DCPC submits comments to DC Attorney General on proposed medical cannabis regulations

The District of Columbia Patients' Cooperative (DCPC), a non-profit, medical cannabis organization registered in the District of Columbia, has submitted comments to the Office of the DC Attorney General addressing numerous issues on proposed regulations announced 45 days ago.  

DCPC's comments may be viewed online at http://www.dcpatients.org/DCPC_comments.pdf along with the comments of cannabis advocacy groups including Americans for Safe Access and the Marijuana Policy Project.  

DCPC's is the only major local organization addressing practical changes needed to implement a sustainable non-profit model.  

Major issues addressed in DCPC's comments include:

1. DCPC wants the DOH, not ABRA, to regulate medical cannabis.
2. Best applicants should be selected for licenses and not on a first-come, first-served basis.
3. Proposed regulations do not distinguish between for profit, non-profit, and individual applicants.
4. Best practices used in other states are being ignored pertaining to caregivers.
5. Police potentially have access to patient records at dispensaries.
6. Numerous free speech issues for physicians and unfair dispensary signage restrictions.
7. Non-refundable application fees 50 times greater than DC's pharmacy license.
8. Fees 4 to 6 six times greater than annual licenses of analogous ABRA approved alcohol establishments.
9. The number of cultivation centers is arbitrarily limited when anticipated demand is not known.
10. Officials are not required to wear protective clothing during inspection of cultivation centers.
11. Proposed regulations do not address re-imbursement for medicine provided to low income patients.

The District Council has until October 19, 2010 to approve or disapprove the proposed regulations.  DCPC urges the District Council to thoroughly review the comments submitted by stakeholder organizations and reject portions of the proposed rules that are inconsistent with best practices found in other states with implemented medical cannabis programs.

The District of Columbia Patients' Cooperative intends to construct and operate a dispensary in the Adams Morgan neighborhood and will be seeking a license for both a dispensary and cultivation center in the coming months.  In order to ensure the viability and sustainability of the District's medical cannabis program, it is imperative that significant changes are made to the proposed regulations.