Our Model Comments on State Regulations

We draft model comments and letters on proposed cannabis regulations for submission to the appropriate regulatory agencies. These comments are based on the best scientific evidence and information available. Comments are downloadable and available as models for public use.

Model Comments on Bureau of Cannabis Control Proposed Regulations (2018)

While the regulations contain certain important advances such as requiring specialization of cannabis businesses, BCC’s proposed regulations as written continue to permit excessive licensing and density of retailers, gives no consideration to equity in licensing, falls short of effectively constraining harmful marketing practices, and proposes excessive daily sales limits, all of which impose unnecessary risks on the health of Californians. To avoid irreversible harm, an immediate cap should be placed on the number of retailers licensed by the state and provisions for greater equity instituted under the proposed regulations.

Model Comments on CDFA Proposed Regulations (2018)

CDFA’s proposed regulations, while creating important systems for managing legalized cannabis cultivation, fail to address two key threats to public health and equity, specifically the growing proportion of cannabis sold in the United States that is high potency, with greater risks of negative health impacts such as addiction and psychoses, and the need to assure that individuals who have been historically victimized by the war on drugs have the opportunity to participate in the legalized cannabis industry. We also recommend a greater distance from institutions serving children and youth.

Model Comments on California Department of Public Health Proposed Regulations (2018)

Proposed regulations incorporate some positive steps which we strongly support. However, incorporating lessons learned from tobacco, alcohol and pharmaceutical regulation is urgently necessary to protect public health. These measures include prohibiting manufactured cannabis products that are of particularly high risk or used to attract children and youth, including high potency flower and conceNtrates, flavored products, cannabis beverages, and infused pre-rolls and commissioning a full evaluation of potential public health impact of these products free of conflicts of interest; reinstating the essential protection of children from accidental ingestion through child RESISTANT packaging; asSuring legible prominent warnings, COMPLIANT WITH LEGAL REQUIREMENTS, that inform consumers on products and marketing; preventing abusive industry marketing tactics particularly those that attract children and youth; and more actively preventing conflicts of interest. adoption of these measures will help to assure a better balance between the benefits of legalization anD the reduction of harms from an expanded market.

Opposition Letter to AB 3157 (5/9/2018)

This is a sample model letter that can be sent to legislators to forcibly oppose AB 3157 (Lackey/Bonta) a bill that would slash taxes on cannabis products that were recently legalized by the voters of California.


Model Comments on CDFA Proposed Regulations (2018)

A model letter that serves as a way to express serious concerns regarding the strength of public health protections specified in the proposed regulatory framework for medical cannabis, as well as to raise key issues we believe should be included in upcoming regulations for recreational adult use marijuana licensing. 

Comments on Proposed California State Medical Cannabis Manufacturing Regulations (2017)

A model letter to express serious concerns regarding the strength of public health protections specified in the proposed regulatory framework for medical cannabis manufacturing, as well as to raise key issues we believe should be included in upcoming regulations for recreational adult use.