We, the undersigned, are enthused that the newly released draft regulations take an important step towards creating an equitable cannabis delivery market. Through the creation of a wholesale delivery model that aims to be equitable, along with establishing an equity period of 3 years, the Commission has demonstrated leadership within the national conversation on Cannabis Social Equity.

However, there are some key inequities that remain that we feel will prevent the existing draft regulations from creating a fully equitable cannabis delivery market and, as such, we request the following changes to the draft regulations regarding Delivery:

Main Changes:

1. Repackaging Equality
   1. Add the ability for [wholesale] Delivery Operators to repackage marijuana and marijuana products purchased from cultivators, manufacturers and other Marijuana Establishments as is allowed for Marijuana Retailers.This will create a level playing field for Delivery Operators when purchasing cannabis.
2. One Driver
   1. Eliminate the requirement for Delivery Operators and Couriers to have two people in the vehicle during operations. Allowing only one driver will further the commission's aim to keep start-up costs low, increase the ability for independent Retailers to effectively partner with Marijuana Couriers, and maintain safety.
3. Prioritize Exclusivity
   1. Open the application portal for Delivery Operator Licenses by Q1 of 2021. We also request that the 3-year Exclusivity window starts at the commence operation date of the first [wholesale] Delivery Operators. This will allow [wholesale] Delivery Operators to not lose time in their exclusivity window due to Marijuana Couriers commencing operations first.

Minor Changes:

1. Clear & Concise License Names
   1. Change the name of the “Wholesale Delivery Licensee” and “Limited Delivery Licensee” to Marijuana Delivery Operator and Marijuana Courier respectively. The word “wholesale” in this context only creates confusion. The word “Limited” does not clarify anything in regards to its license type. The word “Licensee” (nor “License”) does not appear in any other license type. Providing straightforward and concise names to the license types will create clarity for busy municipal officials and other stakeholders as to what delivery companies are proposing to do in their cities and towns.
2. Ownership Limitations
   1. Ban 3rd party tech platforms from owning any portion of a delivery company.This will prevent an Amazon type of entity from taking over the delivery market.

We also support maintaining the following elements of the existing draft regulations:

1. Creation of a wholesale delivery license with the ability to store products overnight
2. The extension of the exclusivity period.
3. The classification that delivery companies are not defined as retailers.
4. Ability for delivery companies to white-label.

After signing the petition we encourage all signers to submit a public comment directly to the commission. You can learn how to make a public comment here.