I wrote to Jonathan Bach at the Statesman Journal:

Jonathan,

I just finished reading your article on the SOS audit of the OLCC. Great reporting that went much deeper than other articles I’ve seen.

A couple of things that the OLCC does not bring up:

First, the OLCC continues to approve licenses, even as the amount of cannabis in the legal market has exploded in terms of volume. The direct result: very low wholesale prices for growers. And the result of that: a strong incentive to move product to the black market. I was at the first METRC training, with the manager of METRC from Florida (Scott Denholm, April 2016). He explained that METRC was designed to keep product from moving into the legal, regulated market from the black market, under the assumption that prices would always be higher in the legal market (and thus, that the incentive would be to move product IN rather than OUT of the legal market). This mistaken assumption underlies the basis design of the self-reporting system: METRC designed a one-way valve that faces the wrong way, as it were.

Second, threatening fines and loss of license for volunteering to be regulated by the state is a backwards-looking activity. It reminds me of Prohibition. I think the OLCC should be encouraging, rather than threatening growers, processors and retailers. I think the state and the OLCC would better spend their time and treasure asking licensees how they can make it easier to comply with the basic goals of the system, rather than continually adding rules to try plugging the dike, and threatening licensees. We get enough threats from the federal government!

Just some basic thoughts I’d like to have out there. I find the OLCC is not receptive to suggestions (it is like they are so busy that they cannot stop to listen to constituents).

Thank you for your writing, Jonathan!