The CCA thus creates a two-step appellate process in order to challenge denial of a registry identification card. (A patient must have this state-issued ID card in order to obtain cannabis from a store under the CCA – since it does not permit individual cultivation.) The patient must submit the appeal first to the advisory committee, which reviews the appeal and sends its recommendations to the Commissioner. This system is instead of simply creating an administrative appeals process within the Department.
How many appeals will there be?
Instead of agreeing to participate in a series of meetings to draft proposed regulations you would agree to be sucked into acting as a judge for a caseload of appellants – with no sense of what volume of cases there might be.