The Compassionate Use Act of 1996, an initiative measure enacted by the approval of Proposition 215 at the November 5, 1996, statewide general election, allows the use of marijuana for medical purposes. The Medical Marijuana Regulation and Safety Act, enacted by the Legislature, provides for the state licensure and regulation of certain commercial cannabis activities by the Department of Consumer Affairs, the Department of Food and Agriculture, or the State Department of Public Health, as specified. The act establishes the Bureau of Medical Marijuana Regulation within the Department of Consumer Affairs, under the supervision and control of the Director of Consumer Affairs, and requires the director to administer and enforce the provisions of the act. Existing law requires the Governor to appoint a chief of the bureau, subject to confirmation by the Senate, to serve under the direction and supervision of the director and at the pleasure of the Governor.

Existing law, the doctrine of tribal immunity and the Indian Commerce Clause, precludes the state, with certain exceptions, from asserting authority over the activities of federally recognized Indian tribes on their own lands.

This bill would authorize the Governor to enter into agreements concerning medical cannabis with federally recognized sovereign Indian tribes, as defined. The bill would authorize these agreements to include provisions regulating activities between licensees operating on and off the land of federally recognized sovereign Indian tribes. The bill would require these agreements to include a provision requiring individuals conducting medical cannabis business activity on tribal land to meet the state and local licensure requirements that are required of licensees operating in the jurisdiction of the local government in which the tribal land is located. The bill would authorize the Governor to delegate to the chief of the bureau authority to negotiate these agreements.

The Compassionate Use Act of 1996, an initiative measure enacted by the approval of Proposition 215 at the November 5, 1996, statewide general election, authorizes allows the use of marijuana for medical purposes. The Medical Marijuana Regulation and Safety Act, enacted by the Legislature, provides for the state licensure and regulation of certain commercial cannabis activities by the Department of Consumer Affairs, the Department of Food and Agriculture, or the State Department of Public Health, as specified. The act establishes the Bureau of Medical Marijuana Regulation within the Department of Consumer Affairs, under the supervision and control of the Director of Consumer Affairs, and requires the director to administer and enforce the provisions of the act. Existing law requires the Governor to appoint a chief of the bureau, subject to confirmation by the Senate, to serve under the direction and supervision of the director and at the pleasure of the Governor.

This bill would state the intent of the Legislature to enact legislation addressing the state regulation of medical cannabis grown on, but transported out of, tribal lands. authorize the Governor to enter into agreements concerning medical cannabis with federally recognized sovereign Indian tribes, as defined. The bill would authorize these agreements to include provisions regulating activities between licensees operating on and off the land of federally recognized sovereign Indian tribes. The bill would authorize the Governor to delegate to the chief of the bureau authority to negotiate these agreements.

The Compassionate Use Act of 1996, an initiative measure enacted by the approval of Proposition 215 at the November 5, 1996, statewide general election, authorizes the use of marijuana for medical purposes. The Medical Marijuana Regulation and Safety Act, enacted by the Legislature, provides for the state licensure and regulation of certain commercial cannabis activities by the Department of Consumer Affairs, the Department of Food and Agriculture, or the State Department of Public Health, as specified.

This bill would state the intent of the Legislature to enact legislation addressing the state regulation of medical cannabis grown on, but transported out of, tribal lands.

Date of Hearing: May 18, 2016

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Lorena Gonzalez, Chair

ABPCA Bill Id:AB 2545

Author:(Bonta) – As Amended Ver:April 26, 2016

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill authorizes the Governor to enter into agreements concerning medical cannabis with federally recognized sovereign Indian tribes, as specified, and authorizes the Governor to delegate to the chief of the Bureau of Medical Marijuana Regulation (Bureau) within the Department of Consumer Affairs authority to negotiate the agreements.

In addition, it requires any such agreement to require individuals conducting medical cannabis business activity on tribal land to meet the state and local licensure requirements applicable in the jurisdiction of the local government in which the tribal land is located.

FISCAL EFFECT:

1. Assuming the Governor delegated authority to the Bureau to negotiate agreements with federally recognized sovereign Indian tribes, the Bureau would need $150,000 in fiscal year 2016-17, and $270,000 every year thereafter (Medical Marijuana Regulation and Safety Act Fund).

Implementation would require an attorney to meet with all Indian tribes in California that choose to enter into agreements and negotiate the terms of the agreements, and additional staff to assist with the development of regulations and monitoring of agreements.

1. With approximately 110 federally recognized sovereign Indian tribes and assuming all tribes would pursue an agreement with the state, the Bureau would also incur about $115,000 in travel expenses in the first year of implementation (Medical Marijuana Regulation and Safety Act Fund).
2. State licensure and enforcement costs could also potentially be large if a large number of entities on tribal lands seek state licensure (Medical Marijuana Regulation and Safety Act Fund, reimbursed by licensure fees).

COMMENTS:

1. Purpose. This bill is sponsored by the author. According to the author, this bill will guide California on a pathway to integrating tribal governments and businesses on sovereign land into the the regulated market for medical cannabis (or marijuana).
2. Background. Medical cannabis, though illegal under federal law, has been legal under state law since the passage of Proposition 215 in 1996. The Medical Marijuana Regulation and Safety Act (MMRSA) was a package of three bills enacted together in 2015 to regulate the medical marijuana industry and license its participants. The bills created a comprehensive state regulatory system for the commercial cultivation, manufacture, retail sale, transport, distribution, delivery, and testing of medical cannabis. Various state agencies are tasked with implementation, and implementation-related Budget Change Proposals proposed in the 2016-17 Governor's Budget being considered through the budget process.

MMRSA is based on a system of dual licensure—all businesses must have both a state and a local license. However, under current law, tribal governments are sovereign entities, not subject to the new regulatory scheme. Under MMRSA, licensed businesses can only conduct business with other licensees. If businesses on sovereign land are unable to obtain a state license, they would be excluded from the state system and unable to legally interact with the rest of the industry.

1. Related federal memoranda. The August 29, 2013 Memorandum issued by the U.S. Department of Justice (DOJ) indicates that while cannabis remains a Schedule 1 drug, the federal government is less inclined to intervene in states that have authorized medical cannabis use if the states have strong and effective regulatory and enforcement systems. It also listed federal enforcement priorities, including preventing diversion to minors or to states where marijuana is illegal, preventing violence and the use of firearms in trafficking, and preventing drugged driving and adverse public health consequences, among other priorities.

On October 28, 2014, U.S. DOJ published a memorandum regarding cannabis issues on tribal lands. The statement reaffirmed that the Cole Memorandum does not alter the authority or jurisdiction of the U.S. to enforce federal law on sovereign lands; however, it stated the priorities listed in the 2013 Cole Memorandum will guide the U.S. Attorneys’ cannabis enforcement efforts on sovereign lands. As such, in order for a state to have a complete and robust regulatory system for medical cannabis operations, the author of this bill believes it is important to include businesses on sovereign lands.

1. Related legislation. Eight other bills active in this session address various issues of cannabis regulation, taxation, reporting, and other issues, including AB 1575 (Bonta), which is pending on the Suspense File of this committee
2. Prior Legislation. AB 266 (Bonta, Cooley, Jones-Sawyer, Lackey, and Wood), Chapter 689, Statutes of 2015; SB 643 (McGuire), Chapter 719, Statutes of 2015; and AB 243, described above, were companion bills that formed the MMRSA.

Analysis Prepared by: Lisa Murawski / APPR. / (916) 319-2081

Date of Hearing:

ASSEMBLY COMMITTEE ON BUSINESS AND PROFESSIONS

Rudy Salas, Chair

ABPCA Bill Id:AB 2545

Author:(Bonta) – As Amended Ver:March 18, 2016

SUBJECT: Medical cannabis: agreements with tribal governments.

SUMMARY: Authorizes the Governor to enter into agreements concerning medical cannabis with federally recognized sovereign Indian tribes; authorizes the agreements to include provisions regulating activities between licensees operating on and off the land of federally recognized sovereign Indian tribes; and authorizes the Governor to delegate to the chief of the Bureau of Medical Marijuana Regulation (BMMR) authority to negotiate the agreements.

EXISTING LAW:

1. Enacts the Medical Marijuana Regulation and Safety Act (Act), which provides for the state licensure and regulation of commercial cannabis activities, including cultivation, possession, manufacture, processing, storing, laboratory testing, labeling, transporting, distribution, and sale of medical cannabis or medical cannabis products. (Business and Professions Code (BPC) § 19300, et seq.)
   
2. Establishes the Bureau of Medical Marijuana Regulation (Bureau) within the Department of Consumer Affairs (DCA), and requires the Bureau, the California Department of Public Health (CDPH), and the California Department of Food and Agriculture (CDFA) to administer the Act and promulgate regulations for implementation of the act. (BPC § 19300, et seq.)
   
3. Vests in the DCA the sole authority to create, issue, renew, discipline, suspend, or revoke licenses for medical marijuana activities, including licenses for dispensaries, distributors, and transporters. Prohibits a licensee from holding more than one license except as specified. (BPC §§ 19302.1, 19328)
   
4. Allows the Bureau to convene an advisory committee to advise the Bureau and licensing authorities on the development of standards and regulations, including best practices and guidelines to ensure qualified patients have adequate access to medical marijuana and medical marijuana products. (BPC § 19306)
5. Provides that the actions of a licensee permitted pursuant to both a state license and a license or permit issued by the local jurisdiction following the requirements of the applicable local ordinances, and conducted in accordance with the Act are not unlawful under state law. (BPC § 19317)
6. Prohibits a person from engaging in commercial cannabis activity without possessing both a state license and a local permit or other authorization upon the date of implementation of regulations by the licensing authority. (BPC § 19320)
   
7. Requires the Bureau to deny an application if the applicant or the premises do not qualify for licensure or fail to comply with the Act. (BPC § 19323)
   
8. Allows licensing authorities to take disciplinary action against a licensee for any violation of any provision of the law, and requires a licensing authority to inform the Bureau upon suspension or revocation of a license. (BPC §§ 19313, 19313.5)
   
9. Provides that nothing shall be interpreted to supersede or limit existing local authority for law enforcement activity, enforcement of local zoning requirements or local ordinances, or enforcement of local permit or licensing requirements. (BPC § 19315)
   
10. Requires the CDFA to administer the provisions of the Act related to the cultivation of medical cannabis; to create, issue, and suspend or revoke cultivation licenses for violations of the Act; and to promulgate regulations governing the licensing of indoor and outdoor cultivation sites. (BPC § 19302.1, 19332)
    
11. Authorizes a county to impose a tax on the privilege of cultivating, dispensing, producing, processing, preparing, storing, providing, donating, selling, or distributing medical cannabis or medical cannabis products by a licensee operating pursuant to the Act, as specified. (BPC § 19348)

THIS BILL:

1. Authorizes the Governor to enter into agreements concerning medical cannabis with federally recognized sovereign Indian tribes.
2. Defines “federally recognized sovereign Indian tribe” as any Indian tribe, band, nation, or community wholly or partially located within the geographical boundaries of the State that the Secretary of the Interior acknowledges to exist as an Indian tribe, as specified.
3. Specifies that agreements may include provisions regulating activities between licensees operating on and off the land of a federally recognized sovereign Indian tribe.
4. Authorizes the Governor to delegate to the Chief of the Bureau the authority to negotiate agreements, as specified.

FISCAL EFFECT: Unknown. This bill is keyed fiscal by the Legislative Counsel.

COMMENTS:

Purpose. This bill is sponsored by the author. According to the author, “In 1996, California was the first state in the nation to allow the use of medical cannabis after voters approved Proposition 215, the California Compassionate Use Act. Since then, 22 other states and the District of Columbia have passed laws allowing for the medical or adult use of cannabis. In 2015, California passed the Medical Marijuana Regulation and Safety Act (MMRSA), the first comprehensive regulatory framework for medical cannabis in the state’s history.

MMRSA is based on a system of dual licensure—all businesses must have both a state and a local license. However, under current law, tribal governments are sovereign entities, not subject to the new regulatory scheme. Furthermore, tribal governments are only subject to criminal law, not civil law, except as negotiated between the State of California and the tribal entity. Moreover, under MMRSA, licensed businesses can only conduct business with other licensees. If businesses on sovereign land are unable to obtain a state license, they would be excluded from the state system and unable to interact with the rest of the industry.

AB 2545 will guide California on a pathway to integrating tribal governments and businesses on sovereign land into the rest of the regulated market under the Act. It will also ensure that medical cannabis businesses on sovereign lands comply with the priorities laid out by the federal government.”

Background. The Compassionate Use Act of 1996 (CUA). Proposition 215 was approved by California voters to exempt certain patients and their primary caregivers from criminal liability under state law for the possession and cultivation of marijuana. Proposition 215 was enacted to “ensure that seriously ill Californians have the right to obtain and use marijuana for medical purposes where that medical use is deemed appropriate and has been recommended by a physician who has determined that the person’s health would benefit from the use of marijuana,” and to “ensure that patients and their primary caregivers who obtain and use marijuana for medical purposes upon the recommendation of a physician are not subject to criminal prosecution or sanction.”

The Medical Marijuana Program Act. SB 420 (Vasconcellos), Chapter 875, Statutes of 2003, established the Medical Marijuana Program Act (MMP). The MMP, among other things, required the CDPH to establish and maintain a program for a statewide identification card system. Medical marijuana identification cards are intended to help law enforcement officers identify and verify that cardholders are able to cultivate, possess, and transport certain amounts of marijuana without being subject to arrest under specific conditions. All counties participate in the identification card program; however, participation by patients and primary caregivers in the identification card program is voluntary.

In 2008, the Attorney General issued guidelines to: 1) ensure that marijuana grown for medical purposes remains secure and does not find its way to non-patients or illicit markets, 2) help law enforcement agencies perform their duties effectively and in accordance with California law, and 3) help patients and primary caregivers understand how they may cultivate, transport, possess, and use medical marijuana under California law.

Since the passage of Proposition 215, a flood of medical marijuana collectives and cooperatives have created a patchwork of local regulations for these industries and with little statewide involvement.

The Federal Controlled Substances Act. Despite the CUA and SB 420, marijuana is still illegal under federal law. Adopted in 1970, the Controlled Substances Act (CSA) established a federal regulatory system designed to combat recreational drug abuse by making it unlawful to manufacture, distribute, dispense, or possess any controlled substance. (Title 21 United States Code Section (USC) 801, et seq.) Under California law, marijuana is listed as a hallucinogenic substance in Schedule I of the California Uniform Controlled Substances Act. Yet, the CUA prohibits prosecution for obtaining, distributing, or using marijuana for medical purposes. However, under the federal CSA, it is unlawful for any person to manufacture, distribute, dispense or possess a controlled substance, including marijuana, whether or not it is for a medical purpose. As a result, patients, caregivers, and dispensary operators, who engage in activities relating to medical marijuana, may still vulnerable to federal arrest and prosecution.

Congress has provided that states are free to regulate in the area of controlled substances, including marijuana, provided that state law does not positively conflict with the CSA. (Title 21 USC Section 903.) Neither Proposition 215, nor the MMP, conflicts with the CSA because medical marijuana use has not been “legalized” medical marijuana in the state; instead, California has tried to avoid this conflict by not pursuing the state's powers to punish certain offenses when a physician has recommended marijuana as a treatment for a serious medical condition.

The Medical Marijuana Regulation and Safety Act. The Act consisted of three separate bills which were enacted together on Sept 11, 2015, to bring licensure and regulation to the medical marijuana industry nearly 20 years after the passage of Proposition 215 in 1996. The bills created a comprehensive state licensing system for the commercial cultivation, manufacture, retail sale, transport, distribution, delivery, and testing of medical cannabis. In addition, the bills affirm local control and require licensure by both a local government and the state in order for a licensee to operate. The Act went into effect on January 1, 2016, although licensure requirements will not go into effect until the regulatory entities responsible for implementing the act pass necessary regulations.

Among other things, the Act establishes the new Bureau under the DCA, which is responsible for licensing and regulating dispensaries, transporters, and distributors. In addition, the CDPH is responsible for regulating manufacturers, testing laboratories, and the production and labeling of edible medical marijuana products. The CDFA is responsible for regulating cultivation, and other state agencies, such as the Department of Pesticide Regulation (DPR) and the State Water Resources Control Board (SWRCB), are responsible for developing environmental standards.

Under the Act, applicants seeking licensure to cultivate, distribute, or manufacture medical cannabis are required to include a detailed description of the applicant's operating procedures for cultivation, extraction and infusion methods, transportation process, inventory procedures, and quality control procedures.

Federally Recognized Tribes and Reservations. According to the U.S. Department of the Interior Indian Affairs, a federally recognized tribe is an American Indian or Alaska Native tribal entity that is recognized as having a government-to-government relationship with the United States, with the responsibilities, powers, limitations, and obligations attached to that designation, and is eligible for funding and services from the Bureau of Indian Affairs. These tribes are recognized as possessing certain inherent rights of self-government (e.g., tribal sovereignty) and are entitled to receive certain federal benefits, services, and protections because of their special relationship with the United States.  At present, there are 566 federally recognized American Indian and Alaska Native tribes and villages.

The U.S. Department of the Interior Indian Affairs defines a federal Indian reservation as an area of land reserved for a tribe or tribes under treaty or other agreement with the U.S., executive order, or federal statute or administrative action as permanent tribal homelands, and where the federal government holds title to the land in trust on behalf of the tribe. Approximately 56.2 million acres are held in trust by the United States for various Indian tribes and individuals.  There are approximately 326 Indian land areas in the U.S. administered as federal Indian reservations (i.e., reservations, pueblos, rancherias, missions, villages, communities, etc.).  Some reservations are the remnants of a tribe’s original land base.  Others were created by the federal government for the resettling of Indian people forcibly relocated from their homelands.  Not every federally recognized tribe has a reservation.  Federal Indian reservations are generally exempt from state jurisdiction, including taxation, except when Congress specifically authorizes such jurisdiction.

The Relationship Between Federally Recognized Tribes and Government. According to the U.S. Department of the Interior Indian Affairs, because the Constitution vested the Legislative Branch with plenary power over Indian Affairs, states have no authority over tribal governments unless expressly authorized by Congress. While federally recognized tribes generally are not subordinate to states, they can have a government-to-government relationship with these other sovereigns, as well.  Furthermore, federally recognized tribes possess both the right and the authority to regulate activities on their lands independently from state government control.  They can enact and enforce stricter or more lenient laws and regulations than those of the surrounding or neighboring state(s) wherein they are located. Yet, tribes frequently collaborate and cooperate with states through compacts or other agreements on matters of mutual concern such as environmental protection and law enforcement.

The 2013 Cole Memorandum. The Cole Memorandum indicates that while cannabis remains a Schedule 1 drug, the federal government is less inclined to intervene in states that have authorized medical cannabis use with strong and effective regulatory and enforcement systems that prioritize certain policies. Specifically, the Cole Memorandum lists eight federal law enforcement priorities where the federal Department of Justice will focus its limited investigative and prosecutorial resources in all states. These eight priorities are as follows:

1. Preventing the distribution of marijuana to minors;
2. Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs, and cartels;
3. Preventing the diversion of marijuana from states where it is legal under state law in some form to other states;
4. Preventing state-authorized marijuana activity from being used as cover or pretext for the trafficking of other illegal drugs or illegal activity;
5. Preventing violence and the use of firearms in the cultivation and distribution of marijuana;
6. Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use;
7. Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands; and,
8. Preventing marijuana possession or use on federal property.

The 2014 Wilkinson Memorandum. In October 2014, the U.S. Department of Justice published a memorandum regarding cannabis issues on tribal lands. The statement reaffirmed that the Cole Memorandum does not alter the authority or jurisdiction of the U.S. to enforce federal law on sovereign lands; however, the priorities listed in the 2013 Cole Memorandum will guide the U.S. Attorneys’ cannabis enforcement efforts on sovereign lands. As such, in order for a state to have a complete and robust regulatory system for medical cannabis operations, the system should make certain that all businesses on sovereign lands comply with the 2013 Cole Memorandum.

Current Related Legislation. AB 26 (Jones-Sawyer) of the current legislative session requires a licensee under the Act to institute and maintain a training program to educate, inform, and train the licensee's agents and employees regarding compliance with the Act, and requires the Bureau to approve and regulate the training programs. STATUS: This bill is pending in the Senate Committee on Business, Professions and Economic Development.

AB 567 (Gipson) of the current legislative session, would prohibit mobile, vehicular, or technology platforms that enable qualified patients or primary caregivers to arrange for any delivery with a third party; would provide that a dispensary that employs or uses the services of any person under 21 years of age for the sale or delivery of medical cannabis or medical cannabis products is subject to suspension or revocation of certain state or local licenses; and would require tax penalty amnesty programs, for medical cannabis-related businesses, as provided. STATUS: This bill is pending in the Senate Committee on Health.

AB 1548 (Wood) of the current legislative session, would impose a tax in specified amounts on the distribution in this state by a cultivator of marijuana to a licensed distributor, as specified; require the licensed distributor to collect the tax from the cultivator and remit it to the BOE; and require all moneys, less refunds and costs of administration, to be deposited into the Marijuana Production and Environment Mitigation Fund, as specified. NOTE: This measure died in the Assembly Committee on Revenue and Taxation.

AB 2385 (Jones-Sawyer) of the current legislative session prohibits licensing authorities from requiring a local license, permit, or other authorization, and would require the issuance of a state license, if the authorities determine that the applicant meets all of the requirements of the act, as specified, in the City of Los Angeles. STATUS: This bill will also be heard before the Assembly Committee on Business and Professions during today’s hearing.

AB 2516 (Wood) of the current legislative session provides for the issuance of a Type 1C, or “specialty cottage,” state cultivator license, as specified, by the CDFA. STATUS: This bill will also be heard before the Assembly Committee on Business and Professions during today’s hearing.

AB 2672 (Bonilla) of the current legislative session renames the Medical Marijuana Regulation and Safety Act (Act) to the Medical Cannabis Regulation and Safety Act; renames the Bureau of Medical Marijuana Regulation (Bureau) to the Bureau of Medical Cannabis Regulation; renames the Medical Marijuana Regulation and Safety Act Fund (Fund) to the Medical Cannabis Regulation and Safety Act Fund; renames the Medical Marijuana Fines and Penalties Account (Account) to the Medical Cannabis Fines and Penalties Account; and, makes other conforming changes throughout the Business and Professions (BPC), Fish and Game (FGC), Government (GOV), Health and Safety (HSC), Revenue and Taxation (RTC), and Water Codes (WAT). STATUS: This bill will also be heard before the Assembly Committee on Business and Professions during today’s hearing.

AB 2679 (Cooley) of the current legislative session increases the reporting requirements of the Bureau to include the number of appeals of denial of state licenses or other disciplinary actions taken by the licensing authorities, the number of complaints submitted to the Bureau regarding licenses; and, expands scope of the CMCR to include in its studies the effect of marijuana on a person’s motor skills. STATUS: This bill is pending in the Assembly Committee on Appropriations.

Prior Related Legislation. AB 266 (Bonta, Cooley, Jones-Sawyer, Lackey, and Wood), Chapter 689, Statutes of 2015, enacted the Act for the licensure and regulation of medical marijuana and established the Bureau within the DCA, under the supervision and control of the Director of the DCA, and required the Director to administer and enforce the provisions of the Act. AB 266 also required the CDFA to administer the provisions of the act related to cultivation, and required the CDPH to administer the provisions of the Act related to manufacturing and testing of medical cannabis. The bill also required the BOE, in consultation with the CDFA, to adopt a system for reporting the movement of commercial cannabis and cannabis products.

AB 243 (Wood), Chapter 688, Statutes of 2015, required the CDFA, the DPR, the CDPH, the DFW, and the SWRCB to promulgate regulations or standards relating to medical marijuana and its cultivation, as specified, required various state agencies to take specified actions to mitigate the impact that marijuana cultivation has on the environment, and established the Act Fund.

SB 643 (McGuire), Chapter 719, Statutes of 2015, set forth standards for a physician and surgeon prescribing medical cannabis, required the Medical Board of California to prioritize its investigative and prosecutorial resources to identify and discipline physicians and surgeons that have repeatedly recommended excessive cannabis to patients for medical purposes or repeatedly recommended cannabis to patients for medical purposes without a good faith examination, as specified, authorized counties to impose a tax upon specified cannabis-related activity, and set forth standards for the licensed cultivation of medical cannabis.

AMENDMENTS:

To ensure that there is parity between the requirements for cannabis growing, dispensing, transporting, and selling both on and off of tribal lands, an amendment will be added to the bill to require that the agreements the Governor executes with tribes must specify that tribes meet the same local and state licensure requirements that other licensees who participate in the medical cannabis industry are subject to.

REGISTERED SUPPORT:

None on file.

REGISTERED OPPOSITION:

None on file.

Analysis Prepared by: Le Ondra Clark Harvey Ph.D. / B. & P. / (916) 319-3301