Stringent medical marijuana rules proposed in AZ

[Dignan]

I don't have much time in my life to spend on internet forums, which is too bad, because I would like to respond at length to your posts. I have to be quick, so I will just point out a few facts to you.

The folks disagreeing with me are doing so from a free market, free enterprise viewpoint. You will find no greater supporter of free markets and competition than me. The problem is that the new law here in Arizona was designed to stifle the free market and competition in order to benefit out of state interests. Let me illustrate:

The law limits the number of dispensaries to 124 for the WHOLE STATE.

The law prohibits patients from growing their own if they live within 25 miles of a dispensary. This means that over 95% of patients will be FORCED to buy from the 124 dispensaries.

The ballot proposition that was approved by the voters in Nov that contains the above provisions was written by out of state interests.

Limiting the number of dispensaries heavily favors those folks with lots of money and other resources over "mom and pop" type operations and co-ops. Wealthy corporate-style operators from other states can come in and snatch up all the licenses before locals can even start to get ready.

Banning most patients from growing their own insures that those who do get a license will get to dictate price, strain availability and everything else.

There are a lot of people here in Arizona who have been laboring for years to provide high-quality medicine to sick people, often at their own expense, and at the risk of their freedom. Plans were in the works to make a home-grown ballot proposition designed for maximum benefit for the patients here in Arizona. Instead, now we have a law written by out of state interests, that was designed to insure that they will control the market in order to milk cash from sick people.

Lastly, to BiG H3rB Tr3E: You ask "are you so concerned with disallowing out of staters that your willing to pass over all the experience, knowledge and strain selection that they have acquired in over a decade in the medical marijuana field? "

We have plenty of experience, knowledge and strain selection here already, thanks. If we need egotistical arrogance, grossly inflated prices, ties to organized crime or advice on how to alienate the non-smoking community leading to backlashes, we will ask for it.

This is right. ^

The fact that people from Cali or CO or MI might come to Arizona and do a good job of running a dispensary isn't the fear. We of course welcome anyone who wants to do good work for others, whether it's in Arizona, New York and Zambia.

But what happens is this: In Arizona, it's going to cost an outfit $5K just for the application fee. Factor in attorneys fees and the other expenses required to actually be in the running for one of the few licenses being offered and you're looking at $20-30K minimum just to have a chance at a license. Then you need the $200K+ to get the thing off the ground. And this isn't an industry where you can just go get a loan from a bank, which means that people who have $750K cash to play with have an incredible advantage over the locals who live here, raise families here, and call it home.

Most of the people from other med states who have big money to play around with in the new AZ market have that money because they're charging unfair prices for weed in their "medical" dispensaries in those states. If you're charging $300+ per ounce, you aren't serving patients. You aren't even serving your community IMO. You're taking advantage of them.

And I have friends running dispensaries in CA and CO and they see Arizona as "a market" and that's it. They want to make a buck by expanding their already-thriving businesses into another state. To some of us, Arizona isn't just a "market"... it's our fuckin home. You'll have to forgive us if we feel a little hesitant to hand over our emerging cannabis industry to the highest bidders.

 

[Dignan]

And in other news...

And in other news...

This is from The Green Leaf, Arizona's new MMJ magazine.

ADHS Director Will Humble Hints at Changes in 2nd Draft of MMJ Rules
January 25th, 2011 Mike Meyer

The following notes were sent to us anonymously, so take them with a grain of salt. Very interesting info if true…

PLANNING FOR MEDICAL MARIJUANA DISPENSARIES

Thursday, January 20, 2011

This was an Arizona Planning Association professional development seminar. It was attended by 60 to 80 people likely to be planners, lawyers and some identified as industry people. There were few questions. The session was videotaped, and a DVD should be out in a couple of weeks. The following are my notes on the seminar.

Will Humble, Director, Arizona Department of Health Services

The next draft of the Prop. 203 Rules will be out Jan. 31. There will be substantial changes as a result of staff work and 1,500 comments. Most of the comments were standard copies provided by groups. Changes will include chain of custody issues. The 70 percent self grow will be deleted. Dispensaries will be able to grow their own on site or offsite or purchase from other dispensaries. The C of O [certificate of occupancy] requirement will be dropped and replaced by a certificate of acceptance by a city or county. There will be new requirements for distribution of dispensaries around the state, so there will be some left for rural areas. There will be new language on inventory control.

Debra Stark said the City of Phoenix has 15 applications for dispensaries„ most coming on the morning after the City Council approved the zoning ordinance text amendment.

Caregivers are a big problem for regulators due to no opportunity for regulation other than they are limited to 12 plants per patient and themselves if they are a patient.

Comments on the rules are available on azdhs.gov

Growing is allowed as long as the area is surrounded by 12 foot walls and covered with a durable cover. It does not have to be fully enclosed. This is for dispensaries and remote grow facilities including self grow and caregivers.

Dispensaries will need a food establishment license, or agents with food handlers’ licenses must accompany the marijuana to and throughout the food production process at remote locations (e.g. bakeries) and return the finished product to the dispensaries.

A dispensary may own a cultivation facility and sell to other dispensaries.

Cameron Artigue: attorney with Gammage and Burnham

How will ADHS select applicants and grant licenses? Financial capacity, criminal record, expertise, and business plan will be considered. What should have been done is to qualify the applicant first and then allow selection of area.

The Use Permit requirement may not be sustained if challenged in court. Others commented that is useless as any applicant meeting the standards must be granted a use permit.

There will be some way found to apply a tax to marijuana sales. 10 percent seems likely.

Sales per square foot of dispensaries are estimated to be $2,500. That is four times Scottsdale Fashion Square, the highest revenue per square foot in Arizona.

Necessary inventory is likely to be in the $1,000,000 range. It is unlikely to be able to be insured. The potential for theft and assault is significant. Police want dispensaries to limit activity to daytime hours.

The single secure entry requirement is unclear and difficult with fire code requirements. One solution might be to set up the dispensary as a pharmacy is set up in a drug or grocery store, a single secure entry to the portion of the building used for the dispensary.

The current regulatory structure does not provide a rational way to establish primacy in location of dispensaries.

Cities are bound to comply with Arizona law regardless of Federal law. They must, therefore, comply with state zoning requirements.

Susan Goodwin: attorney with Curtis, Goodwin, Sullivan, Udall and Schwab

(She provided extensive handouts on the provisions of 203 related to land use, legal issues and concerns, relevant definitions from Proposition 203 and sample ordinances from several cities.)

Prop. 203 only applies to dispensaries and their related cultivation sites.

Prohibitions on deliveries from dispensaries in ADHS rules may be illegal as not authorized by 203.

203 does not allow purchases from other dispensaries or sales to others.

She thinks a conditional use permit process is likely where a city or county issues the conditional permit pending ADHS approval of the applicant.

She also agrees that if all zoning requirements are met, a use permit must be issued.

Many other requirements in ADHS rules and city ordinances may not be permitted by Prop. 203. Look at the authorizing statute first before challenging the rules and ordinances. Prop. 203 reference to Arizona Revised Statutes Title 9 (Municipal Zoning) may allow cities to do more with location requirements than envisioned by 203.

Debra Stark, Phoenix Planning and Development Services Department

Phoenix City Council wanted use permits in spite of information that they must be issued if provisions are met. Some cities are granting approvals by right after meeting all restrictions without a use permit.

Three types of medical marijuana dispensary:

* Retail dispensary, max. size 2,000 sq. ft., distance limits measured from facility wall to zoning district boundaries. A lot of non-profits looking to have dispensaries, hospice, nursing home. Many felt retail dispensaries should be allowed in commercial districts and as a result, distance to residential districts was reduced to 250 feet.
* Cultivation (grow facilities), distance to residential increased to 1,000 feet.
* Nonprofit infusion. Some felt that definition should be expanded from food to lotions and cosmetics.

On Tuesday, January 18, the City Council deleted the provision that Use Permits require compliance with Federal law.

The City had 20 people in line after the council approved the ordinance authorizing the use permit. Fifteen have now applied for use permits.

Debra discussed the chicken or egg problem with the currently preprocess of approving applicants and said the zoning-by-right option avoided this.

She suggested that Phoenix might find a process where a variance might be allowed to address spacing requirements but acknowledged that it would be difficult to find a hardship not caused by the applicant.

ADHS rule changes may require the City of Phoenix to amend its ordinance.

Mayor Gordon asks that medical marijuana nonprofits make contributions to Phoenix charities.

She thinks efforts to tax marijuana sales are likely.

 

[rick shaw]

Attorneys and mmj consultants are going to be the big winners for the first five years.

 

[emerald city]

I disagree. I thought this was the UNITED states of america. why do i feel like a foreigner in my OWN country? are you so concerned with disallowing out of staters that your willing to pass over all the experience, knowledge and strain selection that they have acquired in over a decade in the medical marijuana field? should we not allow doctors to practice in our state because they are from out of state? what about paramedics, nurses, or fire fighters? what if we did not allow albert einstein to come to our country and he developed the atomic bomb for hitler? what happened to having the FREEDOM to find a more prosperous life for you and your family? what happend to the constitution? our fore fathers must be rolling over in their graves at all the injustices that our country continues to support.

On the whole id have to agree with you,but on this subject i see the issue a bit differant....Our state [Maine] is going threw the same growing pains as AZ.....We the people vote to reform our already 10 year old mmj laws....Who does the state look for to help change the law,a guy from outa state.....When the state sets up a task force to create and impliment the new guidelines,who is siting on the hand picked task force,another handfull of transplants from the west coast.....Finally...when the time come to file aplications for 1 of the 6 dispensaries allowed in Maine,folks from away got there hands on 2/3 of the permits....
I understand freedom of speach,movement ,equal playing field for all...But why not give the first chance at a new econonmy to the people who it effects most,the locals...
Good luck with the whole deal,As maine goes ,so goes the nation.

 

[bluepeace]

This is right. ^

If you're charging $300+ per ounce, you aren't serving patients. You aren't even serving your community IMO. You're taking advantage of them.

To some of us, Arizona isn't just a "market"... it's our fuckin home. You'll have to forgive us if we feel a little hesitant to hand over our emerging cannabis industry to the highest bidders.

Well put!

 

[Drybulb230]

Lets get this straight...THE CARTELS RUN AZ! Now..is the fucking elephant apparent now? Like a Multi-Billion dollar organization is going to abandon its #1 Cash crop in 1 of its 3 major transport border states. which happens to be to a very lucrative market. There's more influence in the desert then people think. Plus this here is a "good ol boy" "one horse" show kinda town, everyone's packing heat and its #1 most profitable market is the the Large scale drug trade.

 

[Dignan]

Lets get this straight...THE CARTELS RUN AZ! Now..is the fucking elephant apparent now? Like a Multi-Billion dollar organization is going to abandon its #1 Cash crop in 1 of its 3 major transport border states. which happens to be to a very lucrative market. There's more influence in the desert then people think. Plus this here is a "good ol boy" "one horse" show kinda town, everyone's packing heat and its #1 most profitable market is the the Large scale drug trade.

Certainly true of the southern portion of the state... but what is your point as it relates to medical marijuana? Are you saying nobody but mexican drug cartels are going to own them?

 

[Drybulb230]

Certainly true of the southern portion of the state... but what is your point as it relates to medical marijuana? Are you saying nobody but mexican drug cartels are going to own them?

NO im saying they'r not gonna just laydown when they start to lose millions of dollars due to increased production and lower prices. They also have quite a bit of influence internally.

 

[Dignan]

NO im saying they'r not gonna just laydown when they start to lose millions of dollars due to increased production and lower prices. They also have quite a bit of influence internally.

It will be interesting to see how much they shape the look of things.

 

[bluepeace]

It will be interesting to see how much they shape the look of things.

You mean like the 15 dispensary's that have already been approved ever though the laws aren't official!

 

[Dignan]

What's your source of that info, bluepeace?

 

[Eli Bloom]

this is a good response to the ridiculous proposed CHAA based distribution of dispensaries. It seems that the focus of the distribution is not to support patient access but only to limit home grows. i found it here http://www.keytlaw.com/arizonamedicalmarijuanalaw/2011/02/chaa/

also here is a map of the CHAA zones

http://www.azdhs.gov/prop203/chaa_layers.htm

CHAA on This!
By Anonymous, on February 3rd, 2011
I am part of a group that plans to apply for one of the medical marijuana dispensary licenses to be awarded by the Arizona Department of Health Services. I believe the method the AZDHS has chosen to distribute the licenses throughout the State is flawed. Here are some of the reasons.

Prop. 203, as it was passed by the voters, expressly based the number of dispensary licenses to be awarded on the number of retail pharmacies in the State. Recently, the total for the State was 1,249, which, if rounded up would result in 125 dispensaries.

Prop. 203 does not expressly state how the dispensaries are to be distributed throughout the State of Arizona. There are two obvious methods that could be used. One would be to distribute them among Arizona’s 15 Counties according to the number of pharmacies in each county. After all, Prop. 203 based the total for the state on the number of pharmacies statewide. The other method would be to distribute the dispensaries throughout the 15 counties according to the per-capita population of each county compared to the total for the state.

Using either the pharmacy method or the population per county method would have similar results. Although urban areas have more pharmacies per capita than rural areas, the differences are not so great as to make the distribution result significantly different based on the method chosen.

In general, using numbers of pharmacies per county slightly increases the number of dispensaries in large urban areas and using population per county slightly decreases the share of the large urban areas and transfers a few of the dispensaries to smaller population counties.

In the 2d set of Agency rules distributed by AZDHS on January 31, 2011, they have come up with a different method of distributing the dispensaries. They have used AZDHS’s Community Health Analysis Areas (CHAA) and have decided to locate one dispensary in each one of them. There are 126 of these CHAA zones. 19 of them are located throughout the State on Indian Reservations Although I have not seen it in print, I have heard that possibly all of the 19 tribes may allow the State to refrain from locating a dispensary in their lands. I believe that AZDHS is counting on this. The reason I believe this is that in his January 28 posting to his blog, Director Humble stated that individual CHAA districts in Arizona include as few as 5,000 residents and as many as 190,000 residents. If you take into account Indian Reservation CHAA districts, there are 6 districts with fewer than 1,000 residents and 11 with fewer than 5,000 residents. On this basis, I am assuming that AZDHS does not plan to distribute dispensaries to the 19 Indian Reservation CHAA districts. AZDHS has not said whether it intends to distribute 19 additional dispensaries among the non-Indian Reservation CHAA zones in order to bring the total back up to 126. They will likely be required to do something to make up the difference between 107 and at least 125, since Prop 203. specifies that at least 1 dispensary license will be distributed for each 10 pharmacies. Since there are 1,249 pharmacies, AZDHS should be required to distribute at least 125 licenses.

To view the CHAAs go to the Medical Marijuana Dispensary CHAA Map. You can zoom in and out or enter an address to determine the CHAA in which the address is located. If you click on a CHAA, the map will display the name of the CHAA, its ID number, 2000 population and 2010 population.

Using the CHAA districts as the basis for distribution of the dispensaries throughout the State will result in a radical redistribution of dispensaries from urban areas to rural areas. I have learned, from the AZDHS website, the 2010 population totals for each of the 107 non Indian Reservation CHAA zones. The smallest is Ajo, in far West Pima County which had 4,290 residents. The largest is Maryvale in Phoenix which had 224,678 residents.

I divided the CHAAs into two groups. The first is the 54 CHAAs with the smallest 2010 population totals. The second group is the 53 CHAAs with the largest 2010 population totals. Here is some information comparing those two groups.

The 54 smallest CHAAs have a total of 1,165,676 residents. They average 21,587 residents per CHAA. Their total population represents 18% of Arizona’s total non-Indian Reservation population of 6,535,445.
The 53 largest CHAAs have a total of 5,335,808 residents. They average 100,808 residents per CHAA. Their total population represents 82% of Arizona’s total non-Indian Reservation population.
Under the AZDHS proposal group 1, representing 18% of Arizona’s population will receive 54 dispensaries. Group 2, representing 82% of Arizona’s population will receive 53 dispensaries.
I have also looked at how dispensaries would be distributed among Arizona’s 15 counties based on number of pharmacies per county, per capita population per county and distribution by CHAA. As mentioned above, by pharmacy total Maricopa County would receive 80 dispensaries. By per capita population it would receive 75. Since there are 41 CHAAs in Maricopa County, per the AZDHS proposal, Maricopa County would receive 41 dispensaries. Although Maricopa County has 64 % of the State’s pharmacies and 60 percent of the population, it would only receive 38% of the 107 non-Indian Reservation dispensaries.

Pima County receives a similar percentage of the number of dispensaries whether they are distributed by number of pharmacies, per capita population or by CHAA.

The difference between the 80 dispensaries out of 125 that Maricopa County would receive by pharmacy total and the 41 of 107 it would receive according to CHAAs would be distributed to the smaller and more rural Counties. Here are some facts concerning the population totals that would be served by Maricopa County’s 41 dispensaries and those of smaller rural Counties.

Maricopa County’s 41 dispensaries would each serve, on average, 98,130 residents.
La Paz County is the 2d smallest population County in Arizona. Its population is 21,616. It was one of the Counties that, per Prop… 203 was guaranteed at least one dispensary even though it would not receive one if it were determined by number of pharmacies or by population. Since La Paz County has 2 CHAAs, it would now receive 2 dispensaries which would each serve 10,808 residents.
Cochise County has a population of 140,623. If dispensaries were distributed by number of pharmacies (23), it would receive 2. If they were distributed by population, they would receive 3. Cochise County has 6 CHAAs and will receive 6 dispensaries per the AZDHS proposal. These dispensaries, would, on the average, serve 23,377 residents, compared to the Maricopa County average of 98,130 residents.
By virtue of distribution by CHAA, Santa Cruz County, Gila County, Navajo County and Coconino Counties would each gain dispensaries compared to the distribution by number of pharmacies or population. In each of these Counties, less than 30,000 residents, on average, would be served by the dispensaries the County would receive according to CHAAs.
AZDHS could make up the difference between the 107 non-Indian Reservation CHAAs and the 125 dispensaries required by Prop. 203 by distributing 18 or so additional dispensary licenses. The most logical way to do this would be to assign an additional license to each of the 18 highest population CHAAs, so that each of the 18 largest CHAAs would have 2 dispensaries instead of 1. 16 of these additional dispensaries would go to Maricopa County and 2 would go to Pima County. This would reduce to some extent the radical disparity between the treatment of urban and rural areas. The disparity would still be large. If Maricopa County received 57 dispensaries out of 125 as opposed to 41 out of 107, its share of dispensaries would increase to 46% from 38%. This compares to Maricopa County’s 60% share of Arizona’s population.

This would not alleviate the problems AZDHS will be creating by insisting that every tiny population CHAA receive a dispensary license. These problems are discussed in detail below.

According to AZDHS figures, Arizona has 6,535,445 non-Indian Reservation residents. Dividing this total by the 125 dispensaries mandated by Prop. 203 would result in an average of approximately 52,000 residents per dispensary. Close to this average would result whether the dispensaries were distributed by numbers of pharmacies or by per-capita population per County. Distributing the dispensaries by the AZDHS CHAA proposal radically revises the distribution so that dispensaries in rural areas will serve far fewer residents than those in urban areas.

In my opinion the AZDHS proposal is a clear and blatant violation of the Arizona Voter Protection Act and the provisions of Prop… 203. The fact that Prop. 203 provided that the total dispensaries in the State would be determined by a 1 to 10 ratio clearly implies that distribution of dispensaries throughout the State should be done by the same method. As mentioned above, distribution by per-capita population would yield similar results, with just a few dispensaries being transferred from Maricopa and Pima Counties to several smaller rural Counties.

Prop. 203 implied that distribution should be based on number of pharmacies. Moreover, it dealt specifically with the situation where a small population County might not be entitled to a dispensary because it has few pharmacies. It provided that each County, no matter how small, would be entitled to no less than one dispensary if there were a qualified applicant. Prop.. 203 provided that the State total of dispensaries could be increased above the number specified in the law, if necessary to provide at least one to each County. Distributing dispensaries by CHAA flies in the face of the clear language of Prop… 203. If litigation were filed, the CHAA distribution would probably be struck down by a Court, since it flies in the face of the language of Prop… 203 and its effects are so clearly unjust.

It is obvious that the reason AZDHS decided to distribute dispensaries per CHAA is that it will spread the dispensaries out throughout the entire State and increase the percentage of Arizona’s land that will be covered by “grow your own exclusion zones” of 25 mile radius which will exist around each dispensary. I can understand how many could consider this to be a worthy goal. Even if the goal is worthy, it does not justify such a radical perversion of the intent of Prop. 203.

I can see several specific negative consequences of distribution of dispensaries by CHAA.

Since the urban areas will have dispensaries serving very large populations, those dispensaries will become very large operations. This could be difficult in light of the fact that many if not most Cities and Counties are putting square footage limitations on dispensaries.
Of the 20 smallest CHAAs, 13 have 2010 populations of less than 10,000. All of the smallest 20 CHAAs have 2010 populations less than 15,000. Some have only the smallest of towns or settlements and may not have commercial suitable space available for a dispensary. Many of these CHAAs are very large geographically with their population densities being extremely low.
In many cases, because of the very small populations and very low population densities, these low population CHAAs may not be able to support the operation of a dispensary. Many of these dispensaries could fail and go out of business. As they were in the process of going out of business, numerous problems involving patient services, defaulting on financial obligations and others could arise. Having dispensaries go out of business would decrease the stability of the industry and create additional problems for AZDHS to have to deal with.
Presumably if a small population CHAA went out of business, the “grow your own exclusion zone” would go away and the original motive of those proposing distribution by CHAA would be frustrated.
The CHAA proposal is not necessary. There are better ways to distribute dispensaries in a way that would not create such radical distortions. Gila County is a good example. It would receive only one dispensary whether they are distributed by number of pharmacies or by population. Gila County’s population is divided, more or less evenly, between Payson in the North and Globe in the South. The road between the 2 towns is over 80 miles. They have a legitimate desire to have a “grow your own exclusion zone” surrounding both towns.

Here is a way to solve the problem without creating all of the problems involved with the CHAA rule. AZDHS could write a rule that would allow a County, such as Gila County, to request, based on its particular circumstances, that it have its one dispensary operate out of 2 locations, one in Payson and the other in Globe. It could qualify as one dispensary rather than 2 by operating out of the 2 locations on alternate days and never being both open at the same time. AZDHS would impose a “25 mile radius grow your own exclusion zone” around each location of the one dispensary.

Although the dispensary would have increased costs maintaining 2 operating locations, it would be able to share other costs like wages between the 2 locations. A single dispensary operating out of 2 separate limited hours locations would be more likely to survive financially than 2 separately owned dispensaries with larger operating costs.

Other rural Counties with large distances separating their population centers could benefit by such a rule. This would satisfy the goal of reducing the area where self cultivation is allowed while avoiding the instability involved with trying to force people to operate dispensaries in locations that are not viable. There will inevitably remain some locations that will not have dispensary locations even with the suggested rule. Even the CHAA rule does not completely eliminate areas where card holders could grow their own. These areas have very low population density and the number of card holders living in them would likely be quite small. It seems unlikely that many cardholders would move to one of these unprotected locations just so they could grow their own medical marijuana.

People who are interested in Prop. 203 should take the opportunity to submit their concerns and suggestions to AZDHS in the next several weeks. They should also consider attending the public meetings where they can voice their concerns and suggestions.

___________________________

 

[Eli Bloom]

it seems like it might be way easier to apply to be a caregiver and then find patients outside of the 25 mile zone? i can't tell if caregivers would be allowed to grow in their own home without all of the restrictions placed on dispensary grow facilities. also i don't think that caregivers would have to be outside of the 25 mile range, only the patients.

 

[bluepeace]

What's your source of that info, bluepeace?

Public record! I must explain. The 15 different dispensaries have been approved by the zoning side only. AZDHS has not given the go head to produce or stock yet because the application's are not final. (nor are the rules) These 15 have a nice head-start.

On a another note how about MPP writing the rules and regs. for the AZDHS looks like shenanigans! I wished I could have donated enought Money to the MPP so they could lobby AZDHS for me to get a dispensary!

 

[Dignan]

Public record! I must explain. The 15 different dispensaries have been approved by the zoning side only. AZDHS has not given the go head to produce or stock yet because the application's are not final. (nor are the rules) These 15 have a nice head-start.

On a another note how about MPP writing the rules and regs. for the AZDHS looks like shenanigans! I wished I could have donated enought Money to the MPP so they could lobby AZDHS for me to get a dispensary!

Zoning is being done by local municipalities and counties. The DHS has nothing to do with it, outside of making a few recommendations.

Dispensary applications aren't available yet.

 

[bluepeace]

Zoning is being done by local municipalities and counties. The DHS has nothing to do with it, outside of making a few recommendations.

Dispensary applications aren't available yet.

You are fabulously correct. I was inaccurate.

What do you make of this? http://www.keytlaw.com/arizonamedicalmarijuanalaw/2011/01/alan-sobol-phoenix-zoning/

 

[Dignan]

It seems like the City of Phoenix just didn't observe protocol. And it may bite them in the ass if a lawsuit is filed for some reason.

Still, it has little or nothing to do with being awarded an actual dispensary license, as far as I can see.