Delivered to the Marijuana Regulatory Agency
February 12, 2020
Both the medical marijuana and adult-use cannabis programs were the result of citizen directed initiatives. First and foremost, those initiatives laid out personal freedoms and individual rights. The MRA has been given the responsibility of administering the Michigan Medical Marihuana Act, which contains all personal protections and no formal business outline; the legalization law, which outlines personal freedoms and citizen rights first then describes a supportive business system; and the MMFLA, which is an exclusively business regulatory program.
If all the MRA does is focus on the issuance of licenses to business you will have abdicated your greatest responsibility- ensuring those personal freedoms and citizen rights are not infringed upon. Fail in that role and you will have made real all the fears citizens have about being unable to trust government to run anything.
The MRA is the sole agency charges with the protection of approx. 300,000 medical consumers and 7 million current and potential adult-use consumers. The business licensing aspect of the MRA remains a secondary purpose; your prime directive is the administration and protection of the personal freedoms contained within those citizen-dictated laws.
When conflict exists between the rights of citizens and rules which create advantage for business, the rights of citizens must always prevail. Citizens rights supersede business advantage every time. EVERY TIME.
You cannot create rules which criminalize common behaviors just to provide protectionism for a particular license type. For example, your definition of a social use lounge is overly broad. Other speakers will detail the concerns citizens have regarding this overstep. Enacting these regulations will make accidental criminals out of everyday cannabis consumers, and that is the opposite of the mandate set forth by the passage of Prop. 1
We have similar concerns regarding the special event promoter’s license. I am hearing the MRA feels that Hash Bash and the Monroe Street Fairs need to acquire a special event promoter’s license in order for them to operate, but that would be a significant overreach. There is no admission charge NOR are there vendors selling cannabis at either event; therefore, they seem to not meet the requirements of the special event description. No MRA approval is needed for these events.
Make no mistake- patients and cannabis consumers are under attack in 2020 Michigan. Detroit’s chief of police called cannabis DOPE repeatedly in a recent interview. Brian Calley went on Michigan Public Radio recently and said all cannabis businesses in Michigan are committing federal money laundering schemes every time the make a bank deposit, and so are the ancillary industries who never touch a plant. And the Michigan Department of Health releases a series of videos portraying cannabis users as fat losers with no jobs or friends.
Remember, there is only one agency in Michigan charged with the protection of patients and adult-use cannabis consumers; that agency is the MRA.
Prop. 1 reduced penalties for violations of personal use laws. We made sharing cannabis and transfer without remuneration legal acts. The vote of the people sent a clear message to government: stop criminalizing casual cannabis behaviors. Get government out of our weed bags. Unless there is a threat to public health and safety, leave cannabis consumers alone.
Owner, Michigan Cannabis Business Development Group
NORML of Michigan, Board member