Michigan's CRA Comments on the Proposed Federal Rule Rescheduling Marijuana

Published 2 days ago Legislation & Policy Updates
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The Michigan Cannabis Regulatory Agency (CRA) has submitted an extensive comment on the proposed federal rule for rescheduling cannabis. This comment, available in full on the CRA website, addresses key issues related to the proposed rescheduling from Schedule I to Schedule III. The CRA's submission aims to inform the Drug Enforcement Administration (DEA) and other federal agencies about Michigan's Medical Marijuana Program and provide critical considerations for rescheduling cannabis.

Key Points of the CRA's Comment

The CRA's comment is twofold: it provides detailed information and statistics about Michigan's Medical Marijuana Program, and it outlines a comprehensive list of considerations for federal agencies when determining whether and how to reschedule cannabis.

Michigan's Medical Marijuana Program

Michigan's program began in 2008 following a voter-approved initiative. The program has grown significantly, peaking in 2018 with nearly 300,000 registered patients and over 40,000 caregivers. Despite the legalization of adult-use cannabis in 2018, many patients continue to value the medical marijuana registry. As of the end of Fiscal Year 2023, there were 129,099 qualifying patients and 11,554 primary caregivers.

Considerations for Rescheduling

The CRA highlights several areas that require clear guidance and robust coordination from federal agencies to ensure a smooth transition if cannabis is rescheduled to Schedule III. These areas include:

  1. Requirements Applicable to Schedule III Drugs: Federal guidelines must clarify how existing Schedule III requirements will apply to cannabis, considering that over 35 states have established medical marijuana programs and 24 states have adult-use programs.

  2. Banking and Taxation: Rescheduling cannabis could enable businesses to access banking services and benefit from standard tax deductions and exemptions. Clear federal guidance is essential to address these changes.

  3. Bankruptcy Protection: Allowing cannabis businesses to seek bankruptcy protection could provide crucial financial relief and restructuring opportunities. Guidance from the U.S. Trustee Program is necessary.

  4. Packaging, Labeling, and Advertising: Standardized federal guidelines could streamline compliance and enhance consumer safety. Agencies like the FDA should issue clear directives.

  5. Product Safety Standards: Uniform safety standards would ensure consistent quality across states, protecting consumers. The FDA should oversee these regulations.

  6. Transportation and Interstate Commerce: Legal interstate commerce of cannabis products would require detailed federal guidelines, considering the diverse state regulations currently in place.

  7. Research: Rescheduling could expand research opportunities using state-regulated products, necessitating clear federal research protocols.

  8. Federal Enforcement: Rescheduling should prompt new enforcement priorities, potentially modeled after the Cole Memo, to ensure stability for state-regulated markets.

  9. Federal Regulatory Agencies: Agencies such as the DEA and FDA should have defined roles in regulating cannabis post-rescheduling, with states retaining authority over specific aspects like licensing and distribution.

CRA's Stance and Offer of Expertise

Brian Hanna, the Executive Director of the CRA, emphasized the significant investment and effort by Michigan's licensees, caregivers, patients, and advocates in developing a leading cannabis industry. He stressed that rescheduling must be accompanied by comprehensive federal guidance to be effective. Hanna also expressed the CRA's readiness to testify at the federal level to share Michigan's progress in creating a robust regulatory framework.


The CRA's submission underscores the importance of a coordinated, whole-of-government approach to rescheduling cannabis. Without clear and comprehensive federal guidance, the rescheduling could potentially disrupt existing state programs. The CRA urges the DEA and other federal agencies to act responsibly and seize this historic opportunity to reshape cannabis regulation in the United States.

Tyrone Township Enacts 180-Day Moratorium on Medical Cannabis Facilities

Published 5 days ago Legislation & Policy Updates
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Tyrone Township has enacted a temporary moratorium on medical cannabis facilities, halting all development, permitting, and operations for a period of 180 days. The Board of Trustees approved this resolution to allow time for a thorough review and potential revision of the township's current ordinance concerning medical cannabis.

Reviewing Ordinance for Compliance

The Board has tasked the Planning Commission with evaluating the township's existing regulations, focusing particularly on minimum parcel sizes and suitable locations for such facilities. This review aims to ensure compliance with Michigan's Medical Marijuana Act while avoiding exclusionary zoning practices that could limit where these facilities can be established.

The resolution acknowledges that there have been several inquiries about medical cannabis regulation within the township. Consequently, the township believes it is in its best interest to re-examine the Medical Marijuana Act along with associated rules, regulations, case law, attorney general opinions, and other relevant information.

Public Input and Supervisor's Comments

During the board meeting, Supervisor Mike Cunningham emphasized the importance of revisiting the current ordinance. He noted that there have been public comments and discussions indicating the need for a comprehensive review. "We do have an ordinance in place, but we want to make sure it's up-to-date and aligns with the latest legal and community standards," Cunningham stated.

The decision to impose the moratorium reflects the township's commitment to carefully consider all aspects of medical cannabis regulation, ensuring that any future development is conducted in a manner that benefits the community while adhering to legal requirements.

Next Steps for Tyrone Township

The Planning Commission's review will involve a detailed analysis of current zoning laws and how they apply to medical cannabis facilities. The goal is to create a balanced approach that accommodates medical cannabis operations without imposing unreasonable restrictions or creating conflicts with existing land uses.


Tyrone Township's 180-day moratorium on medical cannabis facilities represents a proactive step towards thoughtful regulation. By re-evaluating the township's ordinance and considering public input, the Board of Trustees aims to develop a framework that supports both the community's needs and the legal landscape surrounding medical cannabis.

Kalamazoo County Revises Employee Drug Testing Policy

Published 6 days ago Legislation & Policy Updates
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The Kalamazoo County Board of Commissioners has unanimously approved revisions to its employee drug testing policy, introducing new provisions regarding legal substances. This decision was made during the board's meeting on Tuesday, July 16th.

Previously, the county's drug-free workplace policy stipulated strict disciplinary actions for employees testing positive for drugs or alcohol. These measures could range from disciplinary action "up to and including discharge for a first offense" to other corrective actions, depending on individual circumstances.

The updated policy now provides the county with the discretion to decide whether an employee should face disciplinary action for testing positive for legal drugs or alcohol. Despite this change, the county maintains a zero-tolerance stance on illegal drugs, according to county spokesperson Taylor Koopman.

A significant modification in the policy is the replacement of the term "will" with "may" concerning potential disciplinary actions. This change grants the county greater flexibility in handling cases involving legal substances.

The agenda packet did not provide a specific reason for the policy revision, and Koopman did not immediately respond to inquiries regarding the motivation behind this change.

Additionally, the board voted to eliminate a policy related to medical marijuana, aligning the county's regulations with state laws.

Coldwater Mayor Proposes Ban on Cannabis Grow Facilities in Industrial Zones

Published 1 week ago Legislation & Policy Updates
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Coldwater Mayor Tom Kramer is advocating for the cessation of cannabis grow facilities within the city's D-2 heavy industry zones.

In August of last year, the Coldwater Planning Commission approved a motion initiated by Kramer to begin phasing out special use permits for cannabis grow operations in the industrial park. Despite this approval, no further action has been taken since.

During a Planning Commission meeting on Monday, Kramer suggested that with Amanda O'Boyle succeeding the retiring Meghan Angell as City Attorney, there is now an opportunity to advance this initiative.

Kramer acknowledged that market conditions might ultimately influence the future of these grow facilities.

Notably, retail cannabis operations in the city would remain unaffected by this proposed change.

Following further discussions, the Planning Commission members reached a consensus in support of Kramer's proposal.

City Manager Keith Baker mentioned that a draft of the proposed changes could be prepared for review at the next Planning Commission meeting.

Senator Gary Peters Proposes DOOBIE Act to Modernize Federal Hiring Practices

Published 1 week ago Legislation & Policy Updates
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Senator Gary Peters, a Democrat from Michigan, has introduced a new bill aimed at preventing federal agencies from using past cannabis use as a factor in employment and security clearance decisions. The bill, known as the Dismantling Outdated Obstacles and Barriers to Individual Employment (DOOBIE) Act, represents a significant effort to modernize federal employment practices in light of evolving cannabis laws.

Senator Peters submitted the DOOBIE Act last week, marking the latest legislative push to ensure that prior cannabis consumption does not negatively impact an individual's eligibility for federal employment. This initiative reflects growing recognition of the need to align federal employment policies with the broader legalization trends seen across many states.

The DOOBIE Act specifies that federal agencies covered by the legislation "may not base a suitability determination with respect to an individual solely on the past use of marijuana by the individual." Additionally, the White House Office of Personnel Management (OPM) would be required to adopt and enforce this policy.

Furthermore, the bill stipulates that "the head of a Federal agency may not base a determination that a covered person is ineligible for a security clearance solely on the past use of marijuana by the covered person." This provision aims to prevent prior cannabis use from being a barrier to obtaining the necessary credentials for federal employment.

Under the proposed legislation, federal agencies would also be prohibited from using past cannabis use as a reason to deny a personal identity verification credential. This credential is essential for federal employees to access various facilities and information, making this an important aspect of the DOOBIE Act.

The Director of National Intelligence (DNI) would be tasked with updating regulations to align with the new cannabis policies and assist other federal agencies in implementing these changes. Notably, the DNI has previously stated that it is not the current policy of the federal government to deny security clearances based solely on past cannabis use, acknowledging that such practices can hinder recruitment efforts, especially as cannabis legalization becomes more widespread.

Senator Peters' legislation parallels a bipartisan House bill introduced last year, which aimed to provide employment protections and prevent security clearance denials for past and current cannabis use. However, an amendment in committee narrowed the scope of that bill to address only past consumption.

The DOOBIE Act is part of a broader movement to modernize federal employment and security clearance policies, ensuring they reflect contemporary attitudes towards cannabis use and support the recruitment and retention of qualified individuals in the federal workforce.

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Voice Your Support: DEA Public Comment Period on Cannabis Legalization

Published 2 weeks ago Legislation & Policy Updates
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The DEA is currently accepting public comments for two more weeks regarding cannabis legalization. Despite an estimated 70% of American voters supporting the legalization of cannabis for recreational use by individuals 21 and older, the DEA has received only 27,000 comments, far from a representative sample of public opinion.

Why Your Voice Matters

Cannabis Legalization and Rescheduling

This is a critical time to support the legalization and rescheduling of cannabis. A greater number of public comments are needed to accurately reflect the public's interest in this issue.

Economic Impacts

Legalizing and regulating cannabis can create jobs, generate tax revenue, and stimulate economic growth.

Criminal Justice Reform

Legalization can reduce incarceration rates for non-violent drug offenses and help expunge records for past cannabis-related convictions. This would save government resources and focus on more serious issues such as drug trafficking, while also restoring individual freedoms.

Medical Benefits

Many patients rely on cannabis for medical treatments. Rescheduling can enhance research opportunities and improve accessibility. Cannabis contains a variety of natural cannabinoids with medical potential beyond THC and CBD, including some that are non-psychoactive.

Public Health and Safety

Regulation ensures product safety and quality, protecting consumers from harmful substances and impurities. This can lead to a better understanding of the long-term effects of cannabis use.

Preventing Harmful Practices

Advocate for safer production practices. While some safety measures are in place, such as child-proof packaging and lab test results on labels, there is no framework to prevent harmful practices similar to those seen in the tobacco and alcohol industries.

  • Tobacco: Cigarette manufacturers add over 600 chemicals to tobacco to "improve the experience," making cigarettes more harmful and addictive. Similar practices could affect cannabis if preventative measures are not implemented.
  • Alcohol: Alcohol products often lack nutrition labels and fail to disclose adverse health effects. This issue could also affect cannabis products, including flower and edibles.

Additional Advocacy Opportunities


Advocate for the legalization and decriminalization of other substances, such as psychedelics, which have been unfairly demonized and criminalized. Some psychedelics, like psilocybin mushrooms, could be legal for recreational use, while others, like LSD, MDMA, mescaline, and ibogaine, have significant medicinal value.

Tobacco and Alcohol Regulations

Advocate for stricter regulations on cigarettes, such as child-proof packaging, lab test results, and limits on additives. Similarly, push for alcohol products to improve transparency and safety measures.

Consistent Regulations Across Substances

Advocate for consistent regulations across all substances. Flavored cannabis and tobacco products are often targeted for appealing to children, yet similar marketing tactics are prevalent in alcohol products. Consistent standards can address these inconsistencies. Currently, products like SunnyD vodka and Voltron beer are available on shelves, while clove cigarettes and flavored vapes are banned.

Participate in the DEA's public comment period, contact your representatives and congresspeople, and encourage others to do the same. Act now to ensure your voice is heard before the deadline! Please share this information.

Important Links

Need help figuring out what to say? Use these customizable boilerplates to effectively voice your support.

Submit this template to the DEA comment form to express your support for cannabis rescheduling. Replace [Your Name] with your own name to ensure your voice is heard in this important discussion.

To Whom It May Concern,

I am writing to express my strong support for the rescheduling of cannabis. This policy change is essential for several key reasons:

- Economic Benefits: Legalization and regulation of cannabis can drive job creation, generate tax revenue, and stimulate economic growth.

- Criminal Justice Reform: Reducing incarceration rates for non-violent drug offenses and expunging past cannabis-related convictions will save government resources and restore individual freedoms.

- Medical Benefits: Many patients depend on cannabis for medical treatments. Rescheduling will enhance research opportunities and accessibility, helping unlock the therapeutic potential of various cannabinoids beyond THC and CBD, including non-psychoactive compounds.

- Public Health and Safety: Regulatory measures ensure product safety and quality, protecting consumers from harmful substances and impurities, and promoting a better understanding of the long-term effects of cannabis use.

- Preventing Harmful Practices: A robust regulatory framework can prevent harmful practices seen in other industries, such as the addition of harmful chemicals in tobacco or the lack of transparency in alcohol products.

Furthermore, I advocate for the consistent regulation of all substances, ensuring fair and uniform standards across cannabis, tobacco, and alcohol products. This approach will address market inconsistencies and promote fairness.

With overwhelming public support for cannabis legalization, it is crucial that our voices are heard in this process. Thank you for considering my perspective.

[Your Name]

Use this template to convey your support for rescheduling cannabis to your representatives. Make sure to personalize it by changing [Recipient's Name], [Your Name], [Your Address], [City, State, ZIP Code], and [Email Address] with your own information.

Dear [Recipient's Name],

I am writing to express my strong support for the rescheduling of cannabis. As a concerned citizen, I believe this change is crucial for several important reasons:

- Economic Benefits: Legalizing and regulating cannabis will create jobs, generate tax revenue, and stimulate economic growth. This can provide much-needed financial support to our communities.

- Criminal Justice Reform: Legalization will reduce incarceration rates for non-violent drug offenses and help expunge records for past cannabis-related convictions. This will save government resources and allow law enforcement to focus on more serious issues, while also restoring the freedoms of many individuals.

- Medical Benefits: Many patients rely on cannabis for medical treatments. Rescheduling will improve research opportunities and accessibility, allowing for the exploration of the therapeutic potential of various cannabinoids beyond THC and CBD, including non-psychoactive compounds.

- Public Health and Safety: Regulation ensures product safety and quality, protecting consumers from harmful substances and impurities. This can lead to a better understanding of the long-term effects of cannabis use and promote responsible consumption.

- Preventing Harmful Practices: Implementing a robust regulatory framework will prevent harmful practices seen in other industries, such as the addition of harmful chemicals in tobacco or the lack of transparency in alcohol products.

Additionally, I urge you to consider advocating for the consistent regulation of all substances, ensuring that the same standards are applied to cannabis, tobacco, and alcohol products. This will address inconsistencies and promote fairness in the market.

This is a pivotal moment for cannabis policy, and public support is overwhelmingly in favor of legalization. I hope that my voice, along with the voices of many others, will be heard and considered in this decision-making process.

Thank you for your attention to this important issue.

[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]