NJ CRC’s License Application Reviews: Worse than you Think

The CRC has yet to award anyone from New Jersey an annual license to operate in the new recreational cannabis industry.  A handful of ATCs have been allowed to expand from medical only to include recreational sales, but all of those expanded ATCs are owned by large, out of state corporations doing business in multiple states (a.k.a. MSOs).

Despite the CRC touting the number of new conditional licenses issued, businesses are not permitted to legally operate with a conditional license!  To operate, you need to have a conditional conversion or annual license application approved.

And the CRC isn’t reviewing existing conditional license applications fast enough to ever get around to reviewing its lower priority conditional conversion or annual license applications.

Because the CRC gives priority to reviewing conditional license applications, regardless of time in, over conditional conversion and annual license applications, a conditional license application submitted today jumps ahead in the review queue of a conditional conversion or annual license application submitted months ago.  If the CRC is not reviewing conditional license applications faster than new conditional license applications are being submitted, an insurmountable backlog of conditional license applications to review will continue to grow.  In that scenario, the CRC will never get to approving the lower priority, but earlier submitted, conditional conversion or annual license applications.

At the CRCs current pace of application review, that backlog is large and most recently growing, not shrinking. 

That portends that at its current pace, the CRC will never get around to reviewing and issuing anyone a conditional conversion or annual license required to operate. 

Here is the evidence, provided in the data the CRC reports as part of every one of the Executive Director’s Recommendation on Conditional License Application memos it issues every time it recommends new conditional licenses for approval at each of the public CRC meetings:

Summary and analysis of new license application, approval and cure data from CRC
Waterfall Chart Showing New Applications vs Approvals & Returns for Cure
Trend line for Backlog of Conditional License Applications awaiting Approval or Return for Cure

The CRC made some progress and reduced the unreviewed conditional license application backlog during the period between March 31 and June 9th.  Unfortunately, that forward progress didn’t last, stopping after June 9th.  The backlog went from of 181 conditional license applications that have not completed review to a backlog of 188 between June 9th and July 17th, the most recent period of data provided.

Until the backlog gets entirely cleared and the line in this chart gets to zero, except for a few possible social equity applicants, conditional conversion and annual license applications won’t be reviewed, and new operational businesses won’t enter the New Jersey legal cannabis market.

This would represent a failure on the part of the CRC to live up to its own mission of creating a legal cannabis industry based first and foremost on equity.

Here are some solutions the CRC could implement to remedy this:

  1. Substantially increase the pace at which application reviews are completed, perhaps by adding additional staff or prioritizing license review ahead of ATC expansion.
  2. Change the review priority such that conditional conversions and possibly annual license reviews that have already applied are given higher priority than new conditional applications submitted in the future. 
  3. Create “application windows” that allow all license type applications to be reviewed ahead of any application type submitted in a subsequent window.
  4. Announce an upcoming closure to the new conditional license application window.

We urge the CRC to take the necessary corrective actions to remedy the lack of conditional conversion and annual license applications reviewed and be able to truly deliver an outcome that delivers equity to the New Jersey Recreational Cannabis marketplace.

One response to “NJ CRC’s License Application Reviews: Worse than you Think”

Leave a Reply

Blog at WordPress.com.