Village Farms has made a submission to the Drug Enforcement Administration (DEA) to support the proposed rescheduling of cannabis in the US. Supporting our position is a decade of objective experience and observational data from Canada and 38 US states with either a medical and/or recreational cannabis program. Below are our comments penned by Michael DeGiglio, the CEO, President, and Founder of Village Farms International.

July 15, 2024

Via Submission to: Federal Register,

Re: Public Comment to Docket No. DEA-1362, "Schedules of Controlled Substances: Rescheduling of Marijuana."

To whom it may concern:

I am submitting these comments as the CEO, President, and Founder of Village Farms International, a public company, employer, taxpayer, and top-ranked producer of both fresh produce and cannabis. I strongly urge the DEA to support the effort to reschedule cannabis, thereby enabling the scientific community to generate the clinical data needed to guide and direct the creation of a permanent and sound cannabis policy at the Federal level. As a result of prohibition, cannabis' status as a Schedule I drug has created near-insurmountable barriers to academic research, particularly in a clinical (human) setting. As a direct result, we lack well-controlled clinical data that can inform the very questions being posed presently, such as the utility, efficacy and characterization of the many potential applications of cannabis in medicine, as well as risks such as abuse potential. Moving cannabis to a Schedule III classification would enable a measured process to gather data, adequately characterize the science of cannabis, and then use those lessons to develop a well-regulated industry.

The paradox to cannabis' current Schedule I classification is, arguably, the legal status of both alcohol and tobacco. Objectively, both are exponentially more likely than cannabis to be abused, result in dependence, and/or lead to a terminal health condition. In addition, both objectively have no claim to medical use as a consumer good. Alcohol and tobacco are proof that we as a society are capable of designing a well-regulated cannabis industry, one that mitigates potential harms while still allowing consumer access. Schedule III is the first step in correcting these mistakes towards needed groundwork to allow the world's foremost health and wellness economy to lead both scientifically and commercially.

While we lack high quality clinical data in humans, we do now have a decade of objective experience and observational data from both Canada and 38 US states with either a medical and / or recreational cannabis program. For example:

• States like Colorado are reporting a decrease in use among high schoolers over the past 10 years, from 19.7% to 12.8%, likely as a result of legalization and normalization.
• In twin studies, which provide some of the most powerful studies in science, there was no correlation between a state legalizing cannabis and a heightened risk of cannabis use disorder, cannabis addition, or addiction to other illicit drugs. In addition, those in legal states showed a reduction alcohol-related problems.
  Our own Health and Human Services Department concluded: "[A]s a relative finding on abuse liability, when comparing marijuana to heroin, oxycodone, hydrocodone, fentanyl, cocaine, ketamine, benzodiazepines, zolpidem, tramadol, and alcohol in various epidemiological databases that allow for some or all of these comparisons, marijuana is not typically among the substances producing the most frequent incidence of adverse outcomes or severity of substance use disorder."
• Canadians have seen a dramatic shift in citizens moving from the black market to the regulated market, with only 3% of people reported purchasing from an illegal source (illegal store, illegal website or dealer), down from 2018 (28%), the inception of the regulated market.
• Fewer Canadians operated a vehicle after cannabis use in the past 12 months. Seventeen percent (17%) of people who had used cannabis in the past 12 months reported driving after cannabis use, a decrease from 27% in 2018.

The US has long been the world's greatest innovator and beneficiary of free market capitalism, yet we have failed completely on the issue of cannabis due to half-measures and a lack of political leadership to take the right, and very publicly supported action: rescheduling, or descheduling, cannabis from a Schedule 1 controlled substance. We are at very real risk of becoming a tertiary player on the world market for what seems, objectively, a foregone conclusion that cannabis legalization is inevitable.

Personally, as a proud former aviator, officer and squadron leader for the US Navy (retiring as a Captain after 26 years active and reserve service) who has proudly served these great United States, I am often asked why we pivoted Village Farms into cannabis and cannabinoids given the immense regulatory challenges. We did so because we see the great opportunity for the cannabis plant to deliver incredible benefits to complement the human endocannabinoid system. I believe that in my lifetime, with proper regulation, and research-supported opportunities, we can finally unlock and understand the power and potential of this plant. The people of this great country deserve nothing less.

Sincerely,

Michael DeGiglio
President & CEO
Village Farms International