Public Hearing on Legalizing Home Grows (HB 1614)
There have been many attempts to legalize the personal cultivation of cannabis in Washington state, and unfortunately none have advanced over the last decade because home grows have been unfairly viewed as a low priority.
Legalizing home grows is literally the first thing listed in PURP’s long term goals, so yeah, we think it’s a priority. Some believe that this our year and that this bill could finally go all the way, but we need you to let the powers that be know that you support this bill! This will only take 3 minutes.
How to Take Action
Go to https://app.leg.wa.gov/csi/House. Select "Regulated Substances & Gaming" from the Committee dropdown menu, then "02/02/2023 8:00am" from the Meetings dropdown menu.
Click on "HB 1614 Home cultivation of cannabis," then click the link that says, "I would like my position noted for the legislative record."
On the next page, make sure you select "PRO" as your position. Complete the form with your information, and feel free to put "Patients and Users for Reasonable Policy" as your Organization.
Public Hearing on a 65% Tax on Concentrates (HB 1641)
We’ve been anticipating this one for over a year. This bill is the direct result of the UW Addictions, Drug, & Alcohol Institute (ADAI) workgroup on high THC cannabis policies which PURP members participated in last year. They've incorporated our suggestion to target young adults through an educational social marketing campaign, but unfortunately the main purpose of the bill is to impose a tiered sin tax system on concentrates and, you know, drive us all back to the black market:
This bill proposes to increase the tax rate to 50% for concentrates & cartridges (and flower lol) with 36-60% THC
Proposes to increase the tax rate to 65% for concentrates & cartridges (and flower lol) with more than 60% THC
Proposes to ban the sale of concentrates to people aged 21-24
Proposes to ban the advertising of concentrates, including on social media
How to Take Action
Go to https://app.leg.wa.gov/csi/House. Select "Regulated Substances & Gaming" from the Committee dropdown menu, then "02/02/2023 8:00am" from the Meetings dropdown menu.
Click on "HB 1641 High-potency cannabis," then click the link that says, "I would like my position noted for the legislative record."
On the next page, make sure you select "CON" as your position. Complete the form with your information, and feel free to put "Patients and Users for Reasonable Policy" as your Organization.
Official Testimony
PURP will be giving the following remote testimony, provided here in writing for any regulators who wish to review it:
I was very thankful to have been invited to participate in ADAI's high potency cannabis workgroup last year, especially considering I'm one of the most vocal opponents of recent efforts to limit the potency of concentrates. During this experience, many of the proposed solutions from workgroup participants were to address this public health issue by imposing higher taxes on concentrates, which are already taxed at 47.25% including Seattle sales tax. Other than tobacco, which is taxed at 95% in Washington, I can't think of a product that's taxed more heavily. Ultimately, the people who stand to benefit from more taxes on cannabis products are research organizations such as ADAI, but they'll only get that extra dough if the consumers are willing to pay a 65% tax rate for the same products. And we won't.
Please bear in mind that many mature cannabis users had, and continue to have established black market connections for cannabis products, including concentrates, and raising the prices as this bill proposes will only harm the state's bottom line in terms of cannabis tax revenue. The consumers want safe & convenient access to well regulated products, but with the current economic conditions consumers have to be especially price conscious and will be quick to abandon retail concentrates for homemade rosin.
It should be noted that the premise of limiting the THC potency of concentrates makes no sense from a physical standpoint. If the average potency of cannabis flower is around 20% THC, and we concentrate that by removing most of the plant matter and leaving just cannabinoids and residual lipids, we can expect the resulting product to be at least 40 to 60% THC.
Hashish— an ancient cannabis concentrate that predates Abrahamic religions— typically clocks in at 40% THC, and today's solventless extractions made by applying heat and pressure to hashish typically yield concentrates with 60 to 70% THC. The 35% threshold in this bill is inherently unreasonable.
With regards to limiting sales of these non-lethal cannabis products to persons 25 and older, I would suggest that we stay consistent and raise the drinking age to 25 as well. Nobody here can deny that alcohol is empirically more dangerous, destructive, and deadly than cannabis and yet none of us here are trying to further limit the potency of liquor or eliminate sales to these exact same young people whose “brains haven't fully developed yet.” I'd be interested to hear why the bill sponsors and the academics are less concerned with young adults drinking than using cannabis, though I suspect the reason is because cannabis is a hot topic that can garner more research grants and publicity.
One thing I do appreciate about this bill is that it would allocate funds for a targeted social marketing campaign to educate young people about the risks of using high potency cannabis products, including cannabis hyperemesis syndrome. It's vital that we fully educate people about all the risks of ingesting any substance, but equally important that we respect the sanctity of bodily autonomy in all contexts.
I can easily go on for another hour, but I'll conclude by saying that the consumers who financially support the cannabis industry are opposed to any additional taxes on cannabis products, and I oppose this bill in the strongest of terms. Thank you very much for your time and consideration.
Public Hearing on Limiting Dab Sales to Registered Patients (HB 1642)
I take no pleasure in telling you that the primary sponsor of this bill doesn’t think highly of cannabis or its users. At all. But I suppose that’s a 2-way street.
They’ve introduced this same bill multiple times over the last 4 years, and it never leaves committee [probably because of how asinine it is]. Each year, they make miniscule changes such as raising the potency cap by 5% and try again, and we need to stay vigilant to ensure this bill never moves past the committee hearings.
This year the cannabis potency cap changed from 30% THC to 35% THC, and any concentrates or cartridges that test higher than that can only be sold by medically-compliant cannabis retailers to registered cannabis patients.
This bill essentially bans dabs and cartridges for all non-medical users. But before we drive to Oregon or DM the🔌for rosin, we need to all take 3 minutes and register as being opposed to this bill.
How to Take Action
Go to https://app.leg.wa.gov/csi/House. Select "Regulated Substances & Gaming" from the Committee dropdown menu, then "02/02/2023 8:00am" from the Meetings dropdown menu.
Click on "HB 1642 Cannabis concentrates," then click the link that says, "I would like my position noted for the legislative record."
On the next page, make sure you select "CON" as your position. Complete the form with your information, and feel free to put "Patients and Users for Reasonable Policy" as your Organization.
Official Testimony
PURP will be giving the following remote testimony, provided here in writing for any regulators who wish to review it:
I've testified in staunch opposition to HB 1641 earlier today, which would create a tiered sin tax system for concentrates containing more than 35% THC... which is essentially all concentrates*. HB 1642 is an even more restrictive, out of touch, and preposterous attempt to ban the sale of concentrates which will only harm Washington's cannabis tax revenue, devastate the regulated cannabis economy created by I-502, and help the black market thrive.
Please look into the fiscal impact of eliminating the entire product category from our state's cannabis economy. According to the LCB's 2022 annual report (page 22), the amount of tax revenue generated through cannabis sales was more than double what the state made from taxes on beer, wine, and spirits combined. According to Headset data, concentrates accounted for 11.8% of cannabis sales in the last 90 days, with concentrate cartridges accounting for another 17.3%. Given this data, my layman stoner projection is a 29.1% decrease in annual cannabis tax revenue if this bill passes, roughly $148.7 million that would go up in smoke.
Per usual, I speak for the daily cannabis users who financially support Washington's regulated cannabis economy, and we voted for this system because we didn't want our government to treat us as criminals anymore. HB 1642 would once again make us criminals. Not only would this eliminate safe access to cannabis concentrates, but it would eliminate safe access to cannabis vapor products as well. The archetypal soccer mom who sips her vape pen when her kids are asleep would also become a criminal, and that same black market entrepreneur who supplies her untaxed and unregulated vape cartridges won't ask for her children's IDs when selling concentrate products to them as well.
I believe this is the 3rd time in the last 4 years that we've heard an iteration of this same bill, and I think it speaks volumes that it never moves forward. Please do not advance HB 1642, then we can all do this again next year when the primary sponsor amends and re-re-introduces this asinine bill with a 40% limit. Thank you all for your time and consideration.
*Per my testimony in opposition to HB 1641:
It should be noted that the premise of limiting the THC potency of concentrates makes no sense from a physical standpoint. If the average potency of cannabis flower is around 20% THC, and we concentrate that by removing most of the plant matter and leaving just cannabinoids and residual lipids, we can expect the resulting product to be at least 40 to 60% THC.
Hashish— an ancient cannabis concentrate that predates Abrahamic religions— typically clocks in at 40% THC, and today's solventless extractions made by applying heat and pressure to hashish typically yield concentrates with 60 to 70% THC. The 35% threshold in this bill is inherently unreasonable.
UW Addictions, Drug, & Alcohol Institute Workgroup on High THC Cannabis Policies
PURP has been asked to participate in the University of Washington Addictions, Drug, & Alcohol Institute (ADAI) workgroup to help “tackle risks associated with high-THC products.” This organization wrote the consensus statement on Cannabis Concentration and Health Risks which was the basis of HB 1463, and lead research scientist Dr. Beatriz Carlini testified in support of the bill. Despite our current differences in perspective, we sincerely appreciate the fact that the ADAI reached out to PURP to participate in the conversation.
We encourage PURP members & supporters to read the ADAI's consensus statement on Cannabis Concentration and Health Risks, as well as their recent High THC concentration cannabis policy initial report and consider ways to prevent people (especially those aged 14-18) from experiencing the health risks associated with daily cannabis use, including Cannabis Hyperemesis Syndrome. We will begin presenting potential solutions for ADAI's consideration around February 18, 2022.
Their initial suggestions for policy changes tell you everything you need to know about their current understanding of cannabis use:
Cap THC concentration in products
Require a serving size for all products
Prohibit certain type of cannabis products
Limit total THC in a single purchase
Require a minimum CBD content
Restrict consumption by age
Regulate or prohibit marketing
Regulate packaging and labeling
Please read their consensus statement, their initial report, and use our contact form to submit suggestions that won’t contribute to the cannabis market becoming lamer than it already is.
Read our blog post on the ADAI workgroup to learn more about this project.
HB 1463 (Concentrate Limits) - Public Hearing in the House Committee on Commerce & Gaming
In order to testify in opposition to HB 1463:
Select “Commerce & Gaming” from the first dropdown menu, then “2/12/2020 10:00AM” from the second dropdown menu.
Select “HB 1463 Cannabis concentrates” as the agenda item.
Click “I would like to testify live during the hearing” and fill out the following fields to comment via live Zoom.
Alternatively, you can click “I would like to submit written testimony” to submit written comments. Feel free to use our sample letter for inspiration.
If you want to go the extra mile, email all the sponsors of the bill and ask them to withdraw their sponsorship of HB 1463:
Read our blog post about HB 1463 to learn more about the bill.
SB 5004 (Tax Exemptions for Medical Marijuana Patients) - Executive Session in Senate Committee on Ways & Means
Read our blog post about SB 5004 to learn more about the bill.
HB 1019 (Home Grow Bill) - Public Hearing in the House Committee on Appropriations
In order to testify in favor of [the substituted edition of] HB 1019:
Select “Appropriations” from the first dropdown menu, then “2/9/2020 3:30PM” from the second dropdown menu.
Select “SHB 1019 Residential marijuana ag.” as the agenda item.
Click “I would like to testify live during the hearing” and fill out the following fields to comment via live Zoom.
Alternatively, you can click “I would like to submit written testimony” to submit written comments. Feel free to use our sample letter for inspiration, or visit homegrowwashington.com for lots of great talking points.
Read our blog post about HB 1019 to learn more about the bill.