On December 17, 2020, the Arizona Department of Health Services (“Department”) held an open meeting to take comments on the proposed state cannabis regulations. In this post, we share some of the comments made by the participants and some of the answers provided by the Department. The Department stated that the purpose of the meeting was not to take questions (although, in some cases, they did answer questions), but rather to just allow interested parties to provide comments on the proposed regulations.

Early Applicants in Counties with Fewer than 2 Medical Dispensaries

There was a robust discussion regarding early applicants for counties that have less than two medical marijuana (“MMJ”) dispensaries. According to the Department, there are currently eight counties in Arizona that have fewer than 2 MMJ dispensaries – the Department will provide a list of those counties before the early applicant period begins (which is set for January 19, 2021). Thus, there should be opportunities to procure an adult-use license in those counties.

Several commentators suggested that given the high application fee, that applicants should be scored and rated. Under the law, the Department will accept applications until March 9, 2021 for early applicants. Any entity that submits

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