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You heard that right: due to regulatory red tape, many if not all Bay Area cities, as well as cities throughout the rest of the Sunshine State, won’t be prepared to permit businesses when California Recreational Marijuana becomes legal in the state on the first of January.

There are a few reasons for the lag: some cities are likely dragging their feet on getting their own regulatory framework up and going, but the state also has not delivered its final regulations, which are expected sometime in November. Many localities are waiting for direction from state regulators before clarifying and finalizing their own regulations, which means that there will only be a few months’ time between when state regulations are finalized and when California Recreational Marijuana will be legal in the state.

Alex Traverso, a  spokesperson for the state’s Bureau of Medical Cannabis Regulation, suggested that although final regulations aren’t published the draft regulations that were released in April of this year should give cities enough to work off of. Some cities are taking that advice, moving forward with proposed ordinances that they expect to tweak later. If some of those cities are successful, they could end up on the forefront of the industry push while other cities scramble to set up regulatory systems.

Emeryville, for example, has requested proposals and plan to approve a single dispensary for both medical and recreational cannabis sales, and are expected to pick the lucky business in November, with the hope that the business will be able to open its doors in early January. Santa Cruz is also on the forefront, with a simple change expected to their ordinance that could speed things up: allowing 12 already approved medical marijuana dispensaries in the city to apply for licensing to also sell California Recreational Marijuana.

“There’s a substantial amount of work that has to be done,” said Sean Donahoe, a former board member of Oakland’s Cannabis Board and an industry consultant, “You can’t phone it in at the end of December.”