More things MJ with Jessica LeRoux - May 3, 2013
Ooops What I sent you was a first draft sent before I wrote my final version for testimony... here ya go. Hope you can use some of this, I dunno?
A potency limit on edibles will be an unfair boone to the blackmarket for edibles which is quite robust and does not require any testing, labeling, or any other oversight. Furthermore A-64 specifically allows sharing between adults of their cannabis including edibles, why is the legal industry being excluded from that aspect of the market? We already know how to make great products, we have clean safe facilities, we have good control over potency, and we are honestly struggling financially under 1284 and there are no improvements to our business licenses to be found in this bill. Home cooks may end up throwing their money in the trash based on their skills in the kitchen, what happens to the burnt batch of brownies in the home trash? is it eaten by Pets? Wildlife (do you wanna deal with a stoned skunk in your garage)? A naughty neighbor child who's lazy parent does not provide adequate supervision? please remove that portion of HB13-1317
Poison control packaging should only be an option for parents that need it, not a forced expense on people who do not have Kids. A person's right to possess a non-lethal legal substance in their purse, their car, or their home certainly superceeds the rights of a lazy parent of a child who steals. We have criminal codes to deal with juvenile thieves, lets remember who is the criminal here...
Perhaps a solution is to instead have adults sign a waiver printed on the receipt they take with them at the time of sale, saying that the purchaser accepts the legal responsibility to keep these products away from Minors, pets and any other party the state deems ineligible to access marijuana.
The state inexplicably plans to steal the private property of legal medical patients by transferring plants that legally belong to a patient into the retail custody of the medical center that merely was growing that plant for the patient in question. This is patently illegal and completely made up out of whole cloth with no legal precedent. This is not a legal option for stocking the coffers of the retail centers, the state needs to go back to the drawing board here.
another year of 70/30 vertical integration will be extremely unfair to rural medical businesses in good standing with the MMED as there is simply no warehouse space in these rural areas for expansion of grows to meet expanded needs to supply retail clients as well as the existing patient base. Also the industry desperately needs new faces, very few (shady) operators have the cash to expand and none of us smaller mom and pop owners want to be under their thumb to remain compliant as we would be exposed to the liability for any rules they break even if they are 5 to 8 hours away and we would be hard pressed to check up on the new partner's compliance efforts. Currently all MIPs are not required to be vertically integrated and there is no problem with ensuring compliance for these non-integrated businesses. Not one MIPs has ever been accused of diversion by the MMED or any other enforcement agency. Also want if the cap on an OPC falls short of the demand, how can that licensee meet the 70/30 without taking on a big alphabet soup cartel partner? Please read the 8 unpleasant truths about vertical integration here:https://www.facebook.com/notes/beth-gonnaget/8-truths-about-vertical-integration/508802002515503
Additionally if a new entrant can apply in january but cannot open for 10 months, they will be paying on a lease for 10 months with no income, crushing the dreams of many for small scale family owned businesses. These businesses have a much better chance of survival in all areas of the state if they are owned by persons who live in the community they serve so that people know and trust the owners. Locals often feel they are being used or burned by some absentee fat cat owner who does not care about the people who shop in the store they own from afar.
Additionally if a new entrant can apply in january but cannot open for 10 months, they will be paying on a lease for 10 months with no income, crushing the dreams of many for small scale family owned businesses. These businesses have a much better chance of survival in all areas of the state if they are owned by persons who live in the community they serve so that people know and trust the owners. Locals often feel they are being used or burned by some absentee fat cat owner who does not care about the people who shop in the store they own from afar.
There is neither the science nor supreme court (mcneely vs missouri) support for a 5 nanogram limit, nor invasive forced blood draws. Additionally the state of Colorado has had 2 years or more of nightmares with our state run lab from thousands of results being thrown out because of employee error, and our Top state toxicologist Cynthia Burbach was found to have lied to the state about her qualifications and credentials. Adding to the financial burden of our state labs without adequate
funding is only an incentive to the overburdened labs who are already 14 months behind in turn around time just on samples from our existing laws, to falsify results to ensure timely results for their friends in the courts. Please follow these links to some other timely info about testing facilities here and nationwide: https://www.facebook.com/notes/beth-gonnaget/letter-to-legislators-re-thc-duid-lab-testing/506449872750716
If we cannot fix these flaws I would strongly urge you to vote no on the entire Bill HB13-1317
Also re 13-1318 I know many in the blackmarket who cant wait to raise their prices by 20 to 25% as they can increase their profit when industry prices rise... Right now you can pay about the same price for marijuana from a MMC or a private grower (i dont know where the talk about cartels comes from the growers in my area outside nederland have been there happily serving the same client base for over two decades, we arent seeing new "gang type" activity where i live. the only cartel in CO is lobbyists backed MMIG and CBA , or as I call them the alphabet soup cartel). Furthermore these "blackmarket" growers far and away exceed the quality of the cannabis grown by big buggy denver warehouses from the cartel of lobbyist backed MMCs. Ive heard Rep Singer claim audaciously that because we have "skin in the game" industry members will support, fund election campaigns, and promote the passage of this bill to which I say HA HA HA no way on earth any of us will remotely do any such thing. In fact you can be certain that as you read this industry members are already actively campaigning against this bill to any patient or person we encounter.
We in the industry think a 12% combined tax is about right... 5% sales tax, and 7% excise tax which should generate between 3.5 and 20 million dollars based on the two extremes of potential sales Ive seen bandied about. If the MMED cant make that kind of money work for actual enforcement (which we've all been waiting to see since 2010) then they are the criminals, not the industry. We desperately need the MMED to clear all the bad apples (including those who served on the governors task force: two of whom have had repeated requests for MMED investigation of their 1284 crimes) from within the industry prior to opening the application process in October.
thanks for reading, I hope you can support these reasonable changes to the bills so that it provides equal and fair access to business owners in all districts that wish to participate in the new jobs and opportunities for Colorado.
Poison control packaging should only be an option for parents that need it, not a forced expense on people who do not have Kids. A person's right to possess a non-lethal legal substance in their purse, their car, or their home certainly superceeds the rights of a lazy parent of a child who steals. We have criminal codes to deal with juvenile thieves, lets remember who is the criminal here...
Perhaps a solution is to instead have adults sign a waiver printed on the receipt they take with them at the time of sale, saying that the purchaser accepts the legal responsibility to keep these products away from Minors, pets and any other party the state deems ineligible to access marijuana.
The state inexplicably plans to steal the private property of legal medical patients by transferring plants that legally belong to a patient into the retail custody of the medical center that merely was growing that plant for the patient in question. This is patently illegal and completely made up out of whole cloth with no legal precedent. This is not a legal option for stocking the coffers of the retail centers, the state needs to go back to the drawing board here.
another year of 70/30 vertical integration will be extremely unfair to rural medical businesses in good standing with the MMED as there is simply no warehouse space in these rural areas for expansion of grows to meet expanded needs to supply retail clients as well as the existing patient base. Also the industry desperately needs new faces, very few (shady) operators have the cash to expand and none of us smaller mom and pop owners want to be under their thumb to remain compliant as we would be exposed to the liability for any rules they break even if they are 5 to 8 hours away and we would be hard pressed to check up on the new partner's compliance efforts. Currently all MIPs are not required to be vertically integrated and there is no problem with ensuring compliance for these non-integrated businesses. Not one MIPs has ever been accused of diversion by the MMED or any other enforcement agency. Also want if the cap on an OPC falls short of the demand, how can that licensee meet the 70/30 without taking on a big alphabet soup cartel partner? Please read the 8 unpleasant truths about vertical integration here:https://www.facebook.com/notes/beth-gonnaget/8-truths-about-vertical-integration/508802002515503
Additionally if a new entrant can apply in january but cannot open for 10 months, they will be paying on a lease for 10 months with no income, crushing the dreams of many for small scale family owned businesses. These businesses have a much better chance of survival in all areas of the state if they are owned by persons who live in the community they serve so that people know and trust the owners. Locals often feel they are being used or burned by some absentee fat cat owner who does not care about the people who shop in the store they own from afar.
Additionally if a new entrant can apply in january but cannot open for 10 months, they will be paying on a lease for 10 months with no income, crushing the dreams of many for small scale family owned businesses. These businesses have a much better chance of survival in all areas of the state if they are owned by persons who live in the community they serve so that people know and trust the owners. Locals often feel they are being used or burned by some absentee fat cat owner who does not care about the people who shop in the store they own from afar.
There is neither the science nor supreme court (mcneely vs missouri) support for a 5 nanogram limit, nor invasive forced blood draws. Additionally the state of Colorado has had 2 years or more of nightmares with our state run lab from thousands of results being thrown out because of employee error, and our Top state toxicologist Cynthia Burbach was found to have lied to the state about her qualifications and credentials. Adding to the financial burden of our state labs without adequate
If we cannot fix these flaws I would strongly urge you to vote no on the entire Bill HB13-1317
Also re 13-1318 I know many in the blackmarket who cant wait to raise their prices by 20 to 25% as they can increase their profit when industry prices rise... Right now you can pay about the same price for marijuana from a MMC or a private grower (i dont know where the talk about cartels comes from the growers in my area outside nederland have been there happily serving the same client base for over two decades, we arent seeing new "gang type" activity where i live. the only cartel in CO is lobbyists backed MMIG and CBA , or as I call them the alphabet soup cartel). Furthermore these "blackmarket" growers far and away exceed the quality of the cannabis grown by big buggy denver warehouses from the cartel of lobbyist backed MMCs. Ive heard Rep Singer claim audaciously that because we have "skin in the game" industry members will support, fund election campaigns, and promote the passage of this bill to which I say HA HA HA no way on earth any of us will remotely do any such thing. In fact you can be certain that as you read this industry members are already actively campaigning against this bill to any patient or person we encounter.
We in the industry think a 12% combined tax is about right... 5% sales tax, and 7% excise tax which should generate between 3.5 and 20 million dollars based on the two extremes of potential sales Ive seen bandied about. If the MMED cant make that kind of money work for actual enforcement (which we've all been waiting to see since 2010) then they are the criminals, not the industry. We desperately need the MMED to clear all the bad apples (including those who served on the governors task force: two of whom have had repeated requests for MMED investigation of their 1284 crimes) from within the industry prior to opening the application process in October.
thanks for reading, I hope you can support these reasonable changes to the bills so that it provides equal and fair access to business owners in all districts that wish to participate in the new jobs and opportunities for Colorado.
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