As you’re probably aware, the medical cannabis community is extremely upset with the legislature’s rush to force medical cannabis patients into the I-502 system.  This would effectively end the current medical cannabis system in the State of Washington.

We believe that the assumptions from the LCB and the Marijuana Work Group used in drafting these current bills are severely flawed.  As such, this will lead to unintended consequences that will dangerously impact the lives and health of patients.

One of the most critically incorrect assumptions was that the I-502 stores will be able to supply the medicinal needs of patients and eliminate the need for the current system of medical access points, collective gardens and home gardens.

The State Attorney General has recently concluded that cities and counties have the legal right to enact moratoriums and bans on I-502 businesses. With over 80 cities and counties already enforcing moratoriums banning these establishments, 85%-90% of the state will not be providing access to medication for patients. A court challenge to settle this issue could easily take two years or longer, leaving patients with no alternatives but to violate the state law or to purchase their medication from the black market.

The Liquor Control Board has already stated that several medications currently used by patients to treat serious medical conditions like cancer and seizure disorders will not be available in the recreational marijuana stores. Under the proposed legislation, patients will be forced to illegally manufacture their own medication or purchase it from those who are willing to violate the state law to provide it to them.

The current price of medication in Washington is approximately $180-$225 per ounce. We have recently seen the price of medication in Colorado rise to $500 an ounce with only a 15% excise tax. This is more than twice the price of medical cannabis here in Washington. With the new excise taxes on recreational cannabis in the I-502 stores at 35%-60% higher than those of Colorado, prices here could easily top $700 per ounce. That’s more than 3 times the price patients are currently paying for their medication. This will give patients no choice but to go back to the black market or go without medication.

Current survey data indicates that 45% of the medical cannabis patients in Washington live below the poverty line. Many of these patients rely on the generosity of collective gardens for free, or low cost, medications that will no longer be available under the I-502 system. The medicine these patients rely on is not covered by any health insurance and there is no provision in any of the new proposed legislation that would provide for these most vulnerable patients.

The recommendations made by the Liquor Control Board and Marijuana Work Group concern critical medical issues affecting a doctor’s practice of medicine, the amount of medication a patient is legally allowed to possess, and the number of plants a patient is allowed to grow for themselves. These were admittedly made without the consultation of a single medical professional. The only member of the Department of Health participating in this Work Group was Kristi Weeks, an attorney for the Department of Health.

The Work Group also recommended that the legal amount of medication for patients be reduced by 83% and reduce the number of flowering plants by 80%. Ms. Weeks testified before an LCB hearing in front of 600 patients and admitted that this decision was made “very unscientifically”. This overturns a 2008 recommendation that was made through a hearing process that considered scientific and medical studies, along with the testimony of numerous medical professionals.

Agency bureaucrats, attorneys and lobbyists should not be making medical decisions or interfering with the doctor/patient relationship. When the legislature follows these recommendations, without any apparent consideration for the health and welfare of patients, or the doctors that treat them, there should be little doubt why medical cannabis patients are angry with our elected officials.

We hope that you will reconsider this rush to legislate and have the compassion to put our medical concerns above your desire for increased tax revenues.

Cannabis Action Coalition

Contact us at:

Steve Sarich

John Novak

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