To Whom It May Concern: I submit these comments in response to the recent Nov 7th Hemp Task Force meeting & subsequent recommendations made by committee members. I also write to express my high level of concern that these efforts & attempts at regulation seem to continue to be done in ways that are devoid of public transparency, & do not appear to adhere to protocols set in place, as they tend to occur in other industries. The summary I took away from this recent (* not made open to the public, )meeting is as follows; 1-Assess the legality of products that include THC, use all THC in total THC equation (This is counterproductive from a number of standpoints, & reflects the governments lack of understanding of the cannabis plant, the extraction processes, & much, much more. This would also completely negate ability for the current industry to be able to fiscally withstand production, testing, & other aspects of operations.) 2-Coordinate with law enforcement to enforce parameters on inhaled THC products (This seems to be a far reach, & one that bleeds into the jurisdiction of ATF, which, again, seems to create a multitude of conflicts of interest, & further convolute an already muddied & stagnated legalization process.) 3-Put into place a permit to sell hemp products. (Who would issue these...? Would you be again trying to task VDACS with a job that isn't theirs? Would a new agency be instituted for this? Where would the money come from for this? Permitting needs to be increased for professional/industry standard, but, I wonder if this process has truly been mapped out with any intention or critical thinking with regard to establishing & maintaining a solid permitting & renewal process.) 4-Add increased penalties to selling illegal hemp products (There is so much wrong with this. VA claims to be invested in the legalization process, & cannot seem to figure that out, yet, you are going to initiate the possibility of increased penalties? Most everyday folks don't even know what is legal, what isn't, nor feel there is any clarity to being able to know whether or not they are following the letter of the law. Businesses in the industry feel similarly, & quite often. Not to mention, literally anyone can receive just about anything they want, from another legal state, via mail. The only thing this would do would be to deepen the black market, & cause more of a mess.) 5-Address edible hemp extracts in restaurants. (I think this task force, and, quite honestly, the Commonwealth need to reground themselves in a concrete legalization path before this is even discussed. There are so many other more critical issues that need addressing with the hemp and cannabis industry, (while VA continues to pass by billions it could be reaping in tax revenue if we were on the other side of this process,) that the idea of this initiative just further weakens the credibility of the folks attempting to string this together. My apologies for sounding overly open but, I, along with countless others, are ready for the legalization of retail cannabis, legal hemp cannabis, & other corresponding products, to be put in place. We are tired of seeing our businesses strung over the cliff of the mountain every time this committee, & budget committees meet, & attempt to put some half woven policy into place. We want safe public use, clear guideline, & you all to invest in folks you still aren't invested in- the folks who know this plant. Regards, Leigh Anne Kuhn

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Please see the attached letter of which I echo. Thank you.

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Thank you for providing this opportunity to discuss and deliberate on the best ways to regulate hemp derived compounds. At the onset, it must be noted that cannabis/marijuana and hemp are the same plant (Cannabis sativa l) and the intoxication from Δ9-tetrahydrocannabinol (“Δ9-THC”), other phytocannabinoids cannabinoids or cannabinoids chemically converted from cannabidiol (CBD) is identical regardless of source. As such, when the Commonwealth’s report specifically states that “ the charge of this taskforce [is] to advise the General Assembly on the best way to distinguish between legal, non-intoxicating hemp products and illegal, intoxicating cannabis products and the regulatory framework that aids in enforcement” one vital piece of information must be clarified: intoxicating cannabinoids are routinely derived from hemp but at the same time fit into the federal definition of hemp and this consideration is not adequately captured by the Commonwealth’s discussion.

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Written Comments Attached in pdf format Re: Virginia Hemp Coalition's response to the proposed draft recommendations of the Virginia Hemp Task Force

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Please see attached comments from the Virginia Healthy Alternatives Association

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We appreciate the opportunity to submit written comments to the Task Force to Analyze Industrial Hemp Extracts and Other Substances Containing Tetrahydrocannabinol (THC) Intended for Human Consumption (the “Task Force”). We ask that you consider these comments in conjunction with our previously submitted written comments as well as the oral testimony provided by our lobbyist, Dylan Bishop, at the Task Force’s July 7 meeting. The Cannabis Business Association of Virginia (“CannaBizVA”) is a non-profit, trade association formed to advocate for the expansion and protection of commercial opportunities for Virginia businesses in the Commonwealth’s regulated cannabis industries. Our membership includes farmers, processors, manufacturers, retailers, laboratory testing facilities, and other ancillary businesses, and we represent their interests collectively. While CannaBizVA generally agrees with many of central tenets brought to light and recommended by the Task Force, CannaBizVA fervently opposes the recommendation that a hemp product’s legality should be assessed using its total THC concentration. Both Federal law and the Commonwealth currently define and distinguish hemp and hemp-derived products from marijuana using a Delta-9 THC scale. Accordingly, a change to a total THC standard would bring Virginia out of alignment with the Federal definition, and which would only serve to shrink Virginia’s hemp markets to a smaller scale than that which is currently permitted by the USDA and Federal courts.

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Please see attached file for written comment.

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Attached are comments from the U.S. Hemp Roundtable in response to the “Report of the Task Force to Analyze and Make Recommendations Regarding Whether Any Statutory or Regulatory Modifications are Necessary to Ensure the Safe and Responsible Manufacture and Sale of Industrial Hemp Extracts and Other Substances Containing Tetrahydrocannabinol that are Intended for Human Consumption in the Commonwealth.”

My name is Ryan Suit and I am a hemp grower and processor, an owner of a CBD and hemp store in Virginia Beach, and a licensed attorney in Virginia. Thank you for your time and effort in drafting this report. The Hemp Task Force came up with several excellent recommendations that will move the hemp and cannabis industry forward. That being said, there are some issues with a couple of the recommendations made. First, assessing a product’s legality using its total THC concentration makes sense, but redefining marijuana to include hemp-derived THC products does not. Products should not be defined as marijuana simply because they have a certain amount of THC. Doing so could create a knot of terms that would later need to be untangled. The term marijuana should be reserved for cannabis and should not include hemp or hemp products. The task force should recommend adding a term such as “intoxicating hemp products” to differentiate hemp-derived THC products from cannabis products and from non-intoxicating hemp products. Second, requiring permits for the sale of intoxicating hemp products is a good idea, but it will not reduce the occurrence of cannabis related “pop-up shops.” Pop up vendors almost exclusively sell cannabis products; in other words, weed. They are not selling hemp-derived products. Requiring a license for hemp-derived products would have a minimal effect on pop ups. If this Task Force wanted to reduce pop up shops, it would recommend increased enforcement of existing laws pertaining to unlicensed sales of cannabis products. While the Task Force’s recommendations have a lot of potential, the entire report limits its own value by failing to consider adult use cannabis sales. The report explicitly states that it takes no position on regulating adult use cannabis and marijuana. However, it would be so much simpler to regulate cannabis products and intoxicating hemp products together. The Task Force acknowledges that licenses should be issued for THC products that are made from hemp. It logically follows that the Task Force would support licenses for THC products from cannabis. At this point, products with THC from either cannabis or hemp can produce the same effects, and they should be regulated in the same manner. This can be done in one single step next session: legalize the adult use cannabis market and let the CCA develop rules to govern cannabis and intoxicating hemp. That is the main conclusion this report should reflect. Thank you for your time and consideration of my comments. I hope you find them helpful, and I look forward to the Task Force’s presentations to legislators.

Through out the Federal Legalization of hemp, many people have touted the positive benefits of the many things that can be done with processed hemp curd or even the many cannabinoids that it has. It’s a plant that you can build with and help treat minor health issues with. Many potentials of course but what you don’t hear to much about would be the hemp plants ability to help reclaim toxic soils that have been contaminated with heavy metals and sulfurs. The hemp plant has the ability to absorb these metals via root system and metabolize them through out the leaf system better than any other plant. Im citing most of this information from testing results reported by Penn State. However, Virginia has a history of mining and prospecting coal and precious metals such as gold, copper, and zinc. Though production mining has slowed down over the last several decades, the damaging impacts to the environment around those mines still exist today. The soils are in poor quality due to the heavy metals leaching from the mines and most native vegetation struggles to survive in these areas. The water sources near or on the mining sites tend to test low for P.H. levels do to these heavy metals causing the water to become corrosive which won’t allow aquatic vegetation to grow. With the lack of aquatic vegetation it reduces the oxygen levels in the water. In return, reduces the aquatic wildlife. I also believe hemp has the potential to sequester carbon from the atmosphere at high rates. So with that being said, hemp can have a significant impact on reclaiming soils and improving the landscape around these retired mines and other polluted soils. I believe when it comes to regulating the hemp plant, Virginia should consider on how to regulate “non traditional” hemp practices such as using the plant for environmental reclaim projects and not just farming. We can also use the reclaim hemp for industrial purposes as well, adding to the extra benefit. Virginia should allow for programs as such and even consider giving grants to businesses who participate in helping reclaim these polluted areas. A program of this nature would not be relevant to traditional agriculture and would need to be monitored and regulated differently. This plant can help us restore our environment and put nature back at its balance. This plant can help us fight a polluted world. Let’s use it for that if anything. Thank you for taking your time to read this.

Hemp, is hemp is hemp! Adding more layers to an already “red tape” laden process doesn’t do anyone any good. Where’s the accountability? Unfortunately, it falls on the farmers. The federal government has defined hemp already. They’ve obviously got some holes to fill. If any product, topical, ingested, inhaled, or other falls into what the federal government says is hemp, then it’s hemp! This really isn’t this difficult. You’re only stifling an emerging industry that has HUGE potential for Virginia. In closing, I ask you to ask yourselves, 1) will it really make a difference 2) are you truly going to be able to enforce it and hold people accountable 3) what good does it bring to the greater good?

Pot is not Alcohol, and THC is not analogous to ABV. There are a lot of things to take issue with in regards to governments control attempts, but this one is a vital starting point in understanding. If you use THC% at any point you're building on false ground and asking for collapse. Please take the time to educate yourself before you create the law of the land.

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I am attaching an update to the comments submitted by the Virginia Catholic Conference on Aug. 5. Thank you.

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This an update to the July 7 testimony and Aug. 5 comments filed by the Virginia Catholic Conference. Since that time, there have been two notable incidents in the Commonwealth that the Hemp Task Force and the General Assembly should consider in responding to the proliferation of Delta 8. Four-year-old Spotsylvania boy died from ingesting Delta 8 THC: In October, CNN, the New York Post, the Fredericksburg Free Lance-Star, NBC 4, WUSA 9 and many other news organizations reported that the mother of a four-year Spotsylvania County boy who died in May after consuming a large amount of Delta 8 THC was arrested. After ingesting THC gummies, the boy was eventually taken to Mary Washington Hospital, and then transferred to the VCU Medical Center in Richmond. He was taken off life support on May 8. The boy’s mother, Dorothy Annette Clements, 30, is charged with felony murder and felony child neglect. Court records show that the child was being cared for by Clements on May 6 when he suffered a medical emergency. According to Dr. Robin Foster, toxicology results showed an extremely high level of THC in the boy’s system. CNN reported that the Virginia Department of Health confirmed the child’s death is considered to have been accidental and “the cause of death is Delta-8-tetrahydrocannabinol toxicity.” Several students sickened after taking Delta 8 THC edibles at Virginia middle school: At least seven students at Liberty Middle School in Fairfax County reported feeling ill after apparently eating Delta 8 gummies, according to the school’s principal who informed families by letter. Fairfax County Fire and Rescue and police officers were called to the school in Clifton on Oct. 27. Fairfax Fire dispatched several ambulances to the scene. The students were having symptoms of vomiting, dizziness, and slurred speech, according to Principal Adam Erbrecht. Three of the students were taken for medical treatment and the rest were treated at school or were sent home with their families. Fairfax Police determined there was no crime, but the principal wrote that there might be disciplinary action. The above cases follow publicly reported THC-edible poisonings in Roanoke and Stafford counties. In July, the Blue Ridge Poison Center at UVA Health reported a five-fold increase in calls for adverse reactions to Delta 8. These repeated instances of harm to children make it abundantly clear that the Virginia General Assembly should consider banning the sale of Delta 8 as has been done by at least 12 states.

Comments Document

Please refer to the attached file as my comment, in which I concur. Thank you kindly, Leandra

I offer my services to the Commonwealth of Virginia as an expert in state regulations of marijuana sales. Right now expertise is missing on the regulatory boards and taskforce. We need industry and law involved more actively and less policy pushing. Accordingly I have submitted my information to the 3 authorities and seek support from the commission members in my effort to improve the boards.

Cannabis legalization would allow citizens to grow their own plant medicine and curb the need of random shops selling dangerous chemical ridden cannabis. Legalize cannabis and allow Virginian's the choice of medicine that works best and safest for them.

Thank you for taking hemp products seriously. Please also consider working to ban Delta 8 products in Virginia. Approximately 18 other states have banned Delta 8 products including Colorado (a liberal substance use state). Delta 8 products have no quality control, are often mislabeled, may include adulterants like Delta 9, can cause health and psychiatric risks, can be easily mistaken for candy by toddlers and youth, and Delta 8 can be misused by adults. Delta 8 is not safe; it poses many individual and community risks for Virginians! Thank you for working to ban Delta 8 products.