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Rules team outlines heavy workload, APA process constraints and statutory gaps in cannabis rulemaking
Summary
The rules team told the board a small rules staff is producing many APA filings and handling frequent petitions; staff warned that sparse statutory language for some cannabis issues forces consequential rulemaking that is legally risky and time‑consuming.
Kevin, representing the rules team, told the executive management team the unit is comparatively small yet consistently produces a high volume of filings under the Administrative Procedures Act. He said rules coordinators have at times filed as many as 12 APA proposals in a single quarter and that, given current staffing, each coordinator averages a high number of filings per year.
He described the full scope of the work: preparing CR‑102…
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