The newly adopted regulations include some additional noteworthy changes from the proposed emergency version, published on September 8, , and first summarized by Vicente Sederberg on September 17, The Addendum to the Finding of Emergency provides an explanation of changes between the proposed and final versions, and the Vicente Sederberg summary below is updated to include these highlights.
Please contact our California team or call if you have questions on how these changes may impact your business. For example, a person who owns 10 percent of the stock in a commercial cannabis business as an individual shareholder and percent of the stock in an entity that owns 10 percent of the stock in the same commercial cannabis business has a 20 percent aggregate ownership interest in the commercial cannabis business.
The original version of the emergency regulations required brands to be disclosed as FIH regardless of financial relationship with a licensed partner:. This change puts brands licensing their IP to producers in the same position as previously—the brand is clearly an FIH of the licensee if the IP license has a profit or revenue sharing component, but less certainly an FIH if the financial arrangement is a flat fee or other model.
A provisional licensee must actively and diligently pursue requirements for an annual license to continue to hold a provisional license, including providing evidence that CEQA compliance is secured or underway.
Non-cultivation provisional licenses may be issued until June 30, , provided the application fee is paid on or before March 31, Cultivation provisional licenses may be issued until September 30, Local equity license applicant provisional licenses may be issued until June 30, , provided they submit an application on or before March 31, The state has issued attendant application deadlines; please speak to your VS licensing lead for more detail. Prospective provisional cultivation licensees cannot hold multiple cultivation licenses on contiguous, connecting premises to exceed one acre of total canopy for outdoor cultivation, or 22, square feet for mixed-light or indoor cultivation, if the application is received on or after January 1, For provisional license renewals from between July 1, , through June 30, , evidence of meeting CEQA requirements must be shown.
This includes requiring documentation demonstrating that the local jurisdiction or the provisional licensee is making progress towards completing the environmental review in satisfaction of CEQA. Provisional cultivation licensees will also provide documentation demonstrating progress with securing the streambed alteration agreement.
For provisional license renewals on or after July 1, , additional CEQA documentation, like showing of a negative declaration or mitigated negative declaration, will be required. Provisional cultivation licensees will also provide additional documentation for the streambed alteration agreement, like a final or draft streambed alteration agreement.
Business formation documents are required now upon request, and only if they are not available online through the California Secretary of State. The three previous regulatory agencies have consolidated and resolved issues on the new DCC forms. These forms are no longer required.
Electronic delivery of the CCR is allowed. Guidance on delivery methods and examples are provided below. Readers interested in finding out more about the quality of their drinking water should refer to their water systems' annual CCRs. You may also contact drinc waterboards. Wikipedia points to this government site for CDA and CCD samples embedded within the various downloadable documentation.
The zip file contains two XML files, each one following one of the two standards. Not only are they very complete representations, but since they are based on the same source information, it is very useful to compare the mapping from one to the other and to understand the evolution of the CCR and CDA standards to the collaborative CCD standard. For some real world data examples, we had luck browsing open forums. Get updates and be the first to know when we publish new blog posts, whitepapers, guides, webinars and more!
This guide shares our knowledge and insights from years of designing and developing software for the healthcare space.
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