We need your help! The Arizona Department of Health Services (AZDHS) has released its draft rules on Social Equity and have offered the opportunity for the public to comment. Public comments are due by midnight tomorrow (Sunday, the 16th). The draft rules certainly don’t represent voter intent as defined by Prop 207. Unfortunately, this current draft does not adequately protect nor provide opportunity for those people who have been disproportionately impacted by the prohibition of marijuana.
If these rules go into effect as written, the social equity program as dictated by Prop 207 will be gamed, delegitimized and ultimately fail. We need you to help us prevent this from happening!
Below is a link to access the public comments as provided by AZDHS:
We have included suggested comments for each question in the survey. Those comments with the associated question can be found below:
1. What part(s) of the draft rules, do you believe are effective?
- The reduction in the application fee from $25,000 to $5,000 for the social equity licenses.
- Lowering the barrier of entry for the social equity licenses by not requiring applicants to secure a physical location prior to the awarding of a license.
- Are there topics that should be added to or removed from the elements of the training program in R9-18-303?
- While the training program is a sound idea, is it necessary to mandate every training module for each applicant?
- The lack of specific training relative to accessing capital is a glaring omission. Adding training centered around this topic would certainly benefit every social equity applicant.
- How else can the draft rules be improved?
- The draft rules need to appropriately define “communities disproportionately impacted” by the enforcement of marijuana laws.
- The draft rules would be enhanced if they sought to create a sustainable program to reinvest in communities.
- The draft rules place inappropriate hurdles relative to the social equity application process such as a $5,000 non-refundable fee. It is incongruent to expect someone who meets the poverty guidelines defined by the draft rules to risk losing a non-refundable application fee. This is particularly true in what is anticipated to be a crowded field of applicants. Allowing this fee to be refundable is a simple solution to this problem.
- To ensure the success of the social equity program, the draft rules need to create quality metrics or mechanisms to be used in evaluating the progress of the program.
- What questions/comments do you have that were not addressed above?
- In order to improve the draft rules, it is necessary to solicit the opinions of the diverse groups and communities that have been disproportionately affected by the prohibition of marijuana. This was not done effectively based on the draft rules as written.
- Based on best practices, consideration should be given to the creation of an advisory board composed of individuals with expertise and involvement in the community to provide feedback on the progress of the social equity program.
Feel free to copy and paste these responses or respond in your own words. There is a link to the draft rules at the top of the survey.
We need to act quickly, comments are due by midnight tomorrow!