mess for applicants pretty much a day after. small and many are outdated, and many local jurisdictions decided to set up their own step-by-step licensing processes, which in many cases ensured that many operators never get temporary licenses (e.g., Step 3 applicants in Los Angeles.
For each applicant who was lucky enough to acquire a state temporary license in 2018, the state is seeking to ease some of the fears that most of these interim applications will end in the next few months and that the temporary authorization procedure is unclear. The new California Senate Bill (SB-67) would restore outdated temporary licenses and fill the gaps in temporary licensing systems by mid-2020. This would give operators who received the temporary license in 2018 effectively to operate and not sit and wait for annual licenses.
In some backgrounds, I recently wrote a temporary licensing scheme designed to act as a band support, given that temporary licenses expired by the end of 2018 and that annual applications were extremely time-consuming for review. Reporting: If an operator who once held a temporary license filed an annual application, provided proof of compliance with CEQA and paid the fee, a government agency could grant a one-year temporary license. However, there is no problem with the temporary authorization system.
The first question about temporary licenses is that they can only be granted by the end of 2019. This actually resulted in a time limit of about one year compared to the temporary licenses. The secondary problem is that government agencies have in practice not given instructions on how to obtain them. The rules do not mention the regulations, and only the California Food and Agriculture Department (or " CDFA ") published instructions to obtain them. This guide makes it look like it is given CDFA with complete discretion after the applicant submits the required annual forms. This is problematic because there is no clear timetable or revision process. In other words, a full annual application could be submitted by the operator, and CDFA could take part in it months before the provision of the provisional information.
SB-67 may correct some of these problems. The main rule of the SB-67 is that when an applicant submits his / her annual license application, his / her provisional licenses will remain valid – even if those licenses have expired earlier. These extended temporary licenses would only remain valid after the issue or refusal of the annual license, the granting of the provisional license, the rejection or rejection of the application or the end of 2019, whichever is the earlier.
This is obligatory to disassemble, but essentially it means that if the applicants' dossiers are before the expiry of the provisional license, the applicants will still have temporary approval until the provisional license is granted. This will help eliminate the ambiguity associated with the temporary licensing process, but still does not change the fact that annual deliveries should be made as soon as possible.
Another important part of the SB-67 is that if it passes, it will first extend the deadlines by 1 July 2020. This will give the Agencies more time to grant temporary licenses by 2019. be a six-month window where licensees with no reservations lose their extended temporary licenses. This year, there may be just another bill on the table to deal with the same problem.
The SB-67 will ultimately benefit only a few operators and may indicate that government agencies are still so confused about applications that they are unable to handle on time. We are sure to keep our readers informed of updates to the SB-67 or temporary license.