Equitable Opportunities Now submitted the following letter to Massachusetts legislators expressing our deep appreciation for their support, highlighting widely-supported bills, opposing changes to license caps, and opposing putting the Cannabis Control Commission into receivership.
Dear Senate President Spilka, Speaker Mariano, Chair Rodrigues, Chair Michlewitz, Chair Gomez, Chair Donahue, and Honorable Senators and Representatives,Thank you for your unwavering commitment to promoting equitable economic opportunities within the cannabis industry. Your legislative actions, from prioritizing Economic Empowerment applicants and creating the Social Equity Program to reforming HCAs, local licensing, and establishing the Cannabis Social Equity Trust Fund, have laid a strong foundation for equity in this burgeoning sector.
On behalf of Equitable Opportunities Now and the Massachusetts Cannabis Equity Council, I extend our heartfelt gratitude to all members of this chamber—especially our dedicated champions, Sen. Liz Miranda and Rep. Chynah Tyler—for your investment in our programming for disparately harmed communities in the FY25 budget. This support is crucial for our work to empower entrepreneurs and workers from communities disproportionately impacted by the War on Drugs.
As a small nonprofit focused on the cannabis industry, EON operates with limited access to private funding, relying heavily on support from the most disadvantaged businesses in the industry and significant volunteer labor. Your initial investment in this work will greatly enhance our capacity to assist struggling employers and connect individuals from affected communities with job opportunities in the cannabis sector.
As you finalize the Economic Development bill, we strongly support the inclusion of the following favorably reported bills, which have garnered widespread backing from EON, MCEC, MassCultivated, the Massachusetts Patients Advocacy Alliance, and over 40 cannabis industry leaders:
- Sen. Lewis’s S. 53 & Joint Committee on Cannabis Policy’s S. 2597, An Act to Support Cannabis Equity Businesses
- Rep. Rogers’ H. 117 & Joint Committee on Cannabis Policy’s H.4409, An Act relative to vertical integration of medical marijuana businesses
- Sen. Tran’s S.1119 and Rep. Kushmerek’s H.114, An Act relative to employment protections for medical marijuana patients / Joint Committee on Cannabis Policy’s H.4426, An Act prohibiting employment discrimination based on legal use of cannabis
- Sen. Fattman’s S.50 and Rep. Soter’s H.119 & Joint Committee on Cannabis Policy’s H.4087, An Act further defining eligibility for medical use marijuana
- Rep. Sullivan-Almeida’s H.122, An Act relative to a medical marijuana pilot program
- Sen. Velis’s S.62 and Rep. Donahue’s H.105, An Act relative to data transparency in the cannabis industry
- Sen. Cyr’s S.48, An Act relative to cannabis use by first responders
- Sen. Jehlen’s S. 52 and Rep. Tyler’s H. 123, An Act to create Cannabis career pathways for justice-involved individuals
- Rep. Sabadosa’s H.118, An Act relative to supporting sustainability in the cannabis industry
As you work to finalize that bill, we urge you to continue your leadership by expanding access and equity in the medical marijuana industry, particularly by ending the medical vertical integration requirement that has effectively shut social equity businesses out from this subsector, hampering their ability to serve patients.
On behalf of EON, MCEC, and more than 40 other cannabis leaders, I wish to reiterate our strenuous objection to any change in the Commonwealth’s license cap and ownership requirements. The current limit of three adult use and three medical licenses is a bedrock of the Commonwealth’s equity efforts and undermining current limits would upend the industry, drive away investors, and significantly devalue cannabis social equity licenses.
Finally, while EON and MCEC recognize that serious concerns have been raised about the Cannabis Control Commission, we strongly urge you to reject any proposal to put the CCC into receivership before the end of session.
Despite the challenges that resulted from the Chair’s suspension, Acting Chair Ava C. Concepcion; Commissioners Nurys Camargo, Kimberly Roy, and Bruce Stebbins; Acting Executive Director Debbie Hilton-Creek; and all of the members of the staff have risen to the occasion through the thoughtful regulatory drafting and ongoing implementation of Ch. 180 of the Acts of 2022, robust ongoing policy discussions and regulatory review, stakeholder engagement and responsiveness, and focus on the work of regulating the industry.
The operational and provisionally licensed cannabis social equity businesses that we have spoken with confirm that despite any challenges created by the even number of Commissioners, staff turnover, and external distractions, the CCC has continued to operate without disruption. Agency staff have maintained the same level of responsiveness and ability to meet deadlines in reviewing application and licensing documents, and inspections and other operations continue to function as normal.
We appreciate that the current structure and Commissioners enabled our external stakeholder listening session focused on the concerns of equity businesses in implementing Ch. 180 with all five Commissioners at the time attending with many of their staff. Ours was just one of many sessions in which the Commission participated, in addition to their official public hearings, that simply would not happen, nor have a meaningful impact if they did, under a receiver — and the final policies would be less representative and worse off for it.
Commissioners and CCC staff have also been diligent in not only providing deliverables related to implementation of Ch. 180 on time, but also building in opportunities for additional stakeholder input, which has helped create better final products.
Most importantly, the current five-member CCC structure with multiple appointing authorities and staff structure provides multiple crucial points of access for patients, consumers, applicants, operators, advocates, and other stakeholders to have a voice in policymaking and regulatory implementation.
EON appreciates that Commissioners, executive staff, government affairs, communications, constituent services, the agency’s enforcement counsel and other attorneys all participate publicly and collaboratively and that they are all receptive to external input.
The Cannabis Control Commission needs a permanent executive director and five members to fully operate, and there may be areas of statute that could be further clarified or enhanced, but on behalf of cannabis social equity businesses and advocates, we strongly urge you to preserve the current structure and ensure the CCC has the resources and staff it needs to fully meet its legislative mandate.
Thank you again for all of your work this session and throughout the years to advance opportunity for those most harmed by cannabis prohibition. We look forward to your continued partnership in the years to come.
Please do not hesitate to reach out if we can ever be a resource.
Best regards,
Kevin Gilnack
Policy Co-Chair, Equitable Opportunities Now