CASP evolution: Welcome new Board members

by Dominic Corva, Executive Director

It’s been a busy and volatile year since I founded the Center for the Study of Cannabis and Social Policy.  Our first Board consisted of myself, Dr. Sunil Aggarwal and Dr. Michelle Sexton.  Although Sunil has had to leave the Board to concentrate on just of few of the many important things he’s doing, including an upcoming NIH fellowship, he was instrumental in jump-starting CASP’s credibility and weaving his incredibly valuable network into ours.  We anticipate the day he can rejoin the organization, but his contributions continue to help our organization going forward.

Our first year was an improvisational performance to a certain extent.  We were open to following the research and policy paths that opened up to us on a daily basis, while relying primarily on volunteer energy and inter-organizational collaboration.  There were so many short-term projects related to informing the public and policymakers about how legal landscapes were developing.  Of all of these, the  Health Before Happy Hour campaign consumed the most time and energy for me personally.  Turns out the biggest short term policy intersection for legal cannabis was … medical cannabis policy. This was not something I anticipated coming in.

While we continue to work on the intersection of medical and cannabis policy, we are at last making substantive headway into legal cannabis policy and economic geography; chemotype mapping; and genetic geographies.  The chemotype mapping project is complementary to Dr. Sexton’s new role as co-owner and manager of Phytalab which just opened in Seattle.

As you may realize, my role as Executive Director supports my ongoing research into the political economy of cannabis agriculture, and this in turn has helped create a grounded network of allies/ethnographic subjects in Washington State.  From this emergent community, we have asked four amazing people to join the board and in conjunction with Michelle, this five member Board will take charge of fundraising and professionalization for the organization.  I am proud to call them my bosses!  In no particular order, please welcome:

Don Wirtschafter:  Don is a countercultural institution in and of himself, having participated in hemp and cannabis politics since there was any such thing.  He played a key role in the formation of GW Pharmaceuticals as a medical research company, pre-corporate global ambitions.  He has served on the board of national NORML, owned and operated Ohio’s pioneering Hemp Store, and practiced law up until recently, when he moved to Washington state to develop an I-502 compliant cannabis business.

Aaron Varney:  Aaron is co-owner of Dockside Cooperative, the first access point to earn Patient-Focused Certification from Americans for Safe Access.  He is an expert cultivator and now is navigating Dockside’s transition to 502 retail.  I first met Aaron through Dr. Sexton and we are both thrilled that he accepted a position on our Board.

Rachel Kurtz:  Rachel is a Seattle Drug Policy Activist and lawyer for Wykowski and Associates.  I first met Rachel while working on the King County Bar Association Drug Policy Project in 2003-2004, and hired her as CASP lawyer not long after I formed the organization.  She has extensive experience serving on nonprofit Boards and is the speaker coordinator for Seattle Hempfest.


Naz Victoria: Naz, a Pennsylvania transplant, is one of the first 50 producer/processors to get the go-ahead from the Washington State Liquor Control Board.  In addition to being an experienced businessman, he is well-versed in the history of cannabis markets and supports outdoor, sungrown cannabis for environmental and economic reasons.  His facility is located in Okanagon, Washington, where the first efforts to create a national Sun Growers association are emerging.

I could say so much more about these people, and undoubtedly will in the future.  They represent the conscientious wing of cannabis industry and activism, are committed to reality-based policy, and have a clearly defined commitment to cannabis and social policy.  They have become my friends and confidants, and I am honored indeed to bring them on board!

Berlin recap


(Dr. Horst-Dietrich-Elvers, Dr. Dominic Corva; Dr. Jan-Henrik Friedrichs; Dr. D.J. Korff)

by Dr. Dominic Corva, Executive Director

I can hardly believe it was a few hours short of a week ago I left Seattle for Berlin to participate in a conference on the topic of Cannabis Legalization at Berlin’s Friedrichshain-Kreuzberg Museum.  The public event was very well attended and featured a terrific keynote address from Dr. Jan-Henrik Friedrichs, cultural historian, on conditions of urban development and refugee politics that catalyzed the need for a public discussion on a proposal being developed by the District mayor, Monika Herman, to establish a legal cannabis market in the  Goerlitzer Park.

As with cannabis politics in modernity, the social issue had very little to do with cannabis itself and mostly to do with the concentration of African refugees selling cannabis in the “Gurly” as the park is known locally.  This issue seems to have developed over the last three years:  drug dealing by young black men in the park has been common in the past, but some families and children’s social workers are reporting themselves “squeezed out” of the park due to aggressive marketing.

This is apparently the consequence of dealers being “pushed out” of other Berlin parks in recent years, rather than simply a matter of more consumption or dealing.  While accurate numbers are probably hard to come by, one panelist suggested that 90% of the dealing in the park is in cannabis flowers. Additionally, property values around the park seem to be rising rapidly with the intensification of gentrification.  Mayor Herman’s plan, in principle, seemed intended to regulate and formalize local cannabis markets in order to (a) prevent the rise of “hard drug” markets; (b) make things easier on the local refugee population as they are increasingly stigmatized as drug dealers and (c) address local concerns about especially children’s safety in the park.

The Mayor’s point person on this initiative is Dr. Elvers, pictured above on the left.  Dr. Elvers was the only person in the audience really prepared to discuss technical issues associated with implementation rather than political issues including whether or not refugee issues could be addressed through legalization.  Dr. Elvers has his job cut out for him, and both the Dutch professor Dr. Korff (above, far right) and myself had limited relevant comparative context for addressing his technical questions.  Dr. Korff’s perspective is from the Dutch coffeeshop system, which is a decrim policy for retail and on-site consumption; and mine of course is from Seattle/the U.S. where 20 years of medical cannabis politics have created more fertile grounds for addressing legalization.  I did, however, get a chance to talk to him one-on-one where I urged him to start with community meetings, to get reticent locals — the ones who are complaining about the Gurly Park situation — to feel like they have a voice and to have a place where they can voice their fears.  His reaction was fascinating:  apparently that’s what he wanted to push for first but the mayor’s office decided other things were more important.

At any rate, the conference was a terrific success — attended by the Berlin Mayor and a Federal politician who has long advocated cannabis lilberalization, Hans-Christian Ströbele.  Museum director Martin Duspohl was amused the next day to find out how the right wing newspaper covered the conference: by announcing that it cost $5000 Euros, highlighting my participation and that of noted leftist and national politician Hans-Christian Ströbele.  It is my honor to have such a person as second bill in a complaint about wasted taxpayer dollars!  The conference was covered with more nuance and discussion here and here.


*****The flyer for the conference, in German******

“Legalize It!?” Conference Flyer PDF: Legalize_It_final_20-5-14_web




Reading the retail lottery landscape 1.0

by Dominic Corva, Executive Director

As producers and processors move slowly through the licensing process, we have at last another milestone in the development of Legal Cannabis Landscapes in Washington State. Thursday the WSLCB held its retail application lottery and released that information to the public — with the exception of Longview, where a lawsuit prevented the release of those results.

What do we know about the results?  Although news reports and maps are currently showing 254 lottery “winners” in 75 jurisdictions where applicants exceeded available retail spots, it’s very important to realize a few key things about what we don’t know.

1.  There were an additional 47 jurisdictions in which 80 retail slots were up for grabs.  That’s a huge chunk of the 122 jurisdictions and 334 total retail slots for which we have no information.

2.  Many businesses played the lottery game by submitting multiple applications.  Each application counted as a separate lottery entry.  Some businesses managed to snag more than one retail slot, although they cannot have more than one retail location.  So the first cut is the one where businesses with multiple winners decide which one they want to open, and the other locations are removed from the ranking list.  This has already happened in Federal Way, according to Federal Way applicant Stefani Quane.  Her ranking (she was at 6 and needed to get to three) moved up one because two of the top 3 in Federal Way were from the same business.  Undoubtedly, this is happening in other jurisdictions.

3.  The retail “winners” win only the right to have their applications reviewed further.  The WSLCB will be examining financial backgrounds, background checks, and other criteria.  If and when a “winner” is eliminated, the other applicants will move up in the rankings.

4.  There is clearly a clustering issue, with Ballard and Sodo hosting about half of the locations., This has significant policy implications for two reasons.  One, because the WSLCB has made certain claims around consumer access in support of arguments about the 502 system being capable of providing safe access in lieu of medical access points. The other is that access to legal cannabis should have a significant effect on consumer choices (medical or not) about whether to stick with their convenient — often delivered — black market access or see if the legal retail stores can meet their preferences.

5.  The flip side of the clustering issue is what parts of Seattle have no retail locations.  The University District, Capitol Hill, and South Seattle are all significant clusters of current cannabis consumption, and there are no retail stores in these areas.

6.  Lawsuits.  No way to tell how many or for what right now other than WSLCB filing errors or the perception thereof.

The Center is working on mapping the retail landscape throughout the state with a special focus on Seattle and King County.  Until then, this is the location of my favorite map so far which not only locates the “winners” but identifies their lottery ranking:

Geographies of Legal Cannabis Real Estate in Washington: An interview with Tom Gordon

by Dominic Corva, Executive Director

Last week I had a chance to sit down with I-5 Real Estate owner Tom Gordon.  Tom is one of the few cannabis real estate stakeholders that I see regularly at activist, as opposed to just industry, organizational events and meetings.  Our half-hour conversation addressed where and why real estate markets are such an important factor to understand structural challenges to policy implementation.

He also blew my mind when I asked his sense of what percentage of producer applicants will end up meeting the various challenges to their 502 permit applications.  From his perspective, he estimates that between 5 and 15% will make it through the process.  That’s a much lower percentage than I expected.  It does however match up with Becky Smith of the WSLCB’s information from a couple weeks ago, that while 10 producers have made it all the way through, 40 more would be finished but for their own unfinished real estate business.

Local Implementation Update and Trend Report



March 26th 2014

Background:  Washington voters approved Initiative 502 in November 2012 setting up a legal system to tax and regulate marijuana for recreational use.  Cities and counties were given authority to pass additional zoning regulations.  Cities have final authority granting licensing for marijuana businesses, following state approval.

Project:  The Center collected data on the 75 most populous cities in Washington to examine how local governments have handled I-502 implementation legislatively.  Over the last several months the Center has tracked the shifting implementation strategies of those cities.


ZONED:  City council passed legislation zoning areas where marijuana businesses could apply or updated the Municipal Code recognizing recreational marijuana.

MORATORIUM: City council passed legislation putting a hold on accepting marijuana licenses.  These ranged from 6-12 months.

BANNED:  City passes legislation banning marijuana businesses until the drug is approved federally or officials have threatened to ban.

NO ACTION:  Cities took no legislative action, will treat marijuana businesses like any other business or simply expands medical marijuana laws to recreational.  

# of cities %*
Population Impacted **
ZONED 33 44% 2,293,070
MORATORIUM 29 39% 1,094,924
BANNED 5 7% 223,416
NO ACTION 8 11% 244,469
Total 75 3,855,879


From January 1, 2014 to March 25, 2014 seventeen (17) cities have altered their policies related to I-502.  The legislative movements are:

Moratorium to Zone 10
Moratorium to Ban 2
No Action to Zone 2
No Action to Moratorium 2
Zone to Moratorium 1 

Key Findings:

  • More cities that originally passed moratoria have opted to zone rather than ban.
  • Only 2 additional bans have been implemented after the Attorney General’s opinion affirming local bans.
  • Moratoria have dropped in 11 cities.


  City County Est. Population Status
1 Seattle King 634,535 ZONED
2 Spokane Spokane 209,525 ZONED
3 Tacoma Pierce 202,010 ZONED (Interim)
4 Vancouver Clark 165,489 ZONED
5 Bellevue King 126,439 ZONED
6 Kent King 122,999 MORATORIUM
7 Everett Snohomish 104,655 ZONED (interim)
8 Renton King 95,448 MORATORIUM
9 Yakima Yakima 93,101 BANNED
10 Federal Way King 91,933 MORATORIUM
11 Spokane Valley Spokane 90,641 ZONED (Interim)
12 Bellingham Whatcom 82,234 ZONED
13 Kennewick Benton 75,971 MORATORIUM
14 Auburn King/Pierce 73,505 MORATORIUM
15 Pasco Franklin 65,398 MORATORIUM
16 Marysville Snohomish 62,402 MORATORIUM
17 Lakewood Pierce 58,852 BANNED
18 Redmond King 56,561 MORATORIUM
19 Shoreline King 54,352 NO ACTION
20 Richland Benton 51,440 MORATORIUM
21 Kirkland King 50,697 ZONED (interim)
22 Burien King 49,410 ZONED
23 Sammamish King 49,069 MORATORIUM
24 Olympia Thurston 47,698 ZONED (Interim)
25 Lacey Thurston 43,860 NO ACTION
26 Edmonds Snohomish 40,400 MORATORIUM
27 Bremerton Kitsap 39,251 NO ACTION
28 Puyallup Pierce 38,147 MORATORIUM
29 Longview Cowlitz 36,458 ZONED
30 Lynnwood Snohomish 36,275 ZONED (Interim)
31 Bothell King/Sno 34,651 NO ACTION
32 Issaquah King 32,633 MORATORIUM
33 Wenatchee Chelan 32,562 BANNED
34 Mount Vernon Skagit 32,287 ZONED
35 Walla Walla Walla Walla 31,864 ZONED (Interim)
36 University Place Pierce 31,562 MORATORIUM
37 Pullman Whitman 31,359 ZONED
38 Des Moines King 30,449 ZONED
39 Lake Stevens Snohomish 29,104 ZONED
40 SeaTac King 27,667 BANNED
41 Maple Valley King 24,171 ZONED
42 Mercer Island King 23,661 NO ACTION
43 Bainbridge Island Kitsap 23,263 MORATORIUM
44 Oak Harbor Island 22,260 ZONED
45 Kenmore King 21,280 MORATORIUM
46 Moses Lake Grant 21,182 ZONED
47 Mukilteo Snohomish 20,605 ZONED
48 Camas Clark 20,490 MORATORIUM
49 Mountlake Terrace Snohomish 20,198 ZONED
50 Tukwila King 19,611 ZONED
51 Port Angeles Clallam 19,056 NO ACTION
52 Mill Creek Snohomish 18,671 MORATORIUM
53 Ellensburg Kittitas 18,348 ZONED
54 Arlington Snohomish 18,317 ZONED
55 Covington King 18,298 ZONED (Interim)
56 Tumwater Thurston 18,102 ZONED
57 Battle Ground Clark 18,044 NO ACTION
58 Bonney Lake Pierce 17,964 MORATORIUM
59 Monroe Snohomish 17,503 ZONED (Interim)
60 Aberdeen Grays Harbor 16,529 ZONED (Interim)
61 Centralia Lewis 16,505 MORATORIUM
62 Sunnyside Yakima 16,054 MORATORIUM
63 Anacortes Skagit 15,928 MORATORIUM
64 Washougal Clark 14,584 MORATORIUM
65 East Wenatchee Douglas 13,439 MORATORIUM
66 Lake Forest Park King 12,972 MORATORIUM
67 West Richland Benton 12,663 MORATORIUM
68 Lynden Whatcom 12,605 MORATORIUM
69 Ferndale Whatcom 11,998 MORATORIUM
70 Kelso Cowlitz 11,832 ZONED
71 Port Orchard Kitsap 11,680 ZONED (Interim)
72 Snoqualmie King 11,594 NO ACTION
73 Enumclaw King/Pierce 11,327 MORATORIUM
74 Woodinville King 11,234 BANNED
75 Cheney Spokane 11,018 ZONED (interim)

For access to our interactive map and links to legislative documents please visit:

Please email Dr. Dominic Corva, Executive Director, with any questions.

* Percentages are rounded to the nearest whole number.

**Population data is from the estimated 2012 population from the US Census Bureau

Partner Project Okanagon Cannabis Association


by Dominic Corva

The Center for the Study of Cannabis and Social Policy is pleased to announce a partner research project with the Okanagon Cannabis Association.  This project will focus on educating policymakers and the public about the environmental impacts of Legal Cannabis Policy, with a special focus on identifying the geography of indoor and outdoor Legal Cannabis businesses throughout the state.

The project should be especially relevant to the Liquor Control Board as it reviews applications; environmental stakeholders throughout the state since Legal Cannabis Policy is, from this perspective, a new layer of environmental policy; Legal Cannabis industry stakeholders as they decide how they will grow and where, at the lowest production cost; and the Department of Agriculture as it should, in the future, be increasingly involved in regulating Cannabis Agriculture.

The term “environmental impacts” will include but not be limited to analysis of solar, water, and soil issues related to Legal Cannabis Agriculture; and will be cross-studied with socioeconomic data to produce information on the relationship between environmental policy and other forms of social policy such as inequality, gender and race.

The Future of Legalization in Washington After Attorney General’s Opinion Affirming Local Pot Bans

By: Drew Matthews

On January 16, Washington State Attorney General Bob Ferguson released his long-awaited opinion regarding local government’s right to ban marijuana businesses, saying, “Although Initiative 502 establishes a licensing and regulatory system for marijuana producers, processors, and retailers in Washington State, it includes no clear indication that it was intended to preempt local authority to regulate such businesses. We therefore conclude that I-502 left in place the normal powers of local governments to regulate within their jurisdictions.” 

In short, Ferguson has affirmed that local governments have the authority to ban marijuana businesses.

Alison Holcomb, the mastermind of I-502 and current criminal justice Director at ACLU Washington responded to the legal opinion, saying, “Despite the initiative clearly and specifically giving the Liquor Control Board the task of licensing enough stores in each county to meet the demand for marijuana legally, it appears legal businesses may be forced to sue to be allowed to compete with the black market.”

The Liquor Control Board (LCB), which requested the Attorney General’s opinion, was disappointed by the decision, saying, “We’re not yet sure how this opinion will change the implementation of the initiative. If some local governments impose bans it will impact public safety by allowing the current illicit market to continue. It will also reduce the state’s expectations for revenue generated from the legal system we are putting in place.”


Lower tax revenue

Tax revenues will be considerably less than projected (currently $1.9 billion over 5 years) if municipalities are allowed to enact local moratoriums or bans.  Tax revenues are to be dispersed to the Department of Social and Health Services, the state health care fund, research programs on drug abuse prevention and the impacts of legalization, and public education programs.

Expansive dry areas in rural and southern Washington

Large parts of southern and eastern Washington have passed moratoriums pausing implementation of I-502 (See Local Implementation map).  All of these moratoriums expire in 2014, at which point city councils and county commissioners must either extend the moratoriums, ban licensing altogether, zone specifically for marijuana businesses, or treat marijuana licenses like any other business.  If the current moratoriums stay in place or are replaced by bans, a person in Vancouver, Washington would have to travel over 100 miles to Lewis County to purchase legal cannabis.

 Black markets will continue to thrive

In order to compete with the black market there must be significant local buy-in.  Cities and counties that choose to ban or place excessive zoning restrictions on marijuana businesses are leaving their local black market unchecked.  If the current number of moratoriums remain in place, nearly 50% of Washington’s most populous cities will have unchallenged black markets.  As the LCB stated, an unchecked illicit market threatens public safety.


The State must give local governments incentive to implement the law.  A bipartisan bill recently introduced in the state legislature would punish local governments that ban marijuana business by withholding their share of disbursements from the state liquor-license account. I offer several other policy options that will smooth implementation of I-502.

Disperse marijuana tax revenues directly to governments that implement

Under the current law, local governments will only receive marijuana tax revenues in the form of grants to fund local community agencies dedicated to reducing youth marijuana use.  Alternatively, lawmakers could give local governments more flexibility with these funds, thereby increasing the financial incentive to fully implement I-502.  A portion of the revenue collected from marijuana taxes should be allocated to local governments that comply with I-502 with no strings attached.  This money could be used as needed by local governments in order to fund other local initiatives, including law enforcement, education and transportation.

Allow home delivery

People in rural parts of the state may not have the resources to drive dozens of miles for a good that should be available locally.  A solution is to allow retail stores to deliver to customer’s homes.  This practice is not currently allowed because the law states that transactions must take place in the licensed establishment.  Black market dealers deliver, further incentivizes consumers to remain in the illicit market.

Remove the cap on the number of retail stores

The cap on retail licenses has already challenged the viability of success for I-502 by creating retail monopolies in certain parts of the state.  The combination of widespread moratoriums and caps on retail stores per county will create “green oases”, where only one or two retail stores are available for dozens if not hundreds of miles.

Demand is likely higher than what the state expected when they wrote retail regulations.  A recent RAND study has projected that marijuana consumption in Washington is likely twice as much as the figure used by state regulators.  More stores should be allowed, especially in areas surrounding dry zones.  Hopefully this will lessen the transportation burden for consumers, and create greater competition for pricing, variety, and quality of product.

Increase local pressure

If the State will not force cities and counties to implement I-502, that pressure must come from citizens.  People living in areas with moratoriums or bans who wish to see the law fully implemented must engage their local governments.  Council members and commissioners have enormous power in regulating and implementing the law, and the success or failure of I-502 is contingent on local cooperation.  Elected officials may be wary of the political backlash if they implement I-502, and need to know that constituents support implementation of a legal marijuana

CASP public comments to the Working Group

Dear Washington State Liquor Control Board (WSLCB):          November 12, 2013

Please accept the following as my contribution to public comments concerning the DRAFT recommendations to the legislature of the Medical Marijuana Working Group, constituted by representatives from the WSLCB, the Department of Revenue (DOR), and the Department of Health (DOH), and presented by the WSLCB on October 21, 2013.  Our Washington State nonprofit organization, the Center for the Study of Cannabis and Social Policy, is dedicated to the promotion of reality-based cannabis policies, significantly made possible by the legalization of cannabis under Initiative 502.  We are concerned that these draft recommendations are based more in the production of political theater than in the realities of currently existing patient access, on the one hand, and a lack of understanding about Washington State cannabis markets on the other.  We do, however, understand that the legislature is responding to an absence of regulatory frameworks around medical cannabis, and that there is a compelling need to do so.  We propose a simple, pragmatic two-step solution that would minimize cost to taxpayers and preserve patient access, while hardly affecting potential state revenues.  We propose that the legislature re-visit a bill they already approved, but was then substantively section-vetoed by the governor’s office in 2011.  And we propose that the state establish a scientific commission to study the realities of patient access to medical cannabis.

The perceived lack of medical cannabis regulation in Washington State is the direct result of former Governor Christine Gregoire’s 2011 section veto of key regulatory provisions in 69.51A.045.    This is illustrated by the following quote from a Seattle Times article dated April 29, 2011:

The governor took a combative posture in vetoing most of the bill, which would have licensed and regulated medical-marijuana dispensaries and grow operations, and given patients broader arrest protection … Recent letters from U.S. Attorneys around the country, including Washington’s two federal prosecutors, threatening more aggressive action against medical-marijuana programs and state workers enforcing them show a “changed landscape,” she said.

That logic, that explicit regulation might expose state employees to Federal sanction, was rendered irrelevant by U.S. Attorney General Cole’s Department of Justice memo dated August 29, 2013 (“Cole 2”).  As you well know, the Cole 2 memo explicitly states that as long as state regulatory frameworks meet eight conditions, the Federal government will allow state experiments with legalization.  There is nothing in the memo that bans state medical marijuana regulation, as long as those regulations are clear, substantive, and do not violate any of the eight conditions.  Washington State’s absence of clear regulatory frameworks for medical marijuana is clearly the result of Gregoire’s 2011 section vetoes.  If they had not happened, Washington State would be in Colorado’s position and there would be no need for your Working Group’s recommendations.

Therefore, the WSLCB should recommend a clear course of action to the legislature: establish a commission to study what was vetoed; modify to reflect the current landscape; and re-submit for executive signature, given the opening created by Cole 2.

I-502 said nothing about medical cannabis when the voters passed it, and it is a perversion of public initiative process for the state legislature, or any public stakeholder including the governor’s office and the Department of Revenue, to use it to dismantle the existing system of patient access.  The WSLCB was tasked with creating a workable legal system, not with destroying what is currently working for patient access.  Despite the Working Groups’ affirmation that patients now have a safe, legal alternative, the fact is that not one license has been given and the legal market will have a lot of kinks to work out.  No honest stakeholder disputes this.  It should be given space to work out these kinks without dragging patient access into the messiness.  Any recommendation that is based on asserting the viability of something that does not exist, has never been attempted, and/or is an optimistic projection, cannot be put forward to the legislature as a foundation for sound policy making.

As a result: each recommendation for which I-502 does not explicitly have a correlating mandate (designated “N/A” in the recommendations) should be withdrawn or amended to explicitly mandate credible, substantive studies of their potential effects on patients and patient access before being revisited at a later date.  That includes Section 2, establishing a mandatory patient registry; 3, regulations regarding health care professionals; and 4, eliminate collective gardens.  Sections 1, 5, and 6 are also problematic, but given the severity of our organization’s recommendation to completely eliminate sections 2, 3, and 4, our comments will focus on these.

We assert that the central problem with the Working Group’s competence and credibility is that it is comprised of state agencies with zero expertise in medical cannabis.  The secondary problems are corollaries: the DOR has no expertise in how licit cannabis markets are affected by quasi-licit medical markets and illicit markets that constitute the main competitors to legal cannabis markets; the DOH has no expertise in medical cannabis; and the LCB’s recently acquired field of knowledge is bounded by licit market regulation, not medical market regulation.  The problem is a profound lack of formal knowledge, in the absence of which politics rule the day over common sense.

The DOR bases its precise calculations on BOTEC’s work.  The acronym “BOTEC” stands for “back of the envelope calculations.”  Another acronym would have worked: SWAG, for scientific wild-ass guess.  The state’s contractor’s numbers are precise but accuracy is not the same as precision, and those numbers are suspect for a number of reasons but most of all, because BOTEC was mostly an outsider organization with no prior knowledge of Washington cannabis markets, much less knowledge about medical cannabis markets in the big picture, which includes a much more significant illicit cannabis markets.  BOTEC did come to the realization that medical markets are a tiny fraction of the overall cannabis markets in Washington State, relative to illicit markets.  This should mean, to you and to the legislature, that the State does not have a substantive economic interest in protecting licit state cannabis markets from quasi-licit medical cannabis markets, and that expensive and detailed regulation can only cost more than it would save.  It makes no economic sense, and the only way to explain this obsession is that it makes political capital for certain stakeholders.

This applies especially to the recommendation to ban “collective gardens,” which are quite different from commercial store fronts.  The true collective garden can be identified by its social relations of production: I recommend that the Working Group read a book titled “Dying to Get High, Dr. Wendy Chapkiss’ outstanding ethnography of the Wo/man’s Alliance for Medical Marijuana.  Patient participation in collective gardens can be important as cannabis consumption when it comes to palliative care.  Banning collective gardens hurts existing and potential patient access, and is therefore a human rights violation.  There is no reason, at all, to believe that collective gardens pose any sort of threat to the as-yet nonexistent legal cannabis market, because they are completely different from commercial relations of production.  If the recommendation to ban collective gardens comes from an urge to ban storefront dispensaries, an alternative might be to ban commercial storefronts.  But if these are illegal anyway, as US attorney Jenny Durkan has asserted, then the recommendation should be to enforce existing law.  There is no need to create additional regulatory work for which taxpayers would foot the bill without receiving any social benefits.  This can only be about political theater, and I urge you to refrain from participating.

The DOH, in these recommendations, would be tasked with overseeing doctor-patient relationships in a manner that deviates substantially from current regulations regarding the sanctity of the doctor-patient relationship.  We note that if the legislature is concerned about fraudulent authorizations, then that is an indication that the DOH is not doing its job or that what is being recommended is a system of physician oversight for which there is no licit precedent.  If the DOH is not currently applying the regulatory power it does have, how can it be expected to fulfill the oversight function for which it has been recommended?  Also of great concern is the absence of any expertise regarding medical cannabis in the DOH itself – how is a licit bureaucracy going to know more about a field of medicine that is only now opening up, where research is advancing at a rapid rate, and due to its illicit nature the people who know the most about cannabis as an herbal medicine are the patients themselves; and brave health care workers who have treated patients despite legal risks, because public health should not be sacrificed to political policy.

Finally, the LCB itself.  With the exception of the secrecy around this working group, the LCB has done a terrific job seeking and listening to public input.  You have learned much in the last 11 months or so, but your learning has been focused – rightly – on how to write rules for implementing a legal cannabis market.  This is what the voters asked you to do, and it is not your fault that the legislature made this extra request.  It seems to me that most of you in the LCB have wanted nothing to do with this, and this is reflected by the dominance of one stakeholder in these recommendations: the Department of Revenue.  But I ask you to take what you have learned in the last eleven months and tell the legislature the truth:  all recommendations that might impact a single patient’s access to cannabis as medicine have to be studied at length before being made, much less implemented.  The problematic assumption that many medical cannabis patients game the system has to be compared with the totally unproblematic assumption that many real patients exist and they should not be sacrificed on the twin altars of politics and revenue.  The WSLCB knows this because it has met those patients, heard from them, at public hearings across the state.  That is only half the picture, however: the WSLCB has not, to my knowledge, made a systematic effort to listen to clinical researchers, physicians, and naturopaths regarding the study of cannabis as medicine.  And why would you?  You were not tasked or funded to do so.

In sum, the Center for the Study of Cannabis and Social Policy asserts that Washington State public health policy would be adversely affected by the Working Group’s recommendations as they now stand.  Further, there is no social benefit that would be created that could offset the fact that these recommendations constitute bad public health policy.  Legal cannabis policy must be constructed to work with with other kinds of social policy, grounded in reality rather than fearful political maneuvering.  It should not create new problems that are totally unnecessary and counterproductive in the long term.  We are committed to making legal cannabis work, and convinced that Washington State has a historic opportunity to serve as a positive model for making things work instead of making a mess that other states and even nations would look at as a cautionary tale.

Thank you                                                                                                              Dr. Dominic Corva                                                                                          Executive Director                                                                                                Center for the Study of Cannabis and Social Policy


Partner Project Vashon Island/VIMEA

CASP is overjoyed to announce our first sustainable livelihood partner project, a collaboration with Shango Los’ nonprofit Vashon Island Marijuana Entrepreneurs Alliance!  While the Grange has yet to find a dedicated partner, VIMEA is a perfect example of our organization’s Action-Research mission to find, support and collaborate with people who are already organizing their communities to inform the public and assist with adjusting to the post-502 landscape.

The following press release describes well how VIMEA and CASP missions and activities will complement each other going forward.

#Press Release#
VIMEA and CASP form Partnership for implementation of legal marijuana in rural Washington State
October 18th, 2014
Vashon Island, WA

The Vashon Island Marijuana Entrepreneurs Alliance (VIMEA) announces their partnership with The Center for the Study of Cannabis and Social Policy (CASP).  Through this partnership, VIMEA will gain access to valuable research, marijuana industry contacts and increased funding opportunities.  The Center will gain first person reports, photos and legal marijuana implementation best practices from VIMEA.  Both groups see this partnership as an opportunity to widen the understanding of marijuana as business and medicine.

Director of VIMEA, Shango Los stated, “We are very pleased to to form this partnership with CASP.  Securing access to the center’s vast resources and marijuana policy experience will assist greatly to VIMEA’s success in rural Washington.  CASP Director Dominic Corva’s in-depth understanding of global approaches to marijuana production and policy supports our goal to implement I-502 in a way that sustains our local food security while also integrating legal marijuana farming in ways consistent with our local community standards.”
CASP Director, Dominic Corva stated, “VIMEA is providing the local community organizing necessary to implement legal marijuana in a way that respects the Vashon Island community.  We are grateful to secure first hand accounts to inform our policy research.  We look forward to studying the VIMEA approach and help disseminate their best practices throughout the country.”

The Vashon Island Marijuana Entrepreneurs Alliance is an advocacy and trade organization for legal marijuana produced on Vashon Island in Washington State.  VIMEA’s goals are to create an environment welcoming to local marijuana farmers, assist marijuana entrepreneurs in setting up their businesses, re-establish the Vashon Island marijuana brand and encourage successful farmers to reinvest a portion of their profits into the community.  VIMEA is based on Vashon Island, and
The Center for the Study of Cannabis and Social Policy (CASP) produces, reviews, and disseminates objective research and opinions about the relationship between Cannabis Policy and other forms of Social Policy including but not limited to environmental policy, agricultural policy, public health policy, policing, foreign policy, and economic policy.  CASP is based in Seattle,
For more information, contact Shango Los at 206-595-9006 or


Shango Los
Vashon Island Marijuana Entrepreneurs Alliance coming soon
PO Box 2327
Vashon Island, WA 98070