The locations of the first three bricks-and-mortar pot shops in Ontario have been posted for public comment.

The stores are the Ganjika House in Brampton, The Niagara Herbalist in St. Catharines and Ameri in Toronto.

The shops will be operated by winners of a lottery held nearly a month ago to select 25 lucky people who were given the right to apply for a licence.

The province is temporarily limiting the number of stores because of a shortage of marijuana for the recreational market.

The shop names and locations were posted Wednesday morning on the website of the Alcohol and Gaming Commission of Ontario, which is responsible for licensing.

Residents in those cities and the municipal governments have 15 days to comment on the locations. The grounds for objecting, though, are limited to arguments that the stores might pose a risk to public health and safety.

The posting did not specify which lottery winners were operating the stores.

No store locations for Ottawa have been posted, and it’s not known yet how many shops the city will get, if any. There were five lottery winners in Eastern Ontario. They can chose locations in any city with a population of more than 50,000 that has opted in to allowing cannabis stores. That includes Ottawa, Kingston, Belleville, Barrie, Peterborough and Kawartha Lakes.

It’s been nearly a month since the Jan. 11 lottery.

Ontario still plans to have 25 privately run shops open by April 1, says a spokesperson for the AGCO.

That will be a challenge, say several consultants and lawyers in the cannabis industry.

“We only have two months now,” says Mark Asfar of Ottawa’s Momentum Law. His firm has advised more than a dozen clients who plan to open cannabis stores when licences open up. “It’s going to be incredibly hard.”

He predicts the majority of stores won’t open on time, “but I’m happy to be proven wrong.”

Matt Maurer, a Toronto lawyer who represents “multiple” lottery winners, says all of them expect to open on time, barring uncontrollable circumstances such as a delay in getting a building permit.

But some winners might find they can’t develop the brand and marketing they want by April 1, said Brenna Boonstra, the director of quality and regulatory consulting for Cannabis Compliance Inc.

Boonstra ticks off some of the things lottery winners must do: obtain a location, design a store and complete renovations, install a security system, hire and train staff, order products and ensure all regulations are met.

“Opening a cannabis retail store is not the same as opening a retail clothing store,” she said. “The security elements alone are significant. The record keeping commitments are significant. It’s a highly-regulated industry.”

The first 25 stores in the province will also be under a public microscope “because they are the lottery winners, and everyone wants to see what they have done with this golden ticket,” she says.

There were nearly 17,000 entrants in the Jan. 11 lottery that gave winners the right to apply for a cannabis store licence.

The AGCO is working closely with the winners, said spokesman Raymond Kahnert.

Winners must apply for two licences, at a cost of $10,000, and put up a $50,000 line of credit that can be drawn down if they don’t have their stores open by April 1.

As part of the second licence, applicants must post a notice on the storefront to allow residents and municipalities 15 days to comment. The AGCO will also postthe list of locations on its website.

The AGCO timeline for store openings, published on its website, is “very ambitious and not entirely logically consistent,” noted Asfar.

For instance, the AGCO says stores should begin hiring staff around Feb. 11. However, as of Feb. 5, the 15-day public notice period had not yet begun for any of the stores.

So applicants will have plans well underway by the time the public starts commenting on their location.

If the AGCO rejects a licence application after considering public comments, the applicant would have to find a new location.

That may seem unfair to the business owner, but it’s a typical risk in the brand-new industry, said Boonstra.

“Cannabis retail is not for the faint of heart.”

The first 25 stores in Ontario are also expected to be lucrative. They will have the country’s largest cannabis market to themselves — at least, for a few months.

Ontario has said the licence restriction is temporary and will be lifted when the cannabis supply increases.

The majority of the lottery winners were individuals, not corporations.

Most have no experience in the cannabis industry, and some have never run a business. The winners have been deluged with offers of help from consultants, investors and corporations eager to get a head start in retail cannabis in Canada’s largest province, but it remains unclear what partnerships will be allowed.

Lottery winners who receive a licence can’t change their ownership structure, hand over majority ownership or control of their business, or sell or transfer their licences.

In the one deal announced this week but not yet approved, High Tide Inc., which runs cannabis stores in Western Canada called Canna Cabana, says it signed a letter of intent with one lottery winner to obtain a minority interest and the option to acquire a greater interest in the future. No details were released about which winner or where the store would be located.

Cannabis stores in Ontario: A timeline

Jan. 11: A lottery selected 25 winners given the right to apply for a licence to operate one cannabis store. Winners were selected in each of five regions. They are allowed to set up shop in any municipality with a population of more than 50,000 that hasn’t opted out of allowing cannabis stores.

In Eastern Ontario, the five winners can select locations in Ottawa, Kingston, Peterborough, Belleville, Barrie or Kawartha Lakes.

Jan. 22: Municipalities had to decide by this date whether to opt out of allowing cannabis shops. Of 414 Ontario municipalities, 77 opted out, including the cities of Mississauga, Markham, Pickering, Vaughan and Oakville.

Feb. 5: The Alcohol and Gaming Commission of Ontario said all 25 winners have applied for the first of the two licences required. The second licence includes a requirement that applicants post the location for 15 days of public comment.

Feb. 6:The AGCO posts the locations of the first three stores for public comment.

April 1: Ontario’s target for the 25 stores to open