Heads Up! DEA Wants to Hear from You on Marijuana Rescheduling by July 22

In case you haven’t heard, the Drug Enforcement Administration (DEA) needs to listen to from you on marijuana rescheduling. Particularly, DEA invitations your feedback on its discover of proposed rulemaking (NPRM) to maneuver each marijuana and marijuana extract from schedule I to schedule III of the federal Managed Substances Act (CSA). The remark submission deadline is July 22, 2024.

How does the remark deadline work?

There are literally two deadlines at play right here. All feedback have to be submitted electronically or postmarked on or earlier than 11:59 ET on July 22, 2024. All listening to requests have to be postmarked on or earlier than July 20, 2024. It’s at all times attainable that DEA will lengthen the deadlines previous July 20 and 22, nevertheless it appears unlikely at this level. Due to this fact, you need to adjust to the July 22 deadline to make it into the executive report, and the July 20 deadline if you happen to’d additionally prefer to request a listening to.

How does one submit a remark?

DOJ encourages submission of feedback by the Federal eRulemaking Portal. Right here is the hyperlink. The interface offers the power to kind brief feedback instantly into the remark discipline on the net web page, or to connect a file for lengthier feedback.

I’m busy. Is there a pattern remark I can adapt?

Sure, there are a few good ones on-line. Marijuana Coverage Challenge, for instance, has a template letter you’ll be able to edit and submit right here. NORML has one right here. I’m positive there are others floating round as nicely.

What number of feedback has DEA obtained?

Seems to be like over 30,000 on the time of this writing. I initially guessed we’d see over 100,000 feedback. I’ll have overshot, however I nonetheless anticipate a major uptick by subsequent Monday.

What if I need to advocate that marijuana be re-scheduled and never de-scheduled?

You possibly can actually do this! I and lots of others have at all times argued that de- and never re-scheduling is the right coverage alternative for marijuana. I anticipate that a good portion of the feedback will advocate for de-scheduling. Others will make arguments on the opposite finish of the coverage spectrum: marijuana ought to stay in schedule I with fentanyl and different harmful medicine.

Wherever you land on the subject, it’s price mentioning that DEA suggested at web page 13 of the NPRM that it “has not but made a dedication as to its views of the suitable schedule for marijuana.” That is but one more reason the remark alternative is so compelling.

Anything to think about within the feedback?

Sure. I defined in a previous put up that the NPRM contemplates “marijuana-specific controls” at schedule III, though the NPRM itself doesn’t define what these particular controls could also be. It’s unclear (no less than to me) whether or not DOJ and DEA may proceed with rescheduling marijuana prior to those controls being in place. Thus, I imagine it’s truthful sport to touch upon what controls ought to appear to be, and/or whether or not we even want them within the first place.

What’s the following step?

As soon as feedback are in, the Administrative Process Act requires that rulemaking be performed on the report after the chance for a listening to in entrance of an administrative regulation choose. It appears possible that the DEA administrator will grant a request for a listening to on this case, with the intention to assessment factual proof and professional opinion on the NPRM.

Past that, you’ll be able to anticipate this course of to be ongoing on the time of the November elections. No matter occurs in these elections may additionally have an effect on the result. However that may be a matter for one more day.

Till then, please preserve subsequent week’s deadlines in place, and take a look at the next posts on marijuana and schedule III: