Madame Chair, members of the Subcommittee, thank you for the opportunity to make a comment today. My name is Shaleen Title, I previously served as a commissioner and currently I spend my time doing two things: first, examining solutions to prevent a national cannabis monopoly through a partnership with a university, and second, educating and advocating for those solutions through the nonprofit think tank Parabola Center. I have three points to make, all coming through that lens.

1. First, I have always opposed the rule requiring two drivers because it was not based on evidence, so of course I support lifting that requirement. If you encounter resistance, one option might be to recommend that the commission lift the requirement temporarily to gather evidence to be considered as part of the process to collect and evaluate data when it decides whether to extend the exclusivity period. That way, both public safety data and the financial feasibility of the regulation which is already required to be examined will be looked at side by side as part of a public process that is already built into the regulations, providing some structure to the permanent decision about two drivers.

2. Second, with respect to removing the vertical integration requirement, which I think is a no-brainer, I urge you to recommend (as Ms. Lucien mentioned) that social equity and economic empowerment licensees (and potentially state-certified disadvantaged business enterprises as Ms. Gomez Andrews mentioned) have exclusive access to all types of medical cannabis licenses for at least 5 years. The last thing we want to do is remove the vertical integration requirement without that type of proactive measure, which will essentially permanently cement the inequities going back a full decade now and currently reflected in the demographic data of medical operator ownership.

3. Third, and most importantly, thanks to the hard work of many of you, the historic cannabis and equity bill passed this summer that is now law essentially puts the commission in charge of whether they want to make the municipal process equitable, and how to do it. In the briefest terms possible, some concern is warranted because any agency is incentivized to lay low, keep things the same, and make the fewest changes possible, unless there’s an outside incentive to be bold and in this case create a strong framework for cities and towns to act equitably, for example through the model HCA, the enforcement of HCA laws, and the municipal equity rules. Historically this body, this subcommittee, has been a positive significant factor in providing incentive and cover for the commission to be bold when it comes to equity, and providing important accountability when that’s not happening. So I encourage you to continue that role because accountability will be critical in this coming year.

Thank you for your time and please don’t hesitate to follow up with me individually to discuss any of these issues further.