Phase 2 Relocation Request Instructions

On March 8, 2019, the City Council instructed DCR to implement a policy that would allow a Phase 2 applicant that has not received Temporary Approval to relocate its business premises one time if it can demonstrate it faces extenuating circumstances at its current business premises.  DCR considers extenuating circumstances to mean that an applicant has lost the ability to continue its application at its current business premises, including due to some adverse action by a landlord, such as reneging on a lease agreement or restricting an applicant’s access to or control over the business premises.  Extenuating circumstances do not include an applicant’s preference to move to a more desirable business premises or an applicant’s evaluation that its current business premises is too costly to take through the licensing process.

An eligible applicant that wants to relocate its business premises must submit a Relocation Request Form (PDF iconavailable here) to DCR’s office no later than 4:00 p.m. on Wednesday, May 15, 2019.  DCR will not approve a relocation request submitted after May 15, 2019, for any reason.   

Before submitting a relocation request, an applicant must consider the following information:

  1. It is an applicant’s sole responsibility to propose a business premises that complies with the City’s zoning and sensitive use distance restrictions. DCR may not be able to review submissions before the May 15, 2019, deadline, and if it later determines that an applicant has not proposed a compliant location, the applicant will not have an opportunity to propose a different business premises.
    An applicant that relocates its business premises through this process will receive the lowest priority for inspections relative to applicants that did not relocate their business premises.
  2. The City Council is considering a policy to require a Phase 2 applicant that has not received Temporary Approval to report substantial progress on the build out of its business premises by June 1, 2019, and to complete its build out by December 31, 2019.  An applicant that cannot meet either deadline will have its application deemed abandoned. DCR will provide more guidance on what substantial progress means.
  3. Due to current state law, a Phase 2 applicant will not be eligible for a provisional state license at a new business premises, which means that the applicant will have to obtain a state annual license to legally operate at that business premises.  DCR cannot provide an estimate of when an applicant might be able to obtain a state annual license.

An applicant can direct questions about the relocation request process to  All emails must include the applicant’s name and application number - DCR will not respond to emails without this information.  DCR will not confirm whether a location meets zoning and sensitive use distance restrictions before an applicant submits a request form.