California: Submit Feedback on Rules and Regs

California: Submit Feedback on Rules and Regs

California: Submit Meaningful Feedback


Guest Contributor:

Amanda Ostrowitz, Co-Founder and Chief Strategy Officer, CannaRegs

May 11, 2017

Over the last month, California has released rules and regulations for business licensing as it relates to the state’s impending adult-use cannabis industry.  Because California’s cannabis program is unlike any before it, the state wants to ensure that prospective licensees, stakeholders, and interested parties, have time to thoroughly review the rules and regulations and provide feedback on any changes they’d like to see.  This not only allows the state to thoroughly vet its written program, but it also affords stakeholders of all kinds the opportunity to be heard, should any of the rules and regulations not be in their best interest, because if you’re not speaking out to represent your interests, then who will?

However, it’s not as simple as stating, “this should be changed because it doesn’t represent my interests.”  If you’re going to take the time to submit feedback, here are some steps you can follow to make sure your feedback is meaningful and will be taken into full consideration by the state.

  • Read the Text. Nobody reads, right?  But the devil is in the detail.  Read the rules, then read them again.  In order to provide valuable feedback to the state, you need to understand what they’re trying to accomplish and how each rule ties back to the larger goal at hand.
  • Written or Oral? The state will take comment via written feedback or in-person at one of the several hearings throughout the state. Which is better suited for your interests?  Oral can spark a conversation in the room, but written allows you to research, articulate, and take your time to craft a meaningful response; plus, not all commenters want a debate on their proposed feedback.
  • Understand the Basis. Every rule and regulation outlined were created with key factors in mind that influenced their decision.  By understanding the key factors that drive their policy decision, you can more effectively propose alternatives that still solve the problem at hand.  Many of the key factors underlying their policy decision included things like; statutory mandates under MCRSA, Cole Memo priorities, product safety and consumer protection, protecting the public health and well-being, and maintaining effective prevention of diversion with a regulated market.  Figure out the driving factor to the rule you’d like to change and when proposing the change, make sure to still solve the problem.
  • Don’t Be Afraid of the Rabbit Hole. If you want your feedback to be meaningful, the previous step is the single most important one.  But figuring it out won’t likely be a 5 minute task.  You have to go down the rabbit hole; one thing will lead to another and you’ll have to dig and dig, but by knowing what they were trying to accomplish in full you can explain why it won’t work or you can offer an alternative that achieves the same objective in a more conducive manner to your interests; better yet, if you can help them achieve their objective in a more efficient or more effective manner than what they proposed, you can be quite persuasive.

**Feedback submissions can be done by written letter or in person at one of the several hearings throughout the state.  Information on how to submit feedback, comment cards provided by each respective department, deadlines, and dates/times for in-person hearings, can be found here.

Info on how to Submit Comments to California including hearing dates/times.

Watch Amanda’s full webinar discussing the proposed rules and regulations in California here; the portion for submitting comments begins at 13:04, however, we recommend watching the whole video as there is a lot of valuable info!

About Amanda Ostrowitz and CannaRegs:

Amanda Ostrowitz is the Co-Founder and Chief Strategy Officer at CannaRegs, a web-based subscription service for those in the cannabis industry and their advisors. CannaRegs provides enhanced access to all cannabis-related rules and regulations from state, county, municipal and federal sources, and aggregates these rules and regulations in an intuitive, easy-to-use database.  Make sure you’re following CannaRegs on Facebook, Twitter, and Instagram!


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