The importance of submitting public comments to the Cannabis Control Board in New York By – Phoenix at Cannabaceae LLC

I propose that the importance of submitting public comments to the Cannabis Control Board (CCB) in New York state and our community staying involved in the regulatory process as we end Cannabis prohibition together in New York state cannot be understated. I would assert that there have been few inflection points in the history of our country that are as impactful to individuals’ quality of life than the end of Cannabis prohibition and our community in New York stands on the forefront of the regulations that will impact the next chapter of a post Cannabis prohibition reality.

As the governing bodies shape how the current and future regulations will impact Cannabis patients, adult use consumers and the industry that forms to meet the needs of our community, we all have a chance to have our voices heard by submitting public comments directly to those individuals who are tasked with approving the regulations. This is a rare opportunity to contribute to the formation of the regulations that will influence how our society regulates Cannabis locally and eventually on a global scale.

Historically, the Cannabis community, other than the atrocities that were inflicted on individuals to enforce Cannabis prohibition, has self-regulated the supply chain that allowed individuals access to Cannabis. In some cases, this self-regulation was carried out successfully and encouraged collaborative communities to form, though, in other cases the illicit market inflicted harms on our community.

I believe the true opportunity now is to attempt to carry over the best of the morality that encouraged a symbiotic community to form in the illicit Cannabis supply chain into the regulated market. I believe this can be achieved if our community stays vigilant with communicating to those who create the regulations in New York allowing them a path to understand the needs of our community.

I would propose by voicing our needs consistently to our regulators, perhaps we can achieve a balance in a well-regulated Cannabis supply chain that preserves the liberties found in a self-regulated illicit Cannabis supply chain and that perhaps staying involved by submitting comments to the CCB allows our community to preserve our morals while ensuring that Cannabis can be safely supplied to individuals.

While no system nor individual is without fault, those who write and approve our regulations in the adult-use Cannabis industry in New York carry a heavy burden and truly need our support to ensure that their perspective stays grounded in reality in a space fraught with propaganda. Ensuring that we continue the conversation with our regulators through submitting public comments to the CCB will prove to be imperative to the formation of a free and fair supply chain in New York state.

This is one of the many reasons I formed Cannabaceae LLC and have perused the privilege of attaining a license in the NY adult-use Cannabis industry, to contribute to the formation of the regulations that govern the adult-use Cannabis industry in New York in an attempt to become a part of the solution as we end Cannabis prohibition together. I hope that those who read this will consider voicing their opinions to the CCB if you haven’t already.

There are a few considerations to keep in mind when compiling public comments to the CCB that help the regulators interpret and apply our comments to the regulatory process, I will include some of these recommendations below echoing the suggestions posted on the New York Office of Cannabis managements website;

·       More information can be found about how to submit a public comment to the Office of Cannabis management and the CCB @ https://cannabis.ny.gov/

While writing your comment: 

• Give your email or letter a title that makes it clear which program or Part you are commenting on. Sometimes multiple different proposals will be out for comment at the same time.

• Clearly state the specific section or subsection within the proposed regulations that you are commenting on. Try to be as specific as you can. Your citation should begin with the Part number of the regulations and include all letters or numbers that identify that particular subsection. An example of what a citation of a specific section of Part 116 might look like is: "§ 116.4(a)(2)(i)(b)"

  • You can address multiple sections in your comment. If you are addressing multiple sections, make sure it is clear what part of your comment pertains to each section.

  • If your comment is not tied to any specific section(s) of the proposed regulations, or you are not sure where it best fits, then you do not need to cite a specific section in your comment.

• If applicable, provide specific suggestions on the regulatory language and how you think it can be changed.

• When possible, justify your comment. This could be through data, your personal experience, factual information, scientific research, sound reasoning, expert opinions, or another way. If possible, provide links or references to the information that supports your comment.

• Include examples of how the proposed regulations would impact you, your community, or your business negatively or positively.

• If you disagree with a proposed action, suggest an alternative. Explain how your alternative might meet the same objective or be more effective. If you have information that supports your view, then you should include it. 

  
  

After writing your comment:

• Proofread your comment before submission to be sure it will be understood when it is reviewed.

• Do not submit the same comment more than once. Unless you receive an error message that indicates your email was not sent or another indication that your comment was not received, then you can assume the Office has received your comment. The Office receives many comments on proposed regulations and carefully reviewing all comments takes time.

• Continue to monitor the Office's website and any Cannabis Control Board meetings for additional movement of the proposed regulations on which you commented. The Office issues responses to all comments in the Assessment of Public Comment which summarizes the comments received. This assessment is issued after the comment period ends and the proposed regulations are finalized or revised. 

Comments on the proposed regulations can be submitted by email to: regulations@ocm.ny.gov or mailed to: New York State Office of Cannabis Management, P.O. Box 2071, Albany, NY 12220