An Open Letter To The Boston Cannabis Board Members

By Kathleen Joyce, Monica Valdes Lupi, Darlene Lombos, Lisa Holmes, and John Smith

Boston Cannabis Board
City Of Boston
1 City Hall Square
Boston , MA  02201-2035

Dear Cannabis Board Members,

As the Boston Cannabis Board assumes control over selection of marijuana retail operators, you have an invaluable opportunity to make a corrective change in the local marijuana licensing process. We want to share with you some important thoughts on the topic.

Landlords are unfairly controlling the marijuana licensing process in Massachusetts, especially for retail stores. This may seem a preposterous statement on its face, but it has gained traction within the advocacy community, is well-known by the social equity and economic empowerment community, and is being slowly recognized by municipal leaders.

When a municipality requires a candidate to first secure a location before applying for a coveted host community agreement, control over selection is abrogated to the landlords. Landlords, rather than focus on which operator is the best fit for the community or most aligned with the restorative justice goals embedded in the enabling legislation, select the candidate willing to pay the highest rent and write a check for the largest deposit. This issue is well-publicized in stories throughout the commonwealth and at present is one of the main limiting factors preventing minority and disadvantaged teams from securing a meaningful foothold in the Massachusetts cannabis industry.

Boston could change that.

The City of Boston Marijuana Establishment Application requires both a facility address and selection of a city neighborhood. We urge you to bifurcate the approval process into two steps and eliminate the requirement of an address in advance. This will allow you to focus on selecting the best operator for the community. Once an operator is selected, allow them a reasonable time to identify a location and return for BCB approval. This will allow you to maintain full control, but should also expand the field of applicants to include more local (and social equity) prospective operators.

Today, the applicants you will see are those candidates that have outbid others to secure prime real estate or have deep enough pockets to carry the property empty for extended periods (often exceeding a year) as they navigate the local licensing process. Some of your residents who are vying for a retail marijuana license in Boston have depleted their capital paying these hold fees.

The Town of Maynard pioneered this approach and it has been recently adopted by the City of Westfield. Other communities are considering it. We urge the BCB to join this approach and fix this upside down process where landlords are the gatekeeper.

Below are links to articles that may be of interest.

Thank you for your consideration,

David Rabinovitz, CEO & Social Equity advocate 

NewCann Group /
Cannabis Control Commission social equity training program trainer

Peter Bernard, Executive Director

Bill Flynn, President

MassCann/NORML – Massachusetts Cannabis Reform Coalition
And an Economic Empowerment certificate holder

Richard Evans, Attorney-at-Law

Former Chair Yes On 4 Campaign to Tax & Regulate Marijuana

Will Luzier, Allston Resident & Attorney

Former Campaign Manager for Yes On 4 Campaign to Tax & Regulate Marijuana
Cannabis Commerce Consultant

Blake Mensing, Cannabis Attorney

Former Associate Town Counsel (7 municipalities)
Former Conservation Commissioner

Bill Downing, Founder and past President

MassCann/NORML – Massachusetts Cannabis Reform Coalition
Owner, CBD Please


The Mass Host Community Agreement fiasco rears its ugly head

How the mad dash for HCAs is a windfall for landlords at the expense of local economic progress

Maynard Grants Retail HCA without a predefined location 

Westfield Allows Retail Applicants to Apply for an HCA without a location