That WSLCB Thing

I thought I had touched on this previously. I’d intended to simply copy and paste the letter below with a brief lead in. I looked around at the categories and discovered I hadn’t mentioned the ‘I-502 Washington State Liquor Control Board thing.

So much for the brief lead in.

Cannabis has gone to hell here in Washington State. I don’t know how else to write it. Both the new recreational thing and the medicinal cannabis are looking to be a mess.

As the letter reads, the WSLCB had a job mandated by the legislature. The WSLCB’s answer to the issue was to simply gut the current law, basically making 69.51a impotent. A limp noodle.

If you go here and click on the word “recommendations” in the first sentence you can read them yourself.

You’ll note the Board’s whole foundation is retail sales. With a store on the corner, why would anyone even need a medicinal ‘waiver?’ Yeah, I know that’s screwed up on sooo many levels.

And a butt-load of municipalities in the state currently have moratoria on cultivation, processing and sales. Some, have even passed bans.

And the state’s attorney general has offered the opinion those are perfectly legal.

Not only am I alarmed at this turn of events, but I’m embarrassed. The world is watching Colorado and Washington and Washington keeps tripping on its shoe laces.

Currently, there are about 1/2 dozen bills in the state legislature related to ‘the issue.’ Everything from revamping 69.51a to not allowing municipalities to opt out, to making cannabis cultivation not qualifying for agricultural tax breaks.

A mess.

So, with that written I offer a pasted copy of a letter I sent to my legislators.

Good Day,…

As you are aware, during the 2013 2nd Legislative Special Session the Washington State Liquor Control Board was appropriated 66 mil. dollars in 3ESSB 5034 S Sec. 141. Those appropriations were contingent upon the proviso found in 141(2). That is, to make recommendations to the Legislature regarding the interaction of medical marijuana regulations and the provisions of Initiative Measure No. 502.

In my opinion this proviso’s intention was to both mollify Federal concerns and to maximize the return on recreational cannabis taxation.

This could be easily accomplished by simply enforcing the current law under 69.51a. 69.51a.085 (Collective Gardens) was never intended to accommodate storefront sales. The fact the governor vetoed any section of E2SSB-5073 (revisions to 69.51a) having to do with a retail market is plainly prima facie evidence to my assertion. As well as the fact a previous loophole in the law concerning designated providers was closed.

There is no “grey area.” Any operation in the “business” of providing cannabis to individuals with a medicinal recommendation is an illegal operation.

With that written, once again I will reiterate, simply enforcing the current law would meet the expectations of the legislature.
Unfortunately, the WSLCB was given eight areas to address. And address those they certainly have. By all appearances the Boards answer to mollification and taxation is the gutting of 69.51a.

I will ‘speak’ to those items of particular interest to myself: a disabled military veteran, dependent upon cannabis administered as an adjunct to pharmaceutical medication.

Item 2 (Authorizing requirements…). Why (after 16 years with a system that’s worked just fine) would the suggestion of a registry come up? From what I’ve read the written recommendations (on tamper resistant paper) have been adequate. I’m afraid a registry requirement would be an undue hardship on cannabis approved patients. Obviously, it would be they who would bear the cost. Not to mention more paperwork to fiddle with. Why fix what isn’t broken creating undue burdens?

Item 3 (Regulations regarding…). It’s more than obvious when physicians set up shop in a tent (at a festival) with the intention of making some quick money writing cannabis recommendations something’s wrong. I’m quite confident this isn’t what Washington’s citizens had in mind with I-692. I haven’t a clue why the medical profession doesn’t address this type of behavior. Most other professional groups would. There is a place for “cannabis specialists” however.

To not allow reputable clinics specializing in cannabis is a real issue. As I mentioned above I’m a vet. I depend upon the V.A. for my health care. My primary care physician is aware of my cannabis administration, and approves. He, however, is prohibited from writing me a recommendation himself. Where does that leave me?

Tighten up the regulations, if you must, but please don’t restrict the health care professional’s practice. That would not only be horribly detrimental for me, but every other vet out there in a similar circumstance.

Item 5 (Possession amounts). The effort here, obviously, is to minimize diversion from personal use to other markets. I’ve no doubt a three ounce limit would meet that goal, because three ounces isn’t a sufficient amount for many patients’ personal use. Many individuals render down the ‘foliage’ extracting the volatile organic compounds for use in tinctures, topicals, and foodstuffs. I would recommend reducing the current 24 ounce limit by half (to twelve) and monitoring the result.

Something to note? If the “grey-market” no longer existed (through regulation, or otherwise) the only market left to divert to would be the black. That market falls under the authority of law enforcement. Black-market cannabis is illegal, regardless of one’s paperwork.

Plant count doesn’t necessarily mean material on hand. I can’t support myself with six plants. I ‘run’ nine or ten plants and harvest (net) an average of an ounce a month. I administer an average of an ounce a month.

When I starting growing, my goal was to be self sufficient for the least possible cost. I use only fluorescent lighting (as you might find in a shop), materials and supplies that can be had at any home improvement store. The impact on my monthly expenses is nil.

With six plants I would be forced to go with HID lighting. I haven’t the resources to buy or maintain such a system. I doubt it would be safe to install in my old home. No, that’s not an option.

In closing:
The WLCB is under the impression their recommendations will force “patients” into the recreational market. I’m of the impression that could happen with some, but many (if not most) will simply keep plugging along as they have. That could well create a whole new class of criminal. I don’t find that productive on any level.

The unscrupulous entrepreneurs operating under the guise of “designated provider” previously and now “collective garden” are what Jenny Durkan was referring to when she stated Washington’s medical marijuana system was not tenable.

Not me.
I would ask you give that some consideration.


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