Example Public Comment to the Cannabis Control Commission (MA)

We have an opportunity to provide much needed feedback to the Cannabis Control Commission that will impact the future of the Cannabis Industry in Massachusetts. Please review and use this example below to email your public commentary to Commission@CCCmass.com.

Subject: Public Comment: Disproportionately Impacted Areas

Thank you for the opportunity to submit public comment on your plans to update your Disproportionately Impacted Areas (DIAs). My community has been deeply harmed by the War on Drugs through decades of policing and over enforcement of drug laws. I appreciate that the state’s Cannabis Control Commission has developed programming and opportunities earmarked for DIAs, to remedy the harm that has been done to our communities. These programs and your PIP plans will deliver millions of dollars to communities and non-profits across Massachusetts and aim to prioritize some people of color entering the cannabis industry. However, enough hasn’t been done and UMass’ recent report, Identifying Disproportionately Impacted Areas by Drug Prohibition in Massachusetts would reverse the limited progress made and further disparities for those of us who have been most harmed – black and brown people.

The report fails to focus directly on the communities that have truly been disproportionately harmed by overenforcement of drug policies. While the report states that “prior research demonstrates that enforcement of drug prohibition has resulted in disproportionately high numbers of arrests and incarceration for Black and Latino individuals,” it does not center the DIA designations on those communities of color.  Instead, the report doubles the number of DIAs with a “Tier 2 list.” The addition of 30 wealthy cities and towns that have not faced any meaningful harm from marijuana prohibition, would force my community to unfairly compete against well-resourced communities for jobs, non-profit donations, and other forms of community investment. Insufficient data collection and poor understanding of urban neighborhoods has entirely excluded cities like Lawrence and important neighborhoods of color within Boston, Worcester, Springfield, and other large cities. These cities and neighborhoods have already been devastated by the War on Drugs and UMass’ report will cause further harm because of the ineffective use of census tracts and missing data. Lastly, the intentional decision to use certain research methodologies and datasets paint a distorted picture of who has been harmed and should benefit from the millions of dollars in community investment from the legal cannabis industry. 

In order to correct these concerning matters, I ask that the Cannabis Control Commission revisit this report and its findings in an equitable manner that utilizes a racial-equity lens and prioritizes the identification and designation of only those who have been disproportionately harmed by the War on Drugs. 

I recommend doing so by:

  • Conducting a scholarly peer review of this report with researchers who are from, and understand the impact of the War on Drugs in, communities of color
  • Focusing on those who have been harmed and embracing that a larger DIA list is inherently inequitable – the focus should be serving communities who are deserving, not serving more communities
  • Revisiting the review period of this report to include the 80’s and 90’s and de-emphasize the opioid epidemic of the 2000’s – the opioid epidemic is not synonymous with the War on Drugs
  • Ensuring sufficient data collection and analysis to consider missing cities like Lawrence
  • Focusing on marijuana arrests, convictions, and incarceration instead of “all drugs” to de-emphasize the opioid epidemic
  • Revisiting the overuse of arrest data and include conviction and incarceration data to understand the impact of the War on Drugs as people of color go deeper into the justice system  
  • Identifying and implementing a more effective mechanism than census tracts to ensure you are truly capturing the impact that the War on Drugs had on entire neighborhoods
  • Removing arbitrary “ceilings” (e.g. designating the top 20% of Massachusetts municipalities as DIA) to ensure the list is identifying disproportionately impacted communities, rather than an ineffective ranking list of communities, which overwhelmingly includes communities that have not been harmed by the War on Drugs
  • Focusing on neighborhoods where crime perpetrators reside, not just where the crimes occurred – a truer indicator of the people who have been harmed by the War on Drugs

Thank  you for the opportunity to submit a public comment.

(Insert Your Name here, or organization)