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To the Select Board Members and the Citizens of Buckland, Massachusetts:

As most of you know, my name is Eric Schwartz and I am the co-founder of Farm Bug Cooperative,
an organization made up entirely of Massachusetts residents. Our cooperative is working with local
small farmers and small-scale craft cannabis growers across central and western Massachusetts. To
date, we are completely self-funded and have legal counsel that is working pro bono for our
organization because of his belief that Massachusetts farmers and local cannabis cultivators have a
right to cultivate cannabis on their property and enter this cannabis industry without the
imposition of “unreasonably impractical” barriers as stated in Section 3 of Chapter 94G: Regulation
of the Use and Distribution of Marijuana Not Medically Prescribed. This notion was furthered by the
Massachusetts State Senate and House of Representatives in Chapter 55 of the Acts of 2017, which
was signed into law by Governor Baker. This law clearly states that the Cannabis Control
Commission, which is a state-sanctioned body that oversees both the state's medical and adult use
marijuana programs, must encourage “businesses of all sizes.” To date, the cannabis industry in the
state of Massachusetts has not encouraged business of all sizes and, instead, the local cannabis
industry remains dominated by corporations with millions of dollars in capital. I would argue that
most of these larger corporations have done very little to benefit the residents of Massachusetts
and have done very little for citizens in terms of job creation or community involvement. Farm Bug
Cooperative is not one of these organizations. We are a group of local cultivators and small business
entrepreneurs that believe that the cannabis industry should benefit our local economy and our
local cultivators.

Last week, the Cannabis Control Commission submitted their latest Guidance on Host Community
Agreements. Much of this document is dedicated to further defining the nature of the community
impact fee. As we know, the community impact fee is what is agreed upon between the town and
the operator and is to be a percentage of up to 3% of the operator’s revenue. This impact fee must
be “reasonably related to the costs imposed upon the municipality by the operation of the
Marijuana Establishment or medical marijuana treatment center.” I'd like to convey here a couple of
points. First, Farm Bug Co-op’s legal counsel, Jay Hadden, is working with the Cannabis Control
Commission to determine whether the impact fee should (can) be collected at the end of the fiscal
year based upon the cost imposed upon the municipality by the operation. Therefore, we are
seeking further clarification as to how this is collected and hope that such transparency will ensure
that the Town of Buckland follows state law and state regulations. Second, the Commission has
been very firm in this latest guidance document that such impact fees shall by no means exceed 3%
of the operator’s gross revenue. The reason why this language has been so firm from the Cannabis
Control Commission is because the medical marijuana industry in Massachusetts created a "pay-to-
play" environment where only large operators with large amounts of capital were able to compete
for host community agreements. The law and the regulations around adult use cannabis were
created to address this problem, which was hurting Massachusetts residents and local small
businesses.

Another interesting item in this latest guidance from the Cannabis Control Commission is one of the
examples that the Commission gave for what the community impact fee could be used for. This
example reads as follows:
Environmental impact or storm water or wastewater studies anticipated as the result
of cultivation.

One of the concerns that I've heard in Buckland Planning Board meetings, our community outreach
meeting, and at the last Select Board meeting was a concern over water usage. So far, to date, I have
not found any evidence that water usage is a problem in relation to cannabis cultivation. The only
evidence that I can find in all of my research is that, out in California, where there is much draught,
officials there have been cracking down on non-licensed illicit market growers that are tapping into
a limited water supply. Farm Bug Cooperative is applying for a license from the state of
Massachusetts and will be a legal entity operating under the state sanctioned regulatory body of the
Cannabis Control Commission. Any comparison between us and unlicensed illicit market players on
the other side of the country is wrong and uninformed. In light of the example above, if there is a
major concern about water usage, the Town of Buckland can use funds collected from the
community impact fee to commission a study concerning any potential effects on the local water
supply. I assume that this would suffice to calm any anxiety around water usage that residents may
have.

Property value is another concern that I have recently heard brought up in a Select Board meeting.
Again, I would like to convey that I have not read any evidence that the cannabis industry—be it the
existing medical marijuana industry here in Massachusetts or any other cannabis industry in the
legalized states across the country—has led to a reduction in property value. Therefore, I suggest
the next time this concern is raised by the community that those individuals please direct us to
either evidence of a reduction in property value in an equivalent legalized community or, at the
very least, a news story from a reliable outlet that gives an example of how property value has been
put at risk by the cannabis industry. To date, I have found zero evidence of this.

I'd also like to send my thoughts about a gentleman at the last Select Board meeting that
categorized Farm Bug Cooperative as an "outside group." To be honest, this categorization is rather
humorous to me. Let me be frank—the cannabis industry in the state of Massachusetts is
dominated by corporations (many of them out-of-state) with millions in the bank that are spending
millions on lobbying efforts across this state. In April of 2017, I testified in front of the Joint
Committee on Marijuana Policy in Boston at our State House for cooperative businesses. My belief
since the passage of Question 4 has been that cooperatives would provide small, local players with a
great opportunity to enter an industry, which has largely disenfranchised local cultivators and
entrepreneurs. Farm Bug Cooperative is not an "outside group." We are a group of Massachusetts
residents forming a business model that will help Massachusetts residents. We are also required by
state regulations that every member of our cooperative must prove that they have been a resident
of the Commonwealth for at least a year prior to application for licensure. Therefore, to categorize
us an "outside group" is false and, again, uninformed. I encourage the gentleman who stated this
during the last meeting to do his research on the cannabis industry both in Massachusetts and
across the country as well as in Canada. What he will find is that Farm Bug Cooperative is likely one
of the least "outside groups" in all of North America. We're creating a model that will benefit local
communities rather than a group of shareholders that sit somewhere outside of the state of
Massachusetts. Farm Bug Cooperative remains completely self-funded. We have not relied on one
dollar from anyone other than ourselves.
I'd also like to convey how proud I am to work with Dan Sullivan and Dan Wetterwald. When I
watched the Select Board meeting from the other night, it showed how much work they put in to
ensure that every angle was covered and we did everything by the book. We followed every law put
forward by the state and all of the guidance put forward by the Commission. Both of our Cultivating
Members in Buckland are to be commended for their hard work and diligence to ensure that we
were totally transparent about our process. This was most certainly not an "outside group" doing
this work, but, rather, two hardworking people that live in the Town of Buckland that want to take
advantage of a brand-new industry coming to the state of Massachusetts. As local residents, they
should be given that opportunity without unreasonable barriers put in place and misinformation
spread throughout their community.

The cultivators that we are working with are hardworking people that want the best for their
communities (in all the municipalities where we are working). We also believe that this new
industry should favor local residents and local farmers and not well-funded out-of-state big
businesses. The sad part in all of this is that a loud minority of local prohibitionists that have based
their concern on misinformation are preventing local folks from entering this industry and
benefiting from it. I went to college in Massachusetts and I've lived here fulltime since 2005 and I
am quite positive that this kind of behavior is not the norm in this Commonwealth. Rather, it's quite
the opposite. We all know that Massachusetts residents are loyal to their own. Therefore, it is not
surprising that I have read many Facebook posts in various local Buckland groups of community
members that support our organization and our proposed small-scale operations. These
community members will soon become the vocal majority as they gain a better understanding of
what a minority of residents are trying to do to a couple of local cultivators.

Question 4 to legalize marijuana in the state of Massachusetts was passed in November of 2016 by
the majority of Massachusetts voters and nearly 60% of voters in Buckland. The time to oppose the
legalization of adult use cannabis was in November of 2016, not in August of 2018. The debate was
over long ago. It is now time for our local governments to do what they were elected to do and put
in place programs that encourage local cannabis businesses to enter this industry and to benefit
from it.

I thank the Town Administrator and the Buckland Select Board Members for their service to the
Town of Buckland and for their commitment to serving the nearly 60% of Buckland voters that
voted Yes on Question 4 in November of 2016 to legalize adult use cannabis. Their vote was the
right decision then and it remains the right decision now.

Most Sincerely,

Eric Schwartz
Co-Founder
Farm Bug Cooperative
eric@farmbug.coop

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