Page 3 of 5
Drug impaired driving is already illegal in British Columbia. Funds would best be used through education campaigns noting the risks of impaired driving. The issue that needs to be addressed is actual impairment – someone can use cannabis, but not be impaired (based on tolerances, method of ingestion, etc.). Proper public education campaigns will be key. In addition, officers should be properly trained in Drug Evaluation and Classification.
Personal Cultivation It is important to allow for the personal cultivation and production of cannabis. To restrict the personal production of cannabis in an otherwise legalized environment will have a negative impact on individuals, on the health and safety of those individuals, and on the health and safety of the public at large (by driving the activity back underground and into the black market). If the government intends to remove organized crime from the cannabis trade, allowing cannabis to be grown at home should be a central part of the program. If people are allowed to grow their own cannabis, they will have diminished incentive to procure cannabis from the black market. Currently in Canada, people can choose to brew their own beer or grown their own tobacco, or purchase those items through retail outlets. The same framework and options should be available to Canadians when it comes to personal cultivation. A licensing regime for personal cultivation is likely unnecessary and will be financial prohibitive to administer.
Distribution Model CTAC believes that a centralized cannabis distribution system should be avoided for a number of reasons. Cannabis is a very different product than alcohol. It has a different shelf life and requirements for controlled environment. Licensed producers are already required to keep their products in extremely secure vaults far beyond what is seen in alcohol processing facilities, making the need for secure centralized warehouses redundant. Adding layers in the supply chain between producers and consumers will result in higher costs for the province as well as for the consumer. It is important to keep prices low in order to remain competitive with the black market and erode demand for illicit product. A direct distribution model where producers distribute their product directly to retailers, and to consumers via e-commerce, is more effective. Additionally, centralized government distribution restricts the ability of entrepreneurs such as nursery operators, cultivators, processor and retailers to negotiate their own margins. If the barriers to access distribution and retail channels are too high, smaller producers may not be able to achieve the necessary production capacity to enter the system. The key is to create a distribution system that is not overly burdensome for regulators or stakeholders. www.sustainablecannabis.ca