Ever since the Alabama Medical Cannabis Commission released its proposed rules governing the cultivation, processing, testing, transporting, and dispensing of medical cannabis there have been questions, comments, and concerns about certain of the proposed rules. In my view, the proposed rules are generally as expected. One surprise to many, however, was the timeline for issuance of the licenses. Many assumed – based on the statutory requirements that the commission accept licenses by September 1, 2022, and that the commission make a decision within 60 days – that licenses would be awarded late this year. Others, including the author, assumed that licenses would be awarded by the commission in early 2023. At the end of the section on Applications and Licensing Requirements, the commission set out a detailed timeline for the application and license awarding processes. The key takeaways:

1. Applicants can “request” a “License Application Form” from the commission between September 1 and October 17.
2. The deadline for submitting applications is December 30.
3. The commission intends to issue licenses on July 10, 2023.

This is the first time the commission has laid out a clear timeline, and it dramatically pushes out the date on which would-be applicants can hope to learn that they have been awarded a cannabis license. To be clear, I do not wish to criticize the commission or its timeline. The commission has been at the mercy of certain statutory deadlines ever since the commission was created, and at some point the commission had to make a determination about whether it would strictly adhere to the most stringent reading of the statutory deadlines at the expense of establishing a safe and effective medical cannabis program in Alabama. It appears the commission has declined to do so. Discerning readers noticed that we called these “proposed” rules.  The rules are subject to change before they become final. The commission will accept written submissions of data, views or arguments concerning the proposed rules until 5 p.m. (CST) on August 5, 2022. The final rules are expected to take effect on or about October 17, 2022.