Cleaning Up the CRTA
East view of the Illinois State Capitol Building in Springfield, IL
Yesterday, members of Chicago NORML’s legislative committee and others met with members of the Illinois General Assembly (ILGA) to propose cleanup language for the dispensing organization licensing section(s) of the Cannabis Regulatory and Tax Act (CRTA). Representatives and Senators will sponsor these suggestions in the form of a trailer bill, a secondary (or in this case, tertiary) piece of legislation to address mistakes, omissions, or unintended consequences of the original Act. This is commonplace, especially on large and complicated laws, and completely expected given the short timeframe that the CRTA was passed and enacted.
The suggestions offered by our colleagues and comrades were phenomenal. If passed, we will all continue to see the progress and intentions behind Illinois’ social equity program unfold and take shape. Below are a few of the highlights:
Limit the number of applications PER round - Currently, there is an unlimited number of applications that can be submitted in each round. Some well-funded groups paid for nearly 1000 applications, giving them an unfair advantage over most social equity applicants.
Include a range of scores, not just the top scorers - Currently, only the companies tied for the top score will advance to the lottery.
Include veterans, but do not make it mandatory for advancing - Currently, only companies that are 51% owned and controlled by a veteran can achieve the highest scores, allowing them to advance to the lottery.
Give applicants the scoring rubric - In the current round, applicants were not privy to the rubric used to score their applications. Allowing applicants to understand the standards to which they are being held promotes transparency and helps them to achieve higher scores.
Work with subject matter experts to develop the criteria for the rubrics used to score each exhibit. In many instances, there were vast discrepancies in how identical exhibits were scored by reviewers in different regions. Providing an industry-vetted rubric with standardized criteria promotes consistency and objectivity in the scoring process.
Provide more clarity in the notices of deficiency - Clear instructions on how to correct a problem were not provided on their notices of deficiency and many found it impossible to comply.
Changes to Social Equity Status Eligibility
Delete Employee Eligibility - Currently, an applicant may qualify for SE status by hiring 6 of 10 employees who live in a disproportionately impacted area (DIA) or have been impacted by a cannabis arrest or conviction.
Extend Residency Eligibility - Currently, an applicant may qualify for SE status if they have lived the last 5 of 10 years in a DIA. Extend it to the last 10 of 20 years.
BEYOND LICENSING
We would like to remind you that the social equity program goes beyond licenses. The program includes funding for loans, educational opportunities, community reinvestment, and giveback requirements from the MSO’s, and more. The Medical Cannabis Patient Program also includes provisions for social equity, inclusion, and parity. In addition to the suggestions above, we encourage the State to convene and appropriate cannabis tax dollars to fund a Cannabis Social Equity Commission. The CSEC will:
Develop and implement specific outreach strategies for patients, jobseekers, licensees, vendors, entrepreneurs, and communities
Ensure that program participants are aware of and are getting access to training and other support offered by the Act.
DIA’s are receiving their fair share of the cannabis tax dollars
Track SE license applications and advocate for those who seek administrate review
Monitor the MSO’s ongoing participation levels in the program to ensure compliance.
Report to and liaise with the State’s Cannabis Regulatory Office and the R3 board.