Seeds must be produced by either a OPC or MIPs licensed facility in order for them to be completely legal for distribution. Patients and caregivers are not allowed to sell to dispensaries, and caregivers are not allowed to distribute to anyone other than their listed patients. Basically you need a dispensary or infused products manufacturer manifest in order to legally distribute your seeds.
Seed production plants at this time do not count against the 70/30 ratio if grown in an OPC, and there isn't any plant counts for MIPs.
A collective of patient and caregiver testers is possible and legal, but breeding and sales are going to be limited by the need for OPC/MIPs production and distribution.
303 Seeds has OPC production and distribution at this point, and I know Adam at TH Seeds is producing seeds here in a OPC as well.
Thats what I know...love this conversation and I am more than willing to be a part of the Mile High breeder team!
BP