The Summit Lounge CEO’s Letter To Regulators About Social Consumption

Kyle Moon: “The CCC needs to address the current regulatory environment of the cannabis industry before issuing this license type.”


In September 2023, when it was still unclear when or even if there would be movement on social cannabis consumption licensing in Massachusetts, we visited the Summit Lounge in Worcester to hear what its CEO Kyle Moon had to say about the issue. Since they had opened what was basically the sole enduring Bay State smoking venue of its type all the way back in 2018, we asked what his team at the lounge had learned up to that point, and what social consumption regulations ought to look like—and not look like—when they finally come out.

Now that the draft language for three types of Social Consumption Establishment (SCE) licenses has been introduced, and is making its way through the rewriting process, we’re still looking to Moon, as well as others with significant experience in this realm, for guidance, and we hope that regulators are as well. After all, who would know better than somebody who has operated responsibly for years?

Below, we reprinted the text of a letter that the Summit Lounge founder sent to the Cannabis Control Commission during the “informal public comment period” that ended last Thursday. -TJM Editors


To Whom it May Concern,

As the clerk of the Summit Private Lounge, I believe it is part of my responsibility to voice my concerns and those of others over the current cannabis regulations as they stand. While The Summit Lounge is not considered a social consumption establishment, we work day in and day out with the cannabis community and industry. Now entering our seventh year of operation, we have seen the cannabis industry move from an idea to a reality.

While I appreciate the work the Cannabis Control Commission has done to provide a safe, profitable and equitable cannabis industry—there is still work to be done. When it comes to social consumption, the current regulations have fundamental flaws that prevent it from being a sustainable model. As someone who has a lot to gain from this license type, it is with a heavy heart that I say the CCC needs to address the current regulatory environment of the cannabis industry before issuing this license type.

A few of my current concerns include:

  • Selective interpretation of regulations, as well as selective enforcement by inspectors

  • Registered agent badging processes and fees

  • Security requirements

  • Overregulation pertaining to packaging, marketing & operational requirements

  • Testing requirements, especially where it intersects with on-site food infusion and consumption

These are some, definitely not all of the issues every Massachusetts cannabis licensee is struggling with. If you issue social consumption establishments without addressing these current issues, this license type will be unsustainable and unattainable for equity applicants.

The hospitality industry is one of the most difficult industries to operate in. Everything from staffing to the cost of goods create extremely low profit margins. The current regulations in this industry will add a barrier to this license type making it unsustainable to operate under.

Social consumption is not about cannabis; it is about providing a social environment for consumers. If the regulations don’t allow you to provide that type of environment, how do you expect these businesses to succeed and thrive?

Please consider my input as you continue to develop this new license. The Summit Lounge would be happy to provide any support, feedback and ideas to ensure fair and successful regulations.

Thank You, 

Kyle Moon