May 22, 2020

VIA ELECTRONIC SUBMISSION—REGULATIONS.GOV

Re: Comments from LA NORML Regarding DEA Proposed Rule “Controls to Enhance the

Cultivation of Marijuana for Research in the United States”

 

[RIN 1117-AB54/Docket No. DEA-506]

 

We write as the LA Chapter of the National Organization for the Reform of Marijuana Laws (LA NORML). LA NORML respectfully submits its comments on the Drug Enforcement Administration’s (DEA) notice of proposed rulemaking (NPRM), entitled “Controls to Enhance the Cultivation of Marihauna for Research in the United States,” issued in the Federal Register on March 23, 2020 at 85 FR 16292. LA NORML appreciates the opportunity to submit these comments. Should the DEA have any questions or wish to discuss any of the information discussed below, please do not hesitate to contact us. One of the oldest NORML chapters in the country, LA NORML was founded in 1973 and is a regional chapter of the National Organization for the Reform of Marijuana Laws. NORML’s mission is to repeal the prohibition of cannabis at the local, state and federal level by educating those in our community about cannabis and hemp and their potential medical and industrial uses. The DEA’s proposed rulemaking would require licensed cannabis cultivators to transfer title and physical possession of their total crops to the DEA within four months of harvest, and require the DEA to exercise the “exclusive right” of importing, exporting, wholesale trading, and maintaining stocks of cannabis. The DEA has clarified that these new rules have been promulgated to bring the licensing framework for the cultivation of cannabis for medical research into compliance with U.S. treaty obligations under the United Nations Single Convention on Narcotic Drugs of 1961, 18 U.S.T. 1407 (Single Convention). The NPRM also expresses the DEA’s intention to promote the advancement of cannabis research, explaining: “DEA believes that these changes will enhance and improve research with marihuana and facilitate research that could result in the development of marihuana-based medicines approved by the Food and Drug Administration (FDA).” Comment from LA NORML for the Public Record [RIN 1117–AB54/Docket No. DEA–506] …

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