revenues exceeding $2.2 billion. Aldworth has most recently held the position of CFO at Phobio, LLC, Stratix Corporation, Jacada, Ltd. and Infor Global Solutions. Aldworth has also served as an advisor to nonprofit organizations including a sizable Property Owner's Association in Florida and a Montessori school in New Hampshire. 2628406 PRince LOB Lm Watertown Zoning Board of Appeals February 7, 2017 Page 5 Chief Operating Officer Aidan O'Donovan will lead the team throughout all stages of the cultivation and dispensing process. O'Donovan has operated the Natural Selections, Colorado facility since 2014 and has extensive experience in in developing, implementing, and maintaining standard operating procedures related to environmental control, lighting mechanisms, media and nutrient additives, post harvest processing and quality control, and optimal strain selection. Based on this experience, Natural Selections has developed its business plan based on three commitments: high-quality products tailored for medical conditions, product transparency, and high standards for cannabis cultivation, and processing. High Quality Products Tailored for Medical Conditions Natural Selections is committed to providing its patients with high quality cannabis that offers palliative care and pain relief, while reducing the side effects and symptoms of certain disorders. While Natural Selections acknowledges the lack of double-blind placebo-controlled tests illustrating the efficacy of cannabis in treating certain medical conditions, the company has taken a scientific approach to strain development, aggregating data based on patient feedback and carefully studying plant and terpenoid profiles. David R. Goodman, MD, will serve as Medical Director for the business. Dr. Goodman is an Anesthesiology Specialist based in Newton, Massachusetts. He has more than 14 years of medical experience and is affiliated with Newton- Wellesley Hospital. Dr. Goodman will be responsible for developing, organizing, and facilitating education programs for patients, caregivers, board members, and the community at large concerning methods of consumption, cannabinoid profiles, regulation updates, as well as Natural Selections' services and programs. The company has studied the medical conditions eligible for treatment under the Regulations and intends to provide an array of cannabis products best suited to treat these conditions. Natural Selections will initially introduce an array of strains that have demonstrated success in alleviating symptoms of HIV, AIDS, multiple sclerosis, cancer, epilepsy, and Crohn's disease, and Parkinson's disease and will adjust its product line based on available data and science, regulations, and market demand as the business evolves. Product Transparency The founders of Natural Selections are committed to transparent and ethical business practices and understand that these practices are particularly essential within the medical cannabis industry. Natural Selections will only offer quality, lab tested products. Natural Selections guarantees that all batches of medical cannabis are tested at a certified laboratory for potency, terpenes, metals, pesticides, and microbials, as well as THC/CBD [ content. The results of these tests will be displayed on the packaging of all 2628406 13 PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 6 products. As per the regulations outlined under 105 CMR 725.105(E), information is placed describing our nutrients, pesticides, ingredients, and recommendations on methods of intake, dosing, batch information and contact information. Dispensary agents will be trained to explain the significance of laboratory testing results, so they can make accurate recommendations based on a patient's specific ailments and needs. Natural Selections will provide extensive educational materials in its MMTC as well as on its website. Its website will have an extensive R&D section that posts information*on all strains produced along with current testing results. Natural Selections' website will also have a research portal that shares reliable medical journal articles from high profile entities such as GW Pharmaceuticals, so qualifying patients and dispensary agents are able to conduct their own research concerning the medicinal benefits of medical cannabis. Best Practices for Cultivation, Processing, & Manufacturing Natural Selections is committed to maintaining high standards of production throughout all elements of the cultivation and processing medical cannabis. Chief Operating Officer Aidan O'Donovan will lead the team in managing, tending, and cultivating the plants throughout all stages of the cultivation and dispensing process. O'Donovan has extensive experience in in developing, implementing, and maintaining standard operating procedures for cannabis cultivation and dispensing facilities. Natural Selections intends to emulate its cultivation strategies at is cultivation facility in Colorado. In contrast to a perpetual harvest cycle, Natural Selections uses a 4- week cycle in which a different flower room is cut down every week. Natural Selections separates flowering rooms based on the unique needs of each strain group. This strategy prevents the early harvest of immature plants and mitigates many common problems that are associated with strains growing in non-ideal environments. Cannabis grown at the cultivation facilities will be inspected thoroughly to ensure the medicine is free of pathogens and contaminants. Plants fertilizer and ' est quality, lab tested state approved f will be cultivated with the high q y, pp pesticides to prevent potential carcinogens and residual contaminants from being consumed. Natural Selections strives to have minimal impact on the environment and on plants. Natural Selections utilizes as few chemicals as possible and uses that are extreme) low in heavy metal content. These e salt-based nutrients t t clean t Y Y practices ensure the overall quality of finished product. 11. Protect Description Natural Selections has identified 23 Elm Street, Building 2 in Watertown as an ideal location in which to establish its MMTC. e Property is located within the Regional Mixed Use District RMUD which allows � The p y 9 ( ) I Medical Marijuana Treatment Centers by Special Permit. f f F 2628406 . PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 7 The Proposed Site is located near a centrally located shopping district in Watertown, on the outskirts of Cambridge, Allston, Brighton, Belmont, and Newton. There are approximately 450,000 residents living within a five-mile radius of the facility, which translates to roughly 2,061 registered patients eligible for medical marijuana based on a proportional ration of total patients currently registered with the Massachusetts Department of Health. The Property itself operates as three (3) standalone buildings, Building 1, Building 2, and Building 3. Natural Selections has a binding letter of intent with the property owner (Christopher Lucy, Trustee, of 23 Elm Street Trust) for Building 2, Rear, 2,755 square feet of space located within Building 2. The Proposed Site is set back and almost completely shrouded from public view, from the right of way for both pedestrian and vehicular traffic on Elm Street. It sits tucked behind Building 1, which fronts Elm Street, thus blocking it from direct view. The Proposed Site is not directly visible from Arsenal or Arlington Streets. Natural Selections proposes 22 units of off-street parking to allow patients direct access to services. Deliveries will occur through the rear of the building, with secure off-street loading (which will be staggered and staged with secure unmarked vehicles). The location will be made safe and secure through reinforced construction materials and technology, cameras and remote monitoring, and on-site security personnel. The Proposed Site will include various security and safety equipment and technology, including but not limited to secure sally port, or access control vestibules, computer verified patient or caregiver entrance protocols, and redundant security alarms and controls. In addition all personnel will be trained extensively, and the operation will fully comply with Massachusetts guidelines. Ill. Natural Selections satisfies the provisions for a Special Permit set forth in Section 9.05 of the Ordinance Natural Selections respectfully submits, and requests that the Board find, that the benefits of the MMTC outweigh the adverse effects of the MMTC, taking into account the characteristics of the Proposed Site and of the proposed MMTC described herein. In addition, Natural Selections respectfully submits that it has satisfied the criteria required for a Special Permit pursuant to Section 9.05 as follows: a) 9.05(b)(1). The specific site is an appropriate location for e such a use, structure or condition; F Natural Selections seeks to locate a MMTC at 23 Elm Street, Building 2 in Watertown for the purpose of dispensing medical marijuana and medical marijuana products to registered patients. The Proposed Site is located within an existing building and the proposed MMTC will not require any change to the natural environment from the existing conditions. 2628406 0 PRince LOB L Watertown Zoning Board of Appeals February 7, 2017 Page 8 The Proposed Site is set back and almost completely shrouded from public view, from the right of way for both pedestrian and vehicular traffic on Elm Street. It sits tucked behind Building 1, which fronts Elm Street, thus blocking it from direct view. The Proposed Site is not directly visible from Arsenal or Arlington Streets. In addition, Natural Selections proposes the use of 22 units of off-street parking to allow patients direct access to services. Deliveries will occur through the rear of the building, with secure off-street loading (which will be staggered and staged with secure unmarked vehicles). Natural Selections has spent a significant amount of time searching for appropriate locations for its MMTC and chose the Proposed Site because of its industrial neighborhood and its significant distance from schools and other sensitive uses. The existing neighborhood that the Property is located in is comprised of industrial, retail and office uses, and Natural Selections respectfully submits that the proposed MMTC at the Proposed Site will not adversely affect the surrounding neighborhood. Natural Selections has thoroughly vetted the use and the location of the MMTC through the DPH licensing procedure. Many of the issues Natural Selections considered in determining a location that complies with the Regulations, directly address the effect of the proposed MMTC on the surrounding neighborhood. For example, the DPH required Natural Selections to detail its operating procedures in order to evaluate their impact on the neighborhood. Natural Selections was required to supply detailed operational information on the hiring of employees, employee security policies and crime prevention techniques, hours of operation and after-hours contact information, and extensive security protocols. Natural Selections has attached hereto a copy of its Draft Policies and Procedures, which is also incorporated herein by reference. Further, many of the procedures and safeguards set forth in the Regulations, which are enforced and implemented by the DPH, are specifically designed to ensure the safe and discreet dispensing of medical marijuana so as to minimize and mitigate any impact the proposed MMTC may have on the surrounding neighborhood and community. Natural Selections will be subject to continued oversight by the DPH and is required to adhere to stringent requirements for the security, storage, handling, testing, packaging, labeling and dispensing of medical marijuana. The Regulations limit the logos used for labeling, signage and other materials and specifically prohibits the use of medical symbols, images of marijuana, related paraphernalia, and colloquial references to cannabis and marijuana as logos. The Regulations limit the illumination of external signage and prohibits any displaying of advertisements for marijuana, graphics related to marijuana or paraphernalia on the exterior of the MMTC. All of these requirements were designed in an effort to minimize and mitigate any adverse effects an MMTC may have on a neighborhood. As stated above, the DPH will continue to enforce these requirements and Natural Selections' license can be revoked for any violations. f 2628406 ® PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 9 Further, because Natural Selections chose an appropriate location for the MMTC and had many other mechanisms in place, including a proven track record of experience in the industry, it was selected to submit three (3) Siting Profiles in connection with its application for three (3) Licenses from the DPH. Lastly, Natural Selections does not expect to cause an increase in demands on Watertown's police, fire, emergency, or health-related services and does not expect to cause an adverse impact on Watertown. Natural Selections is committed to benefiting Watertown through community and fiscal impact and is willing to enter into a Community Host Agreement with Watertown and set aside funds annually to offset any additional or unforeseen issues that may affect Watertown, such as additional demands on local law enforcement agencies, increased use of Watertown infrastructure, or the need for additional Watertown infrastructure, employees and equipment. Natural Selections is fully committed to improving the region's economy to the extent possible and integrating seamlessly into the community. b) 9.05(b)(2). The use as developed will not adversely affect the neighborhood; Natural Selections is committed to benefiting Watertown through community and fiscal impact. Natural Selections is willing to offer up the greater amount of $200,000 or S% of the gross revenue generated annually from the MMTC to Watertown in the form of a Community Host Agreement. Natural Selections has also set aside $100,000 annually to offset any additional or unforeseen issues that may affect Watertown, such as additional demands on local law enforcement agencies, increased use of Watertown infrastructure, or the need for additional Watertown infrastructure, employees and equipment. Further, Natural Selections has taken great precautions in creating its security and safety plans, with the intention of protecting its employees, patients, and caregivers. Natural Selections does not expect to cause increased demands on Watertown's police, fire, emergency, or health-related services and does not expect to cause an adverse impact on the Watertown. Natural Selections is committed to improving Watertown's economy and integrating seamlessly into its community and will take full responsibility for offsetting any potential use of resources, white simultaneously bettering the economy. Therefore, Natural Selections intends to implement a number of procedures to mitigate issues associated with crime, drugged driving, distribution to minors, public consumption, and air, noise, fight and water pollution. Preventing Increased Crime Natural Selections is committed to implementing intensive security measures to ensure that the legalization of cannabis does not result in increased crime rates. Natural Selections believes that preventive security measures are the best way to ensure that there is no illegal distribution or diversion of the products sold at the proposed MMTC. Natural Selections has created these security measures based ' 2628406 RM PRince LOB L Watertown Zoning Board of Appeals February 7, 2017 Page 10 on the concept of "Concentric Circles of Protection," which are compliant with 105 CMR 725.110 and based on varying levels of protection that work in conjunction with one another to create and maintain a secure and safe facility. Natural Selections intends to form a relationship with Watertown's police department and will meet on an annual basis to discuss concerns and effective security operations regarding the MMTC. While Natural Selections does not expect an increase in crime rate or an increased demand on the Watertown's police department, it anticipates that its Community Host Agreement with Watertown will mitigate any financial drain on Watertown's resources. Preventing Drugged Driving Natural Selections will develop, implement, and maintain educational materials and seminars designed to prevent drugged driving and other adverse public health consequences associated with marijuana use. Natural Selections will design training procedures and policies to educate patients and employees about the risks associated with operating a motor vehicle after consuming medical cannabis. Each patient will be required to complete an orientation session before purchasing medical cannabis from the MMTC. This orientation will help patients understand how cannabis affects the human body and the risks associated with use. The orientation will also cover potential legal and financial risks for not abiding by Massachusetts law. The orientation will also provide extensive information about the dangers, risks, and adverse effects associated with the consumption of cannabis, particularly the health, legal, and financial risks of driving under the influence of cannabis. The educational materials will outline Massachusetts law so that employees will be able to inform patients that Massachusetts law prohibits any driving under the impairment. Preventing Distribution to Minors The Department of ,Justice has stated that preventing the distribution of marijuana to minors" is its first enforcement priority related to medical cannabis. Natural Selections shares this concern and understands the potential risk of lilegal cannabis o minors. Natural Selections is committed to preventing distribution of distribution t the products sold at their Massachusetts dispensary to minors other than as allowed by state law and regulations. Natural Selections will begin prevention on the premises with rigorous physical security measures that ensure only registered qualifying patients, personal caregivers, dispensary agents and other authorized individuals can access the MMTC. Natural Selections will also train employees to inspect photo identification and registration cards, which physicians, patients, and caregivers will present upon entering the dispensary. The MMTC will be designed in a neutral and secure fashion and it will not attract the attention of loiterers or minors nor encourage any congregating outside of the dispensary. Additionally, Natural Selections is aware of the dangers of "social distribution" and will provide extensive educational materials 2628406 F IS PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 11 to inform patients and physicians about the dangers and risks associated with distributing medical cannabis to non-registered patients. In the event that Natural Selections becomes aware of such activity, or is otherwise suspicious, it will take immediate action. Location, Security, & Surveillance Natural Selections understands that its location, security, and surveillance systems will also be critical in preventing the illegal distribution of medical marijuana to minors or other nonregistered users. Natural Selections has chosen a location for its MMTC that is highly compliant with 105 CMR 725.110(A)(14). The Proposed Site is not situated within 500 feet of a school, daycare center or any facility in which minors commonly congregate. Natural Selections specifically chose this location, as it is a significant distance from any area that would be considered to be at risk for the congregation of minors. The MMTC will in no way reference the sale of marijuana through its logo, external signage or on the exterior of its premises abiding with Massachusetts's law. The signage outside of the MMTC will only be illuminated 30 minutes prior to the MMTC's closing and there will be no neon signage that may attract potential loiterers. Natural Selections will also ensure that security measures are taken if there appears to be loitering outside of the dispensary. Natural Selections will ensure that the MMTC is under video surveillance 24 hours a day and 7 days a week and will make the surveillance available for inspection by Department of Public Health and/or Watertown Police Department at all times. The following will be implemented at the Proposed Site to ensure that Natural Selections is secure and is designed to prevent the illegal distribution of marijuana. Security personnel will be on site at all times to remove individuals not complying with Act 105 CMR 725.000. Preventing Public Consumption There will be no public consumption permitted on the premises of the MMTC or any of its ancillary facilities. This policy will be strictly enforced among patients, caregivers, and employees. Prior to purchasing medical cannabis at the MMTC, patients will be required to undergo an orientation session where they will be educated on medical marijuana law in Massachusetts. Patients will be instructed that they should only consume cannabis in a private residence. By signing the patient consent and agreement forms, the patients are confirming that they have completed the law and understand that public consumption is strictly prohibited under Massachusetts state law. Increased Demands on Watertown Fire Department f Natural Selections will not be cultivating medical marijuana on site at its MMTC. f Therefore, it does not expect that its operations will have any emergency incidents E 2629406 13 PRinceLOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 12 that will increase the burden on Watertown's fire department. Natural Selections will ensure that its MMTC is fully compliant with fire codes and fire prevention, and will form a relationship with the Watertown fire department and ensure that all staff members receive training in regards to preventative fire techniques, as well as fire suppression and avoidance. Natural Selections is committed to ensuring that its MMTC is fully compliant with fire code and fire safety prevention techniques, thereby causing no additional demand on the Watertown's emergency fire services. Increased Demands on Watertown's Emergency Services Natural Selections does not expect to require or impact Watertown's emergency services. However, Natural Selections expects that its Community Host Agreement will offset any such expenses. Increased Demands on Watertown's Health Services While Natural Selections expects that its MMTC will have a positive impact on the community's health and education, it does understand the potential health risks associated with medical marijuana. Natural Selections is committed to educating patients and caregivers about the potential risks of medical marijuana. Natural Selections will require that each patient undergo an orientation session so they understand all of the potential side effects and associated risks, including the dangers of drugged driving. Natural Selections also intends to hold educational seminars and programs in order to educate the community about responsible cannabis use, substance abuse, and HIVIAIDS prevention. Natural Selections intends to use its position as a MMTC to educate the community about substance abuse and the responsible use of cannabis. Including its preventive measures, Natural Selections expects that its Community Host Agreement will mitigate any potential financial demand on Watertown's health services. Increased Air, Noise, Light and/or Wafer Pollution Natural Selections intends to comply with all Federal, State, and local requirements regarding increased air, noise, light, and water pollution created by its proposed p osed MMTC. While Natural Selections does not intend that its MMTC will have a negative impact on the community, should any problems arise regarding increased air, noise, light, or water pollution, Natural Selections will work with the community to ameliorate any negative impact. Natural Selections will not be cultivating medical marijuana on-site at the proposed MMTC. Therefore, it does not expect an increase in air pollution at its dispensary location. Natural Selections does not expect an increase in noise pollution. It purposefully chose an industrial/commercial location to open its MMTC in order to avoid issues E associated with noise pollution. E f 2628406 IM PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 13 Natural Selections' security system will utilize motion-sensor lighting in order to prevent theft or breaches of security on the premises, especially at night. These motion-sensor lights will illuminate all entrances and the parking lot and will be used to detect loitering or intrusion. However, Natural Selections does not intend to illuminate the parking lot during daylight hours or beyond hours of operation, barring any emergency circumstance. This should minimize potential lighting pollution. Natural Selections chose a commercial area for its location in order to avoid problems associated with light pollution. It intends to work with its community in order to ensure that its additional lighting does not cause issues for surrounding businesses. Natural Selections will not be cultivating medical marijuana on site at its MMTC. Therefore, it does not anticipate an increase in water pollution at the dispensary. Employment for Watertown Residents Natural Selections is an equal opportunity employer and seeks candidates aligned with its core mission of building a compliant operation in good standing with regulators and producing safe, consistent cannabis products of the highest quality. Natural Selections seeks a seamless integration into the Watertown, Massachusetts community and intends to hire local residents with a proven work ethic and interest in educational development, as well as experience and skills relevant to the required duties of each position. Community Involvement Further, Natural Selections plans to build collaborative relationships with state and local governments to ensure a seamless integration into the community it serves. Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local organizations and non-profits that promote public health within Watertown, Massachusetts. Natural Selections takes a compassionate approach to providing medical cannabis, and is specifically committed to serving the veterans, elderly people, and low- income patients suffering from medical conditions. Natural Selections intends to establish a subsidized distribution network for low-income patients in Watertown, Massachusetts. The business's team members will also organize community outreach efforts to create a safer, cleaner town as well as provide transparency about their operations and education about the responsible use of medical cannabis. Natural Selections has spent a substantial amount of time in Watertown and understands the public health challenges that the community faces. Natural Selections is committed to ethical and transparent business practices and will work closely with the community to provide education on the benefits and risks associated with cannabis use. Natural Selections will hold regular seminars about scientific research related to cannabinoids and their associated benefits, as well as 2628406 0 PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 14 proper and responsible use of cannabis. Natural Selections is also committed to working with Watertown to provide public health educational programs geared towards education and prevention of HIV/AIDS and substance abuse. For the foregoing reasons, the proposed MMTC will not adversely affect the Proposed Site's neighborhood, or Watertown as a whole, but instead will offer various benefits to the neighborhood and Watertown. c) 9.05(b)(3). There will be no nuisance or serious hazard to vehicles or pedestrians; and The Proposed Site is an ideal location for the proposed MMTC with respect to traffic and congestion. The Proposed Site is located in a stand-alone building that is set back and almost completely shrouded from public view, from the right of way for both pedestrian and vehicular traffic on Elm Street. It sits tucked behind Building 1, which fronts Elm Street, thus blocking it from direct view. The Proposed Site is not directly visible from Arsenal or Arlington Street. Natural Selections will not expect an increase in traffic to its MMTC, which is located at 23 Elm Street, Building 2. It chose the Proposed Site because of its industrial neighborhood and its significant distance from schools, locations where minors may congregate, and high-traffic regions. Based on its current Market Analysis, Natural Selections does not expect to have more than 15 patients at its dispensary at peak hours during the first year of operations. Natural Selections will be open for 12 hours per day, from 8 AM to 8 PM, which should offset some concerns regarding traffic. Natural Selections submits the following Trip Generation Study prepared by Hayes Engineering, lnc. describing the estimated vehicle trip ends from the existing facility and proposed use. Average Daily Vehicle Trips and Peak Hour Trips for the proposed MMTC are calculated using data published by the Institute of Transportation Engineers (ITE) Trip Generation Manual, 9th Edition. The Proposed Site is best classified as Specialty Retail (ITE Land Use Code 826), defined as: ...generally small strip shopping centers that contain a variety of retail shops and specialize in qualify apparel, hard goods and services, such as real estate offices, dance studios, and small restaurants. The operation of a MMTC is in harmony with the foregoing description and does not change the Proposed Site's LUC from the existing condition. As such, no additional vehicle trip ends are created and no impacts to off-site traffic are anticipated as a result of the operation of a MMTC at the Proposed Site. 2628406 13 PRince LOB L Watertown Zoning Board of Appeals February 7, 2017 Page 15 The Property represents ±20,600-sf. of Specialty Retail space. Trip Generation Rates for the proposed ±2,545-sf. MMTC at the Proposed Site under various traffic scenarios are listed in the table below: Time Trip Ends Vehicle Period/Direction Per 1,000- Trip SF Ends Weekday Daily 44.32 113 Weekday AM 6.84 17 Peak Hour 48% 8 Entering • 52% 9 Exiting Weekday PM 5.02 13 Peak Hour • 56% 7 Entering 44% 6 Exiting Saturday Daily 42.04 107 1 Sunday Daily 20.43 52 As previously stated, the ITE Land Use Code Classification does not change as a result of the operation of a MMTC at the Proposed Site. Traffic impacts resulting from the operation of the proposed MMTC will not be substantially more detrimental than the existing use to the neighborhood. Lastly, Natural Selections proposes the use of 22 units of off-street parking to allow patients direct access to services. Deliveries will occur through the rear of the - reet loading which wil l be staggered and staged with building, with secure off-street g g g � gg secure unmarked vehicles). The proposed MMTC will not disturb the existing right of way and pedestrian access, and will not cause a serious hazard to vehicle or pedestrian traffic or create a nuisance, nor will it require the addition of any new parking or loading spaces. f ' Based on 2,545-sf. Gross Leasable Area. f f: 2628406 M PRince LL Watertown Zoning Board of Appeals February 7, 2017 Page 16 d) 9.05(b)(4). Adequate and appropriate facilities will be provided for the proper operation of the proposed use. Natural Selections proposes to re-use the existing building in which the Proposed Site is situated, as well as site amenities located at the Property, including parking and landscaping. Adequate parking is available for the patients and employees. Conformance with Zoning requirements is illustrated on the accompanying Special Permit Site Plan. Natural Selections is committed to quality assurance in all elements of its dispensing. All facilities used by Natural Selections will have adequate work areas and equipment, if any, for the intended task. The facilities will have sufficient space, a clean environment, and appropriate lighting, ventilation, heating, cooling, plumbing, washing and sanitation, as necessary. Natural Selections will implement its security measures to ensure the protection and safety of its patients, employees and the Watertown community. Natural Selections has determined that the utilities and public services available at the Proposed Site are adequate for its proposed use. Natural Selections withstood a vigorous application process by the DPH and demonstrated that it satisfied the requirements as to appropriateness of the Proposed Site. As detailed herein, Natural Selections' dispensing at the proposed MMTC will be strictly controlled and monitored under the Regulations and Natural Selections' license is subject to revocation if it fails to comply with the Regulations. IV. Natural Selections satisfies the provisions for a Special Permit for a, Medical Mariivana Treatment Center set forth in Section 8.04 of the, Ordinance. Natural Selections respectfully.submits, and requests that the Board find, that the proposed MMTC has satisfied the criteria required for the operation of a Medical Marijuana Treatment Center pursuant to Section 8.04 of the Ordinance, to the extent feasible, as follows: E { a) The Medical Marijuana Treatment Center fully complies with all of the applicable provisions and conditions of the Regulations; and Natural Selections is proposing to operate a MMTC at 23 Elm Street, Building 2, in Watertown. Natural Selections has undergone a thorough vetting and application process with the DPH. Because Natural Selections chose an appropriate location for the MMTC and has had many other mechanisms in place, including a proven track record of experience in the industry, it was selected to submit three (3) Siting Profiles in connection with its application for three (3) Licenses from the DPH. Natural Selections submitted its Application of Intent with the DPH on June 29, f 2015. After review of its application, which included an extensive review of the [ background and character of the members of Natural Selections' team, the DPH E 2628406 ON PRince LOB e L Watertown Zoning Board of Appeals February 7, 2017 Page 17 invited Natural Selections to the second phase of the application process, entitled "Management and Operations Profile". Shortly after receiving an invitation, Natural Selections prepared a comprehensive Management and Operations Profile application detailing, among other things, its business models, standard operating procedures and experience in the industry. After a thorough review the Management and Operations Profile application, the DPH invited Natural Selections to the third phase of the application process, entitled "Siting Profile". Natural Selections is currently processing its Siting Profile Application with the DPH and is confident that it will receive its provisional certificate of registration and final certificate of registration in due course. Furthermore, Natural Selections is willing to enter into a Host Community Agreement with Watertown. Many of the procedures and safeguards set forth in the Regulations, which are enforced and implemented by the DPH, are specifically designed to ensure the safe and discreet dispensing of medical marijuana so as to minimize and mitigate any impact the proposed MMTC may have on the surrounding community. Natural Selections will be subject to continued oversight by the DPH and is required to adhere to stringent requirements for the security, storage, handling, testing, packaging, labeling and dispensing of medical marijuana. The Regulations limit the logos used for labeling, signage and other materials and specifically prohibits the use of medical symbols, images of marijuana, related paraphernalia, and colloquial references to cannabis and marijuana as logos. The Regulations limit the illumination of external signage and prohibits any displaying of advertisements for marijuana, graphics related to marijuana or paraphernalia on the exterior of the MMTC. All of these requirements were designed in an effort to minimize and mitigate any adverse effects a MMTC may have on a neighborhood. As stated above, the DPH will continue to enforce these requirements and Natural Selections' license can be revoked for any violations. Further, because Natural Selections chose an appropriate location for the MMTC and had many other mechanisms in place, including a proven track record of experience in the industry, it was selected to submit three (3) Siting Profiles in connection with its application for three (3) Licenses from the DPH. b) The Medical Marijuana Treatment Center obtains a Special Permit. Natural Selections respectfully submits that it has supplied sufficient information and materials herein to satisfy all of the conditions and requirements of Section 8.04 and other applicable sections of the Ordinance. V. Natural Selections' proposed MMTC is within the purview of and satisfies the Statutory and Reaulatory framework for Medicinal. Mariivana in Massachusetts. The citizens of Massachusetts legalized the medical use of marijuana for qualified patients suffering from debilitating medical conditions in November of 2012. As of 2628406 0 PRince LOB L Watertown Zoning Board of Appeals February 7, 2017 Page 18 December 31, 2016, there were a total of nine (9) Medical Marijuana Treatment Centers open for sales and approximately thirty three thousand five hundred and forty-three (33,543) active patients. It is our understanding that the current supply available does not meet the demand that the patients require. Natural Selections respectfully submits that it is the intent of the legislature to not further delay the opening of Medical Marijuana Treatment Centers and that the DPH, acting as the regulatory body for the Commonwealth of Massachusetts, has promulgated a regulatory framework to implement the humanitarian use of medical marijuana. Natural Selections has adhered to that regulatory framework and has been invited to the final stage of the application process prior to receipt of a Provisional Certificate of Registration. As such, Natural Selections respectfully requests the Board approve this location pursuant to the guidelines set forth in the Chapter 369 of the Acts of 2012, known as the Act for the Humanitarian Medical Use of Marijuana (the "Act") and the Regulation. Furthermore, in two recent Suffolk Superior Court decisions, Judge Billings and Judge Kaplan relied on the clear language in the Act to find that the legislature established a regulatory framework wherein the DPH was to license one dispensary in each county within one year. The Court went on to further infer that delays in the licensing process resulting in the failure to get patients access to the medical relief they are entitled to under the Act is precisely the type of prejudice the regulatory framework was designed to prevent, and that the public interest would be harmed by further delays in the registration and opening of Medical Marijuana Dispensaries. See Medical Marijuana of Massachusetts, Inc. vs. Department of Public Health, Suffolk Superior Court, No. 2014-2722-BLS1, April 27, 2015. In November of 2012, Massachusetts voters overwhelmingly endorsed access to medical marijuana. As a result, the legislature enacted the Act for Humanitarian Use of Marijuana, which became effective on January 1, 2013. Of significance to this Application is that the Act provides that: "in the first year after the effective date, the Department [of Public Health] shall issue registrations for up to thirty-five non- profit medical marijuana treatment centers". As such, it is clear that the intent of the Legislature, in including the aforementioned language in the Act, was to emphasize the importance of having Treatment Center's operational in Massachusetts within a year. As is often the case, this process has been slower than originally anticipated. Notwithstanding the delays, Natural Selections has been invited to the Siting Profile phase of the DPH application process and is actively pursuing its License for the proposed MMTC at the Proposed Site. As stated above, Natural Selections respectfully submits that it is the intent of the legislature and the Court to not further delay the opening of Medical Marijuana Treatment Centers. Pursuant to the guidelines set forth in the Act and the Regulation, Natural Selections respectfully requests the Board approve this location. 2628406 U, PRince LOBeL Watertown Zoning Board of Appeals February 7, 2017 Page 19 Vlf. Summary Natural Selections hereby requests that the Board determine that its proposed MMTC will not have any adverse effect on the neighborhood within which the Proposed Site is located in particular, and Watertown as a whole. The findings are made in view of the particular characteristics of the Proposed Site and of Natural Selections' proposed MMTC, as detailed above and herein, that the Proposed Site is the most appropriate location for the MMTC and that adequate and appropriate facilities will be provided for the proper operation of the use and finally that this use will not create any nuisance. For the foregoing reasons Natural Selections respectfully requests that the Board grant the foregoing relief in the form of a Special Permit and such other relief as the Board deems necessary to allow the operation of Natural Selections' proposed MMTC. Sing ly, .f Michael P. Ross, Esq. Direct: 617-456-8149 Email: mross@princelobel.com f 2628406 i :� f ;� �. PROPERTY PHOTOGRAPHS/PLAN BUILDING 2 (PROJ[CT LOCATION) ��- OFF-STREET PARKING loop ro � _ �, - ✓;it y L Y _' ftYrr'h ar7 r a r\ �. ;a Pr -. . u r • i --. VIEW FROM ELM STREET — 2500144.1 September 16, 2016 Natural Selections — Facility Security Program PRIVAT E& CONFIDENTIAL Daniel P. Linskey Kroll Managing Director— Investigations and Disputes daniel.linskey@kroll.com 10 High Street, 3`d Floor, Boston, MA 02110 T 617.210.7471 1 M 857.275.2510 Kroll@ Kroll. Facility Security Program Private & Confidential RESTRICTED USE WARNING Kroll prepared this report at the request of the client to whom it is furnished. The client agrees that reports and information received from Kroll, including this report, are strictly confidential and are intended solely for the private and exclusive use of the client. Any other use and any communication, publication, disclosure, dissemination or reproduction of this report or any portion of its contents without the written consent of Kroll is strictly forbidden. Kroll assumes no direct, indirect or consequential liability to any third party or any other person who is not the intended addressee of this report for the information contained herein, its interpretation or applications, or for omissions, or for reliance by any such third party or other person thereon. To the extent information provided in this report is based on a review of publicly available records, such information, as presented, relies upon the accuracy and completeness of those records, which have not been corroborated by Kroll. Statements herein concerning financial, regulatory or legal matters should be understood to be general observations based solely on Kroll's experience as risk consultants and may not be relied upon as financial, regulatory or legal advice, which Kroll is not authorized to provide. All such matters should be reviewed with appropriately qualified advisors in these areas. THIS REPORT DOES NOT CONSTITUTE A RECOMMENDATION, ENDORSEMENT, OPINION OR APPROVAL OF ANY KIND WITH RESPECT TO ANY TRANSACTION, DECISION OR EVALUATION, AND SHOULD NOT BE RELIED UPON AS SUCH UNDER ANY CIRCUMSTANCES. PRIVATE&CONFIDENTIAL I Kroll. Facility Security Program CONTENTS 1. INTRODUCTION...................................................................................................................1 2. METHODOLOGY..................................................................................................................2 3. SECURITY PROGRAM.........................................................................................................3 ■ General Requirements ...................... ..3 ......................................................................... ■ Limited Access Areas...................... .......4 ......................................................................... • Security and Alarm Systems................... .4 ........................................................................ • Registered Marijuana Dispensary Transportation of Marijuana and MIPs........................6 • Incident Reporting .................... PRIVATE &CONFIDENTIAL i Kroll„ Facility Security Program 1 INTRODUCTION Kroll has been engaged by NS AJO Holdings Inc. dba Natural Selections to develop a security program for their medical marijuana dispensary located at 23 Elm Street, Watertown Massachusetts. The program is to comply with and exceed the statute mandated by the Commonwealth of Massachusetts Regulations 105 CMR 725.110 ("Security Requirements for Registered Marijuana Dispensaries"). Along with the security program, Kroll has developed a physical security technical implementation plan for the facility. PRIVATE& CONFIDENTIAL 1 Kroll Facility Security Program 2 METHODOLOGY Kroll utilized a team of physical security experts led by Managing Director Daniel Linskey ("Linskey"), former Superintendent-in-Chief of the Boston Police Department ("BPD") and a 27-year veteran of the department. He notably led the BPD through some of the most tragic and contentious events in the city's history, including the Boston Marathon Bombings and the Occupy Movement. At Kroll, Linskey serves clients in diverse industries with uncommon experience in investigations, crisis response and risk management, as well as personal, physical and operational security strategies. Widely respected for his knowledge of the complexities inherent in law enforcement and homeland security, Linskey has also consulted with numerous national and international government agencies on a broad range of challenges, including large-scale event management, crisis leadership and preparedness and community engagement strategies. Linskey has extensive experience securing facilities and developing security protocols including overseeing the enhancement of the security program at the City of Boston Evidence Management Facility. Kroll's team conducted a site visit of the proposed facility and researched the requirements of the statute mandated by the Commonwealth of Massachusetts Regulations 105 CMR 725.110. The team conducted meetings with the Watertown Police Department to discuss any concerns or requirements in order to i ensure that the facility did not impact the quality of life of the surrounding community. The team also [ conducted research as to the industrys best practices and incorporated them into the following recommendations. Technology and programing enhancements were further incorporated from Kroll's experience with similar high security industries. i PRIVATE&CONFIDENTIAL i 2 l Kroll Facility Security Program 3 SECURITY PROGRAM General Requirements 1. Only registered qualifying patients, personal caregivers, dispensary agents and other authorized individuals are allowed access to the Registered Marijuana Dispensary("RMD"). 2. If individuals are not engaged in activity permitted by Chapter 369 of the Acts of 2012, An Act for the Humanitarian Medical Use of Marijuana ("the Act"), they will immediately be removed from the premises. 3. Marijuana is disposed in accordance with relevant Massachusetts laws. 4. Access to Limited Access Areas is only granted to a minimal number of key employees. 5. All finished marijuana is stored in a secure, locked safe or vault to prevent loss or theft, 6. All safes, vaults and other equipment used for marijuana or Marijuana-Infused Products ("MIPs") are kept locked and secured. 7. All locks and security equipment will be well maintained. 8. Only limited authorized personnel have access to keys. 9. Only specifically authorized personnel have access to security measures, such as passwords and combinations. 10. Outside perimeter of the facility will have sufficient lighting to illuminate the entire peremiter. 11. Area outside the facility will not have bushes or other landscaping that allows individuals to conceal themselves. 12. Emergency policies and procedures have been established. 13. RMD is not within a radius of 500 feet of an area where children congregate. PRIVATE&CONFIDENTIAL 3 Kroll-0 Facility Security Program Limited Access Areas 1. Limited Access Areas identified by a 12" x 12" (minimum)sign that states "Do Not Enter—Limited Access Area — Access Limited to Authorized Personnel Only." Lettering is no smaller than one inch in height. 2. Dispensary agents will be required to display an identification badge issued by the facility at all times while at the facility or transporting marijuana. 3. Outside visitors, vendors and contractors are required to obtain a visitor identification badge, which will be displayed at all times, prior to entering a Limited Access Area. Individuals must be escorted by an authorized dispensary agent. All visitors log in and out, and badges will be returned to the facility upon exit. Visitor logs will available for inspection by the Department of Health or Watertown Police Department at all times. Security and Alarm Systems 1. Alarm on all entry points and perimeter windows. Windows will have security enhancement to prevent unauthorized access. 2. Panic alarm connected to local public safety 1 law enforcement officials. 3. Video surveillance system equipped with a failure notification system, providing an audible, text or visual notification of any failure in the surveillance system. The failure notification system will alert designated employees, within five minutes of the issue, via telephone, email or text message. Any system failure is reported to relevant authorities. 4. Camera coverage for all Limited Access Areas, point-of-sale areas, security rooms, all points of ingress and egress to Limited Access Areas, all areas where marijuana or marijuana product is displayed for sale, and all points of ingress and egress to the exterior of the Licensed Premises. Cameras angled to capture the clear identification of any person entering or exiting the Limited Access Areas. 5. Sufficient lighting to ensure video surveillance equipment captures high resolution images during all times. 6. One camera will be dedicated to record the access points to the secured surveillance recording area. 7. High resolution cameras will be directly connected to a recording DVR for 24 hours a day, with 90 days mandatory retention. Recordings will not destroyed or altered and will be retained as long as necessary if recording contains relevant information for a pending investigation or proceeding. 8. Video surveillance equipment consisting of a DVR capable of producing still color photo (live or recorded), connected to a color printer. PRIVATE&CONFIDENTIAL 4 'A Kroll. Facility Security Program 9. Commercial grade locks on door(s) leading to Limited Access Area where DVR is stored. 10. DVR enclosed in a commercial grade lock box. DVR will remain locked at all times other than to access recordings or for contractual maintenance by an approved security company. 11. List placed on outside of secured DVR box of all managers granted access to the DVR. 12. DVR "Surveillance Equipment Maintenance Activity Log" placed within the DVR box to be filled out by any individual who accesses or performs work on the video surveillance system. Information to be included: Identify of the individual, service date and time, and reason for service. 13. Date and time stamp embedded on all recordings. The date and time will not significantly obscure the picture. 14. Maintenance of all records applicable to the video surveillance system, 15. Chronological point-of-sale log made available in conjunction with the recorded video of those transactions under request by a governing authority. 16. Video recording that can export still images in an industry standard image format, including .jpg, .bmp and .gif. Exported video with ability to be archived in a proprietary format to ensure authentication of the video and guarantees no alteration of the image. Exported video can be saved in an industry standard file format that can be played on a standard computer operating system. Prior to disposal, all recordings are deleted or destroyed. 17. Access to surveillance areas limited to persons who are essential to surveillance operations, such as law enforcement authorities. Current list of authorized employees and service personnel with access to surveillance room available to Department of Public Health, upon request. 18. Locked surveillance rooms that are not used for any other function. 19. Security equipment in good working order and inspected and tested regularly, at least every 30 days. 20. Back-up alarm system, provided by a company supplying commercial grade equipment. Back-up alarm system has all capabilities of primary system but will not be provided by the same company. 21. Ability to remain operational during a power outage. 22. Manager on duty each day who performs security audit to ensure all recording retention is maintained under the requirements set by relevant authorities. 23. Management with DVR Access expected to monitor all activity during store hours. 24. Video surveillance system equipped with text message notifications for monitoring overnight activity. 25. Security guards employed to help monitor suspicious activity. If approved by the Watertown Police Department, it is the preference of the company to have a professionally trained armed security officer 24 hours a day 365 days a year. PRIVATE& CONFIDENTIAL I 5 Kroll. Facility Security Program 26. If requested by the Watertown Police Department the facility would provide the ability for the department to conduct live monitoring of their CCTV by the police department. 27. The facility will meet with members Watertown Police Department quarterly to receive any concerns or issues that may impact the quality of life of the community. The facility will consult with the department on hours of operations or any issues of concern. Registered Marijuana Dispensary Transportation of Marijuana and MIPs 1. Dispensary Agent only authorized individual to transport marijuana or MIPs on behalf of RMD. 2. The facility will conduct the following steps: • All marijuana to be transported is weighed, inventoried and accounted for on video prior to its leaving original location. • All marijuana re-weighed, re-inventoried and re-accounted for on video within eight hours after arrival at destination facility, except in case of home delivery. • Any unusual discrepancy in weight or inventory documented and reported to Department of Health and local law enforcement within 24 hours. • Shipping manifest completed for retention by the original location and copy of manifest carried with transported products. • Copy of the manifest securely transmitted to receiving facility prior to transport, with the exception of home delivery. 3. Shipping manifests retained by facility for no less than one year and made available to Department of Health upon request. 4. Marijuana will be transported in a vehicle with secured, locked compartment, and vehicle has no markings or any indications it is transporting marijuana. 5. Vehicle transporting marijuana travels directly to the facility and does not make any stops. In case of emergency, a detailed log describing the exact nature of the event and people is maintained. 6. Delivery times and routes are randomized. 7. Minimum of two dispensary agents are required to staff transport vehicles. At least one dispensary agent remains with the vehicle at all times. t3. Dispensary agents will have secure form of communication with personnel at the sending site. 9. Dispensary agents will carry a Department of Health-issued registration card when transporting marijuana and will present card upon request by authorized officials. 10. Any accidents, losses or other reportable incidents are reported to the Department of Health and local law enforcement within 24 hours. I PRIVATE&CONFIDENTIAL C 6 Kroll, Facility Security Program 11. Vehicles used in the transport of marijuana have a global positioning system monitoring device, reviewed by RMD during transport. 12. Delivery to homes of registered qualifying patients or personal caregivers will be conducted in accordance with Massachusetts laws. Incident Reporting 1. Upon discovery of a crime, possible crime or any breach of security, authorities will be immediately notified with as much information and details as possible. 2. Management will work with and cooperate with authorities providing any requested information or documentation as soon as possible. 3. An official report will be provided to the Department of Health identifying all marijuana and marijuana product that has been damaged or taken during the event. The report will be given no later than 10 days after the crime transpired, but all efforts will be made to make it as soon as practicable. 4. All documentation related to incident that is reportable pursuant to Massachusetts laws will be maintained by the facility for no less than one year and made available to all relevant authorities upon request. 5. The facility will obtain, at its own expense, a security system audit by a vendor approved by the Department of Health, on an annual basis. Audit report will be submitted to the Department of Health no later than 30 days after the audit is conducted. If issues are identified, the facility will submit a plan to mitigate the concerns within 10 business days of submitting the audit report, f i E Lf V Er�E l PRIVATE&CONFIDENTIAL KFOII@ 10 High Street, 3rd Floor Boston, MA 02110 E 5 Pei Kro I I Security System Narrative Dispensary — Watertown, MA DRAFT September 16, 2016 Private and Confidential Certain Kroll companies provide investigative ve services. See www.kroll.com/licensing for state licensing information. Security System Narrative Kroll. Private & Confidential This report was prepared by Kroll at the request of the client to whom it is furnished. The client agrees that reports and information received from Kroll, including this report, are strictly confidential and are intended solely for the private and exclusive use of the client only in connection with a business, investment or other commercial purpose. Any other use (including for employment purposes, credit evaluation or insurance underwriting purposes) is strictly prohibited and client has agreed that no such use will occur. Any communication, publication, disclosure, dissemination or reproduction of this report or any portion of its contents to third parties without the advance written consent of Kroll is not authorized. Kroll assumes no direct, indirect or consequential liability to any third party or any other person who is not the intended addressee of this report for the information contained herein, its interpretation or applications, or for omissions, or for reliance by any such third party or other person thereon. To the extent information provided in this report is based on a review of publicly-available records, such information, as presented, relies upon the accuracy and completeness of those records, which have not been corroborated by Kroll. Statements herein concerning financial, regulatory or legal matters should be understood to be general observations based solely on Kroll's experience as risk consultants and may not be relied upon as financial, regulatory or legal advice, which Kroll is not authorized to provide. All such matters should be reviewed with appropriately qualified advisors in these areas. THIS REPORT DOES NOT CONSTITUTE A RECOMMENDATION, ENDORSEMENT, OPINION OR APPROVAL OF ANY KIND WITH RESPECT TO ANY TRANSACTION, DECISION OR EVALUATION, AND SHOULD NOT BE RELIED UPON AS SUCH UNDER ANY CIRCUMSTANCES, Private and Confidential 2 September 16, 2016 ��,I <f0l Security System Narrative I. introduction The security system for the Natural Selections (NS) dispensary in Watertown, MA is designed to provide a safe and secure environment for staff, the public, and storage/handling of Marijuana in compliance with Code of Massachusetts Regulations 105 CMR 725.110(D). Kroll also considered security principles of Crime Prevention Through Environmental Design (CPTED), Concentric Circles of Protection, and Integrated Design when evaluating opportunities to deter a threat from entering and circulating within the building envelope. CPTED is a concept that utilizes planned passive resources such as architectural barriers, landscaping, and lighting to reduce the necessity of traditional technical and operational security elements to reduce vulnerability to crime. The key concepts of CPTED include: • Natural Access Control: Use of doors, fences, landscaping, and other man-made and natural obstacles to limit access into the building or other defined interior space. • Natural Surveillance: Increasing visibility by occupants and observers (security and staff) to increase the detection of unauthorized individuals or misconduct within a facility. r Natural Boundary Definition: Establishing a sense of ownership by occupants to increase vigilance in identifying intruders. This sends the message that would-be-offenders will be identified. The concept of "Concentric Circles of Protection" is based on varying levels of protection originating at the site perimeter, building perimeter, lobby areas, and interior areas with special control requirements, becoming increasingly more stringent as one proceeds through each level to reach the most critical areas. Intervention zones between each layer of the circle provide opportunities for control, detection, evaluation, and response to undesired activity, intruders or other unauthorized individuals, The Integrated Design Philosophy establishes effective security through the integration of electronic systems with architectural elements, enhanced by security staff and procedures. When the integration of these elements is effectively executed, a synergy is created that meets the desired security objective. The premise for using this concept is that architectural, operational and electronic elements must be implemented to complement one another; thereby creating collaboration between them that results in a strong security program, No one element of the group can stand-alone or operate independently and provide adequate protection. Specifics of the elements used include: Private and Confidential 3 September 16, 2016 Security System Narrative ■ Architectural Security measures address items such as perimeter barriers, lighting, critical building services, spatial adjacencies, and control barriers. N Operational Security measures address items such as staff and public access control, staffing, monitoring and administration of systems. ■ Electronic Security measures address items such as access control and alarm monitoring, video surveillance, and security communications. E Private and Confidential 4 September 16, 2016 h Krol l, Security System Narrative II. Security Measures Security measures for the NS dispensary consist of both physical barriers and electronic systems that work in concert to provide a robust security program. These measures include: ■ Secure Door and Window Hardware ■ Security Mesh ■ Primary Intrusion Alarm System ■ Backup Intrusion Alarm System ■ Video Surveillance System ■ Access Control System ■ Entry& Exit Door Interlock System A diagram showing specific applications of these security measures is provided in Appendix A. Physical Security Measures Measures will be employed by NS that ensure a secure physical perimeter is provided around their entire tenant space as well as walls surrounding the Limited Access Area (LAA). NS will install security mesh that extends from atop the tenant partition walls to the roof deck, which will mitigate climbing over the wall from the adjacent tenant space. To minimize perimeter entry points, NS will be walling over two single metal doors, one double metal door and tour metal-framed windows that exist along the building perimeter. Doors concealed in walls will be securely bolted from the interior side. Security mesh fastened to surrounding masonry will secure concealed windows. Security mesh will also be utilized to harden the perimeter walls of the LAA to deter penetration through its walls, Accessible perimeter doors into the tenant space will be provided with secure locking hardware which will remain secure at all times except when being accessed by authorized persons. One operable perimeter window will remain securely latched at all times. Two fixed windows at ground level will be frosted or opaque to prevent visibility inside the dispensary from the exterior. Intrusion Alarm Systems Intrusion detection for the NS dispensary is comprised of two independent commercial-grade alarm systems — a primary and a backup -- to ensure an intrusion will be detected and reported should a failure of either system occur. The primary alarm system (PAS) and the backup alarm system (BAS) Private and Confidential 5 September 16, 2016 Security System Narrative will be installed, serviced and monitored by separate and unrelated security vendors to ensure redundancy. Perimeter detection of an intrusion is provided using door contacts on all operable perimeter doors and windows and glass break detection for all exposed perimeter glass. Interior intrusion detection is provided by motion detection in the sales area, an office and the LAA. In addition to intrusion devices, hold-up/panic alarms are provided at each point of sale register location within the sales area, in each office and in the LAA. The intrusion alarm systems will be controlled by numeric keypad arming stations located inside the entry and exit doors. Keypads will display system armed/disarmed status, status of security devices and any trouble notifications. Authorized users will be issued unique arm/disarm codes to identify who armed or disarmed the systems at a given time. A duress alarm function will be provided at each PAS and BAS arming station to notify law-enforcement that an authorized user has been forced by an intruder to disarm an alarm system, The PAS and SAS are provided separate detection of intrusion for all perimeter door and window contacts, glass break detectors and motion detectors to ensure a device failure on one system will not compromise intrusion detection by the other. Both systems will have backup batteries for continued operation during power failures. Video Surveillance System The video surveillance system (VSS) is comprised of network-based video cameras and network- based head-end equipment for viewing, recording and playback of video. VSS head-end equipment will be located in the LAA to ensure access is highly restricted. Cameras will be located around the exterior perimeter of the NS tenant space to record activity in nearby driveways, parking areas and the building perimeter; at entry and exit doors to record and identify all who enter or exit the dispensary; and areas where controlled products will be stored, processed, handled and sold. The VSS will record cameras for a minimum of 90 days and retain (at minimum) the last 24 hours for immediate retrieval and playback. The VSS will to save or archive video relating to a particular incident under investigation or pending legal/administrative action for as long as necessary and export still images to industry standard formats. Additionally, the VSS will be provided with a uninterruptible power source for continued operation during a power failure. Access Control System A numeric keypad access control system (ACS) will be provided at the LAA door to limit access those issued a keypad code, Each person authorized to enter the LAA will be issued a unique and Private and Confidential 6 September 16, 2016 K r o Security System Narrative ll. personally identifiable numeric code, which when used, will be logged by the ACS by user code. The keypad will be managed by a separate controller such that damaging or tampering with the keypad will not unlock the LAA door. The ACS controller will be located in the LAA and be provided with backup power supply to ensure operation during a power failure. Door Interlock System An inner and outer door set form a vestibule at the entry and exit points of the dispensary which are configured similar as a mantrap to ensure authorized persons entering or exiting cannot allow an unauthorized person into the dispensary. The vestibule doors are controlled such that only one door can be unlocked at a time. Doors are logically-controlled by a door interlock controller located in the LAA. Door release buttons are provided at the reception desk for the entry doors and at the sales counter for the exit doors. To enter, a person must check in at the reception desk. Once properly vetted, the receptionist releases the outer entry door to allow them to enter the entry vestibule. Once inside the entry vestibule and the outer entry door is closed and secure, the inner entry door will unlock to allow them into the sales area. The entry vestibule doors are typically locked when not in use to prevent unauthorized entry or exiting through the entry vestibule. For exiting, a person can press on the exit bar to unlock the inner exit door. Once inside the exit vestibule and the inner exit door is closed and secure, the outer exit door will unlock to allow them out of the building. While the outer exit door is open, the inner door is locked to prevent it from being opened until the outer exit door is closed and secure. Note: These door controls can be overridden as required by life-safety code, The outer entry door is unlocked from the dispensary reception desk to allowing an authorized person to enter the vestibule. Once the outer door is closed, the inner door can be unlocked to allow entry into the sales area. For exiting, the inner exit door can be opened . Once Electrified locking hardware on each door provides independent control of each door such that when one door is open, the other is comprised of network-based video cameras and network-based head-end equipment for viewing, recording and playback of video. VSS head-end equipment will be located in the LAA to ensure access is highly restricted. Cameras will be located around the exterior perimeter of the NS tenant space to record activity in nearby driveways, parking areas and the building perimeter; at entry and Private and Confidential 7 September 16, 2016 Kroll Security System Narrative exit doors to record and identify all who enter or exit the dispensary; and areas where controlled products will be stored, processed, handled and sold. in the sale inside all areas where marijuana-based product will be stored or handled including is comprised of two independent commercial-grade alarm systems — a primary and a backup — to ensure an intrusion will be detected and reported should a failure of either system occur. The primary alarm system (PAS) and the backup alarm system (BAS) will be installed, serviced and monitored by separate and unrelated security vendors to ensure redundancy. Private and Confidential 8 September 16, 2016 K F o security System Narrative Il I. Appendix A — Security System Diagram Private and Confidential 9 September 16, 2016 Window Concealed in Wall-Security Mesh Door Concealed 1 V --r Wintlow Concealed in Window Concealed in over Window in Wall Bolted Wall-Security Mesh I Wall-Securil Mesh Y Fixed Multi-paned Fastened to Masonry. Closed. over Window aver Window Glass Window rF�laslenetl to Masonry. Faslenetl to Masonry. - �yI^ \II 62 6`" ", � � >/� SYMBOL LEGEND . . � ,✓� . •... .� .,�, - i,- . a .♦ _^. ��.=> - •. ..i ..- ♦ 1 •, _ _ \//. �\ ,., PRIMARY ALARM SYSTEM •�.•`gas_ .._.:= ( / -\ AP f % 1 I ' ` GB GB MD• G ALARM CONTROL PANEL MD 11r NI MD I oC DOOR CONTACT S0 '� S0� - SS safe/ secur >iy room MD' DV ED DURESS BUTTON 1 , , up \ I El/gyp ACS DI inventory I 1 office - GB GLASS BREAK DETECTOR Mar office : AP AP ..� ' 1 11'OrI Of'fiCe NP ARM I DISARM KEYPAD / LS 122$0.FT, - p p Security Mesh 122 SO.FT. r KP inside Wall. Door Concealed MD 90'MOTION DETECTOR hcp r m h trOom DG Wall Rolled I 1 I Closed. 17� MD 380°MOTION DETECTOR II DC ; t BACKUP ALARM SYSTEM ............... 1.... ......... ' Ir I•I . I AP ALARM CONTROL PANEL II II Rerrrove®ci ,{ /� I I ; ; LOlRIg ' ,> DC DOOR CONTACT or ~ V r I I I ( GB GLASS BREAK DETECTOR a li II e ye �D ❑R O❑R I --------' - ,---� HP ARM/DIIOND KEYPAD ........... ^ . ..........• , T.-------.,...--- -.-ya ' MD 9D°MOTIO DETECTOR 4...I....,.. • y breakHoom MD 360°MOTION DETECTOR 1 / kiCNipnette ( 1 El 42 0" VIDEO SURVEILLANCE SYSTEM ISecurity Mesh from I ft 1 1 lop of Paliilion Wall I , , Window R Concealed in VSS VSS WORKSTATION AND RECORDER to Roof Deck. 1L V I I e 1 , Wall-Security Mesh - over Window sales floor 1 Faslenetl to Masonry. ��E UPS UNINTERRUPTIBLE POWER SOURCE f I I , I 1 I ; 12M SO.FT. 1 1 p VIDEO CAMERA 1 I ', OOOft INTERLOCK SYSTEM 1 , I DI DOOR INTERLOCK CONTROLLER _----- ----------------------------------1 I gyp............ �q /- -- - _--_.- ----..---------•--.-------.._{ I J�DC DC DOOR CONTACT E)dSft WSiiS.j1J'y],/,� t0 bB rl?n1lT/� DRDOOR RELEASE BUTTON '"' � ' /� DR 1 I I I EL ELECTRIFIED LOCKING HARDWARE I 1 I O erable GBFire1 . Ud1 p1 � I I Multi-panetl Glass�I'(n', %/�1 I KP 1 i ( I Wlntlow, Gp MISCELLANEOUS ni /// I I D I I 11 I I R POINT OF SALE REGISTER 12'61 reCeptloJa, , , I I , , ❑ I r I I I I I I © SAFE DC EL DC - Dc DC I 1 I e DC EL EL I , I I est I p I I 11 Ica - ce ce GB I ca GB I DC DC L'. a=C',.r - . . .. I,.a .. ._ °' • . '.I� /.L,.,_• . �- .. .. °. . DC EL cc 1 boos 1 OII Door Concealetl Fixed Glass Fixed Glass D Wall Bolted Window Window Closed. PROPOSED FIRST FLOOR PLAN Scale: 1/8" 2545 TOW SO. FT. T&at OoC jw%y 85 Persons 6 Business Operations and Marketing Plan Natural Selections is an established organization committed to providing access to duality natural medicine on the basis of science research and development.Natural Selections,Colorado has emerged as a leading cannabis organization in Colorado with a strong reputation for its commitment to utmost quality care for its clients.Natural Selections has set forth the following objectives in establishing its organization: 1) A compliant operation in good standing with regulators, 2) Safe, consistent, and effective products of the highest quality, 3) Commitment to serving and educating patients and caregivers, and 4) Commitment to scientific research and development. Natural Selections will emulate Natural Selections, Colorado's marketing strategy and build a strong brand rooted in education, community involvement and participation, and a rigorous commitment to scientific research and development. The applicant is committed to utilizing logos, signage, and packaging that are compliant with 105 CMR 725.105(L) and reflect its commitment to natural, quality products. Natural Selections intends to integrate seamlessly into the Watertown, Massachusetts community and has identified charitable partners to partner with to support the community and improve the surrounding areas. Logo,Signage,& Packaging i The,applicant is committed to avoiding any images or=branding strategies that Would`seek to influence or attract consumers flom the general public.Natural Selections will only target',' medical.patients with the conditions eligible.for treatmcnt under the current Massachusetts i legislation. The applicant is cornmitted'to utilizing tasteful branding strategies that are aligned with its values and compliant with 105 CMR 725.105(L). The applicant has chosen its name, "Natural Selections,"to reflect its commitment to providing high quality,natural plant-based medicine to its patients. The Natural Selections brand reflects the medicinal chemical compounds found in cannabis plants, rather than the cannabis plant itself. As per the regulations cited under 105 CMR 725.105(L) the applicant will not utilize medical symbols, images of marijuana, related paraphernalia, and colloquial references to cannabis and marijuana in any of its branding materials. The company also will never produce any items for sale or promotional gifts,such as T-shirts or novelty items, bearing a symbol of or references to marijuana or MIPs, including the logo of the RMD. Sign age The applicant will ensure that external signage will only display the registered company name to assist qualifying patients in locating the business. As per 105 CMR 725.105(L), the cultivation facility will not display Natural Selections' name, The applicant will ensure that all medical marijuana, products, and associated products are not visible to a person from the exterior of the RMD facility and all external signage is in compliance with 105 CMR 725.105(L). Packaging Natural Selections will invest in packaging based on brand reliability, transparency and quality that is in compliance with the regulations outlined under 105 CMR 725.105(E). Each product will 37 be contained in simple packaging that is opaque and child proof In the interior, there will be a label describing nutrients, pesticides, ingredients,and recommendations on methods of intake, dosing,batch information and contact information. All products also must have labels on them, detailing the potency, the types of chemicals used in cultivation and other information. Education In lieu of traditional business marketing and advertising strategies, the applicant will utilize extensive educational materials, seminars, and campaigns to educate patients regarding the use of medical cannabis. Natural Selections will begin its marketing efforts with a grassroots campaign to educate patients about the effects of medicinal cannabis, methods of consumption, as well as cannabinoids and their associated benefits. The applicant's website will have extensive information about Natural Selections' mission, research, strains, and testing results from registered labs, Registered patients and caregivers will be able to access a list of current cannabis strains and products available at the MMTC. In compliance with 105 CMR 725.105(L)(5), the list will not include prices. Prices will be available on a secure website or on printed menus for registered patients and caregivers. The company will also provide an extensive database with links to articles from trusted sources such as PubMed and GW Pharmaceuticals about scientific development in the cannabis field. The team has strong relationships with cannabis-related research groups throughout the country and will stay abreast regarding developments in the field. Natural Selections,' website will also contain specific information about cannabinoids"and their l associated benefits.Natural Selections acknowledges the lack of double-blind placebo-controlled E tests illustrating the efficacy of cannabis in trcatin�medical conditions' However, the applicant is aggregating data based onpatient feedback.and carefully studying plant and terpenoid profiles to provide its patients with as much information as possible.Natural Selections will refrain from malting any statement,design,representation,picture, or illustration related to the safety or efficacy of marijuana unless supported by substantial evidence or clinical data with reasonable scientific rigor, which shall be made available upon the request of a registrant or the Department. Natural Selections has allocated a sufficient budget to invest in Search Engine Optimization to ensure that qualified patients are able to access their content on the web. The applicant will also invest in written materials and handouts to educate employees and patients on methods of consumption,dosage, and types of cannabinoids and their associated effects. The applicant is committed to providing the utmost quality care to its patients and educating employees and patients on all potential side effects. The educational materials will provide information on the following: X) Methods of cannabis consumption Inhaling cannabis Patients may elect to inhale cannabis by packing a small amount of dried flower into a pipe or rolling paper or utilizing a vaporizer. Patients will be advised to begin with a portion of the prescribed dose of cannabis and then, if necessary, increase the amount while taking note of how the medication affects their body. Patients should note that they may experience side effects such as coughing and irritation of the throat. Patients will be informed to use caution 38 when inhaling cannabis and to try a different product or strain of cannabis if they experience any negative side effects. When inhaling cannabis ® Take short, shallow breaths ® Slowly increase dosage and keep note of how the product interacts with the body Orally Administered Cannabis-Infused Protlttets Consuming cannabis-infused products affects patients differently than inhaling cannabis. These products can affect patients differently depending on their weight, metabolism, diet/nutrition, and experience or history of cannabis use. The applicant will recommend that when consuming food-based cannabis, tinctures, or capsules, patients begin by consuming '14 of their recommended dosage. Beginning with a portion of the recommended dose is the best way for a patient to learn how a strain of cannabis or a specific food-based product interacts with their body. After an hour, the patient can increase their dosage in increments remaining aware of the effects. If a patient feels any negative side effects they can try a different product or strain of cannabis that may result in less side effects. Employees will make this information clear and available to each patient. Topical& Transderinal Treatment of Cannabis Topicals and transdertnal methods are often chosen by patients who want the therapeutic benefits of marijuana without the cerebral euphoria associated witli otlier`delivery methods. Cayrinabis infused lotions, salves, oils, sprays;,and other transdermal:melhods of relief work by biridirig to a network of receptors called CB2. These topical and transderrnal treatments can be applied directly to the skin. 2) Dosage The employees will help the patient determine the correct dosage based on the prescription from the patient's medical practitioner and the patient's experience with cannabis. The employees will provide the following general recommendations to each patient: ® Start slowly. It is recommended to begin by consuming a small portion of the prescribed dosage and to monitor how cannabis interacts with the body. ® Inhaling Cannabis.Wait between short inhalations for a few minutes to observe the strength of the product. Begin with %4 of prescribed dose and note how the product affects the body. Edible products. When eating cannabis or consuming cannabis-infused products, allow the product an hour to interact with the body before it begins to take effect. Wait four hours before taking a second dose. Patients who are new to edible products should begin with a dose that is less than 0.5 ml to gauge how the product affects their body. Determine dosage amount based on prescription and the mg of THC in each product. Divide the product up accordingly to the prescribed dose. If it is your first time using the product divide the dosage into of the prescribed amount in order to gauge its effects. 39 a Self-titration. Self-titration is the best way to determine the best product and dosage. When using a new product begin with a low dosage, less than the prescribed amount, and see how it interacts with the body. Always take note of the environment, method of consumption, and amount consumed in order to determine side effects and how cannabis affects the body. The applicant will also offer educational materials on the following subjects: cannabinoids and their associated benefits, cannabis side effects &safety, biochemistry and physiology, and nutrition/diet Commitment to Rigorous Scientific Research The medicinal uses for cannabis plants remains largely undiscovered. While Natural Selections acknowledges the lack of double-blind placebo-controlled tests illustrating the efficacy of cannabis in treating certain medical conditions, the applicant has taken a scientific approach to strain development, aggregating data based on patient feedback and carefully studying plant and terpenoid profiles. Natural Selections believes that rigorous scientific testing should be the base formula for all future development. The applicant is commitment to producing strains with the presence of cannabinoids including THC,CBD, CBG, CBC, and THC-V. Natural Selections is committed to a rigorous testing policy and has established partnerships with certified laboratories to gain an understanding of the cannabinoid profiles and terpene levels in all produced strains and cannabis-infused products. Additionally, the„applicant utilizes an HPLC to isolate cannabinoids to produce ratio-specific products. Natural Selections understands that each individual's body physiology is unique and certain products and strains �affecfpatients' in different ways. There is little known research behind CBG, CBG and several, other compounds that could lead to treatment for other ailments. Similar to the unknown cannabinoids, terpenes, which are unsaturated hydrocarbons, are found within the essential oils of the plant and vary depending on strain, have been associated with medical benefits. The applicant will not restrict its research to cannabinoids and is committed to performing extensive research and testing on terpene profiles as well. Natural Selections is committed to sharing its scientific research with its patients, caregivers, and all members of the community. The research team will work closely with the Community Outreach Director to coordinate the publishing of its research through its website, blog, and printed materials. The research team and Community Outreach Director will also organize ongoing community events and dialogues to provide transparency and knowledge about cannabis with the community. Commitment to Quality Care The applicant understands that a strong brand begins in providing utmost quality care to its patients. The team hopes that Natural Selections can be instrumental in building a strong cannabis industry in Massachusetts, where patients are guaranteed safe access to medication and education. The core of the applicant's branding strategy lies in building strong relationships with patients and caregivers. The applicant believes in personally interacting with all of its patients and caregivers and helping design treatment plans that are uniquely catered to them. 40 Natural Selections has considered its commitment to its patients through the design process of the MMTC. The applicant will invest in a spacious and inviting design to ensure that patients will have sufficient time and space to make their decisions. The applicant will employ enough dispensary agents to ensure that each patient leaves the dispensary after a positive personal encounter and a strong plan to utilize the cannabis and cannabis infused products safely. Each dispensary agent will be trained to ask certain questions to understand the patient's objectives and experience in previously using cannabis. Dispensary agents will offer each patient a wealth of information regarding the available cannabis strains and cannabis-infused products, cannabinoids and their associated benefits,risks and adverse side effects associated with cannabis, and various methods of consumption. The dispensary agents will also inquire about patients' nutrition, diet, and lifestyle to ensure that the recommended consumption method and dosage is appropriate. All dispensary agents will be trained to explain the potency of different products and recommend that the smallest amount possible should be tested initially and increased conservatively until the desired effect is achieved. In an effort to execute its commitment to quality care, the applicant will hire a Director of Patient Affairs to interact with patients and caregivers The Director of Patient Affairs will oversee all employees working in the RMD and be responsible to maintain accurate records of patients identification and registration documents,manage scheduling patient traffic flow, answer phones and respond to patient and caregiver inquiries. Natural Selections"has<an open Oolicy with all clients and will welcome constructive criticism to .F 44 encourage positive'change throughout the ciiktivaLion facility. i Community Ipvolveinent Natural Selections plans to build collaborative relationships with state and local governments to ensure a seamless integration into the community it serves. Natural Selections has demonstrated a commitment to philanthropy and plans to partner with local organizations and non-profits that promote public health within Watertown,Massachusetts, Natural Selections takes a compassionate approach to providing medical cannabis, and is specifically committed to serving the veterans, elderly people, and low-income patients suffering from medical conditions, the applicant intends to establish a subsidized distribution network for low-income patients in Watertown, Massachusetts. Natural Selections will provide medical marijuana at reduced cost, or free, when an individual is a recipient of MassHealth, or Supplemental Security Income, or the individual's income does not exceed 300% of the federal poverty level, adjusted for family size. Patients who demonstrate verified financial hardship will fill out an application and be marked in our patient database as eligible for reduced cost marijuana for medical use. The business's team members will also organize community outreach efforts to create a safer, cleaner city as well as provide transparency about their operations and education about the responsible use of medical cannabis. Educational Serninars.The applicant has spent a substantial amount of time in Watertown and understands the public health challenges that the community faces. Natural Selections is committed to ethical and transparent business practices and will work closely with the community to provide education on the benefits and risks associated with cannabis use. Natural Selections will hold regular seminars about 41 scientific research related to cannabinoids and their associated benefits, as well as proper and responsible use of cannabis. Natural Selections is also committed to working with city of Watertown to provide public health educational programs geared towards education and prevention of HIV/AIDS and substance abuse: o HIVIAIDS Educational Prevention Workshops.In the past few decades, medical marijuana has become an increasingly common prescription for HIVIAIDS patients as they attempt to manage their symptoms. Nearly one in three HIVIAIDS patients turn to cannabis to ward off pain, nausea, appetite toss, cachexia, and emotional decline.Natural Selections, Colorado has worked with many HIVIAIDS patients at its current facility in Denver, Colorado and understands the devastating impact that this disease can have on families and communities. Natural Selections will hold regular community educational seminars for HIVIAIDS patients and community members to discuss prevention techniques. This educational seminar will be designed to significantly reduce risk behaviors among people who have been diagnosed with HIV to help ensure they do not transmit the virus to others. o Substance Abuse.Natural Selections is committed to implementing a public health program to prevent and treat substance abuse. This substance abuse educational program will be closely linked to the aforementioned program geared towards HIVIAIDS prevention. The applicant hopes that substance abuse education programs will be helpful to individuals and decrease the public health threat to the community. I 42 1 _ �uc� �11 f srcF In>r 1 1 1 Pr 2"z 6Ee •ILO Pr.Poree%. 1 r '1 UATEm NFS -- - 2)2• I` 11 I P o 0 INN �i $'Raab( PROJECT LOCUS MAP PROJECT NOTES: i \ \- 1. NOT WE INfOSI OF A NdICIFO MEW W IS AFPOWORIE ONLY AND {3 I\ ` �\/ (, : Mem W. NIC NOT ME RENLT OF NI IGIWL i1FL0 SVINEY PF0SSGISO B!INYES FNgNffglNO,INC.PFOPFRIY ONES TNtEN iBOM YASBCIS TN[PIACFL I N,W M WAT-WIA GTN M MR CITY OF WATFROMN. 1 _ � 2. 1CPoCRAPMW WFORMOEN DEPICTED HEREM IS.WROAINATE ONLY AND `���• ... 4 1 Carp N" WATIO WE RFEIIU OF W14 UM 14PPIHE OF WE AMQflIC CW.S(AS PM( � I 1 I \ � �1 2 I ®IaauN fr PumN OF WE HURRM.WE SWM IMPICI SUMEY 8!fl]N M'O NNIE �\ �, y-N 3 I ❑UeuM Ea RMer AVNIABIE BY IMSS CIS GNM TS NORM AMOOCW VE((UGL MNM V I� ' tV I G t6Be lw.vom). 9 5n :':. 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I p "",IV J��'/�I�� FIBYSB � T- I l� l I WS,UUNANCICOIWi1M AAG It,JOIt Lle�_-/ PARCEL ARM(1.0/54 K )46,8273 SF. 33.6E MORNING COED a o e7C es'Ldeedj . ome grole: 04 4^- _` _ Z 5ro.wsrn+2 Sm - Z P a 12J6 M 0 a. z Q ELL�J ' eP w422mr0Ni Ii02a,ac m � 0 z r o I wSwp aoCK LOCUS PARCEL: Q 4 23-29 ELM STREET d Z 3 1236 4 C LLJ MIDDLESEX $OWN REGISTRY OF DEEDS BX 16459 PG 445 N N PARKING, Sml: Na I,Nn.: F7; :1 C1 SPICES DFOGIED 1 Y _ DEL , I 12 SPITES MNM FW RIM ARM 2.5 P V. PARKING PR DVD.t SPICE PEA 1t8 Sf. SHEET 1 OF 1 62'6F' dip 11'4" 96'6 i ly- `--- � 11'0. •� safe/sewi room / inventory 11'4„ office W4rrl 's ,� •�` 11 0' office SO.F. i i 122 SQ.Fr. �me I I }l�r -1 i stroom I t RemoV£�xi5t1[1g J W forage 4'(? i t 1 Loading E i i 1 Existing wails 1 Ito be removed k employee breagck00 ; /kictitrnette f 42'q' e u I t ! I 1z 1, sales floor) a 1 1 1266$0,Fr. I t 30 6" ' 1 tt ------'_-------------__ _ _---- .--_ ----------- ---+ I -------------� Existing walls-_ ______- _ -__It 1 I to be removed F 11 v Fire `f' I rece tlon N Alarm des i I ` ❑ 76 E � n1 reception/,. 1 , ; I 1 Cu --- (L) 1Z 6" r i ; I ; ; e+ECtriC C y-• lJJ }• ii Fni 7 zN 7t 1 , ii Mestl � = f`E ole 510, �i Q O � c CL Co PROPOSED FIRST FLOOR PLAN Scale: 1/813 w V-Y' D 2545 Tool SQ.FT c 7 Total 0ocupancy 85 PersonsCD 8 Memorandum 603 Salem Street Nantucket, MA 02554 Wakefield, MA 01880 Tel: (508)228-7909 Tel: (781)246-2800 Hayes Engineering, Inc Fax: (781) 246-7596 Refer to File No. WAi'-u01/1 TO: City of Watertown Zoning Board of Appeals FROM: Tony Capachietti DATE: February 6, 2017 SUBJECT: Traffic Impact Statement INS AJO Holdings, Inc. 23 Elm St. Special Permit Application Hayes Engineering, Inc. has prepared this memorandum to summarize anticipated traffic impacts associated with the Medical Marijuana Treatment Center (MMTC) proposed at 23 Elm Street, Building 2. The existing property at 23 Elm Street consists of three (3) buildings and associated paved parking and driveways. The buildings are occupied by various industrial, retail, fast-food, office, service and other commercial uses. Access to the property is obtained by two (2) curb-cuts located at the northern and southern most portions of the frontage. The project, as proposed, includes the operation of a ±2,545 square-foot(sf.) MMTC in the space previously occupied by PixMix Production Services in Building 2. The facility is representative of the Institute of Transportation Engineers (ITE) Land Use Code (LUC) 826, Specialty Retail, defined in the ITE Trip Generation Manual, 911 Edition as being: ...generally small strip shopping centers that contain a variety or retail shop and specialize in quality apparel, hard goods and services, such as real estate offices, dance studios and small restaurants. The operation of a MMTC is in harmony with this description and does not change the facility's LUC from the existing condition. As such, no additional vehicle trip ends are created and no impacts to off-site traffic are anticipated as a result of the operation of a MMTC. Estimated Vehicle Trip data for the facility is summarized below. TRIP GENERATION The facility at 23 Elm Street represents ±20,600-sf. Specialty Retail space. Trip Generation Rates for the proposed ±2,545-sf. MMTC under various traffic scenarios are listed in Table 1 on the following page. Page 1 of 2 MEMORANDUM To: City of Watertown ZBA From: Tony Capachietti RE: 23 Elm Street Date: February 6, 2017 TABLE 1 Trip Generation, ITE LUC 826— Specialty Retail Time Period/Direction Trip Ends Per 1.000-SF. Vehicle Trip Endshl Weekday Daily 44.32 113 Weekday AM Peak Hour 6.84 17 48%Entering 8 52%Exiting 9 Weekday PM Peak Hour 5.02 13 56%Entering 7 44%Exiting 6 Saturday Daily 42.04 107 Sunday Daily 20.43 52 Ol Based on 2,545-sf. Gross Leasable Area As previously stated the ITE Land Use Code Classification does not change as a result of the operation of a MMTC at the site. Traffic impacts resulting from the operation of the MMTC will not be substantially more detrimental than the existing structure/use to the neighborhood. Page 2 of 2