Office at the Camera! (II. amaze July 24, 2017 The Honorable Kate Brown Governor State of Oregon State Capitol Building 900 Court Street NE Suite 160 Salem, OR 97301 Dear Governor Brown: Thank you for your letter of April 3, 2017, which I have attached to this letter as Exhibit A for your convenience. I was pleased to read that you share my concern for public health and safety and my belief that the federal and state governments should work together to address our country?s concerns with marijuana. Congress has determined that marijuana is a dangerous drug and that the illegal distribution and sale of marijuana is a crime. The Department remains committed to enforcing the Controlled Substances Act in a manner that ef?ciently applies our resources to address the most signi?cant threats to public health and safety. I look forward to working with you on these issues. I also read with interest the statement in your letter that you ?have worked . . . to establish robust regulatory structures that prioritize public health and public safety,? and that you believe that the 2013 Cole Memorandum, its eight enforcement priorities, and related memoranda are an ?indispensable? part of the ?framework? in your state. In that regard, I would note the concluding paragraph: ?nothing herein [in the Cole Memorandum] precludes investigation or prosecution, even in the absence of any one of the factors listed above, in particular circumstances where investigation and prosecution otherwise serves an important federal interest.? Thus, the memorandum ?does not alter in any way the Department?s authority to enforce federal law, including federal laws relating to marijuana, regardless of state law.? I also recently read the January 2017 report by the Oregon State Police, entitled Baseline Evaluation of Cannabis Enforcement Priorities in Oregon.? (A copy of this report is attached as Exhibit B.) This report raises serious questions about the efficacy of marijuana ?regulatory structures? in your state, including findings that: a Only 30 percent of marijuana market activity in Oregon is compliant with state marijuana laws (in other words, over two?thirds of marijuana market activity occurs in the black market); 0 There is an association between the counties in Oregon with large numbers ofmarijuana registrants and black market diversion of marijuana; The Honorable Kate Brown Page 2 There is ?pervasive illicit cannabis cultivation in the state. . . [and] a strong indication that surplus cannabis is not discarded, but is in fact trafficked out-of-state and sold for a huge profit margin?; ?Law enforcement is unable to keep pace with out?of-state cannabis diversion . . ?The reality of legalization is that it has provided an effective means to launder cannabis products and proceeds, where in essence, actors can exploit legal mechanisms to obscure 'products? origin and conceal true profits?; The cost and rate of burn victims from marijuana extraction labs has increased substantially since legalization, with $7.6 million in federal government entitlement programs used to cover the cost of treatment; There has been a 55 percent increase in marijuananelated emergency room visits from March 2015 to September 2016; and Under-age users represent the majority of marijuana impairment cases on Oregon?s roadways, according to Drug Recognition Expert (DRE) data from 2013 to 2015; 63 percent of Oregon adults do not even know whether it is legal to drive after using marijuana. These ?ndings are relevant to the policy debate concerning marijuana legalization. I appreciate your offer to engage in a continuing dialogue on this important issue. To that end, please advise as to how Oregon plans to address the serious ?ndings in the Oregon State Police report, including efforts to ensure that all marijuana activity is compliant with state marijuana laws, to combat diversion of marijuana, to protect public health and safety, and to prevent i marijuana use by minors. i also am open to suggestions on marijuana policy and related matters as we work to carry out our duties to effectively and faithfully execute the laws of the United States. You may direct your response and suggestions to the Intergovernmental Affairs and Public Liaison within the-Office of Legislative Affairs, which can help coordinate any communications logistics. I look forward to your response. . -- ferson B. Sessions'HI Attorney General WASHINGTON April 3, 2017 Attorney General eff Sessions Secretary Steve Mnuchin- U.S. Department of Justice U.S. Department of the Treasury 950 Ave, NW 1500 Ave, NW Washington, DC 20530 Washington, DC 20220 Attorney General Sessions and Secretary Mnuchin: As governors of states that have legalized marijuana in some form, we'ask the Trump Administration to engage with us before embarking on any changes to regulatory and enforcement systems. The balance struck by the 2013 Department of Justice Cole Memorandum (Cole Memo) has been indispensable providing the necessary framework for state regulatory programs centered on public safety and health protections. We understand you and others in the administration have some concerns regarding marijuana. We sympathize, as many of us expressed apprehensions before our states adopted current laws. As governors, we have committed to implementing the will of our citizens and have worked cooperatively with our legislatures to establish robust regulatory structures that prioritize public health and public safety, reduce inequitable incarceration and expand our economies. The Cole Memo and the related Financial Crimes Enforcement Network guidance provide the foundation for state regulatory systems and are vital to maintaining control over marijuana in our states. Overhauling the Cole Memo is sure to produce unintended and harmful consequences. Changes that hurt the regulated market would divert existing marijuana product into the black market and increase dangerous activity in both our states and 'our neighboring states. Likewise, without the guidance, ?nancial institutions will be less willing to provide services to marijuana-related businesses. This would force industry participants to be even more cash reliant, posing safety risks both to the public and to state regulators conducting enforcement activity. The Cole Memo and guidance strike a reasonable balance between allowing the states to enact reasonable regulations and the federal government?s interest in controlling some of the collateral consequences of legalization. Attorney General Jeff Sessions Secretary Steve Mnuchin April 3, 2017 Page 2 Twentyweight states, representing more than 60 percent of Americans, have authorized some form of marijuana-related conduct. As we face the reality of these legalizations, we stand eager to work with our federal partners to address implementation and enforcement concerns cooperatively. The Cole Memorandum and the associated guidance are critical to th success of any collaboration. - We look forward to working with you and your administration. We stand ready to have further discussion on how these important federal policies work in our states. (We Sincerely, Bill Walker John Hickenlooper Governor Governor State of Alaska State of Colorado Kate Brown Jay Inslee Governor Governor State of "Oregon State of Washington ?Ax/2 magma State Pa?ice - Mug Enforcement $ect?m 3565 Tvelstad Me Sa?em, Megan mmwma Table of Contents Section 1: Executive Summary and Strategic Findings from Research Section 11: State Compliance on Cannabis Diversion Section 111: State Compliance on Cannabis Distribution to Minors and Associated Adverse Public Consequences Section IV: State Compliance on the Growing of Cannabis on Public Lands and the Attendant Public Safety and Environmental Dangers Section V: State Compliance on Prevention of Exploitation of State?Authorized Cannabis Activities for Illicit Activity and Violence in the State?s Cannabis Industry Section VI: Conclusion Executive Summary and Purpose Oregon has had a state-authorized medical cannabis system since 1998, and in November 2014, Oregon voters approved the Control, Regulation, and Taxation of Marijuana and Industrial Hemp Act, commonly known as Measure 91 to legally commercialize non?medical retail cannabis in the state. The Drug Enforcement Section at the Oregon State Police created this report to survey currently available data in an effort to evaluate state compliance with the federal guidance for enforcement priorities, issued by former Federal Department of Justice Deputy Attorney General James M. Cole, on Preventing the distribution of marijuana to minors; Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs, and cartels; Preventing the diversion of marijuana from states where it is legal under state law in some ?om to other states; I - Preventing state~auth0rized marijuana activity ?om being used as a cover or pretext for the tra?icking of other illegal drugs or other illegal activity; - Preventing violence and the use of firearms in the cultivation and distribution of marijuana; - Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use; a Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands; and Preventing marijuana possession or use on federal property. To this end, this report examines Oregon?s compliance on mitigating these threats and analyzes areas of concern speci?cally related to these enforcement priorities. H?smry (if Qanmh?s Lsga??iy in. Grsgan Ramsa?wsi {Emmi?s Legaiizs? 2014 Measure 91 Recreationai Retail Stores Begin Sales 2017 i i 1998 Ballot Measure 67 Oregon Decrlminalization Bil! 3% (Oregon Medical Maruuana Madioal Marijuana Dispensaries Legalized by Legislatura Enforcement Priorities Cannabis.Piversiea-IFT Accompanying Health 8: Safety. 55 same Lands Strategic Findings train this Assessment Diverted Oregon cannabis has an expansive geographic footprint and has been detected outside of the United States. Six Oregon counties are tied to the majority of diversion activity in the state, accounting for 76 percent of diversion seizures by weight and 81 percent of diversion incidents; these counties were also tied to the majority of destinations. Oregon originated cannabis is trafficked to known distribution hubs across the Southeastern, Midwestern, and Northeastern United States. Speci?cally, the states of Minnesota, New York, and Florida represent statistically signi?cant destinations. There is a geographic relationship between the state~authorized Oregon Medical Marijuana Program (OMMP) registrants and dominant diversion counties (originating counties of diversion activity). Historically, an annual average of two percent of Oregon?s traf?c fatalities were associated solely with cannabis; this rate has not changed signi?cantly since legalization. As of 2015, 60 percent of graders reported that acquiring cannabis was ?easy?. The cost and rate of cannabis extraction burn victims has increased substantially since legalization, with $7.6 million in federal government entitlement programs used to cover the cost of treatment. Currently, 63 percent of Oregon drivers do not know when it is legal to drive after using cannabis. Males 16 to 28 are a high-risk demographic for cannabis impaired driving and account for the majority of the activity in the state. To date, legalization has not affected the rate of illicit cannabis cultivation on public land. The Illinois, Applegate, and combined Rogue Watersheds are particularly vulnerable to environmental damage from illicit cannabis grow sites. Illicit cannabis grows have consumed 1.04 billion gallons of water since 2004 and con- sume roughly 442,200 gallons of water daily during the growth season. Eradication and enforcement efforts have a high return on investment; an average of 1,266.55 dollars? worth of. illicit cannabis is returned for every dollar spent. Enforcement Priorities Violence and Illicit Activates Recommended Enforcement Priorities Strategic Findings irern this Assessment Criminals are exploiting Oregon?s cannabis industry for ?nancial crimes and fraud. Legal entities in Oregon?s cannabis industry have been targeted by Violent criminals and armed robberies. These enforcement priorities require on-going performance monitoring and continual analysis to gauge the ef?cacy of the state?s regulatory regime and enforcement system. To properly evaluate these areas of concern there should be dedicated personnel to collect, analyze, and disseminate information to enforcement forces. Collaborative strategies should be developed to enhance data collection on these enforcement priorities to better evaluate Oregon?s compliance with federal guidance. These enforcement priorities and baseline analyses should be core to the development of a statewide enforcement model. State Compliance on Cannabis Diversion Execntive Summary and Purpose The focal points of this section are derived from the federal guidance, issued by former DOJ Deputy Attorney General James M. Cole, on Preventing the diversion of marijuana ?om states where it is legal under state law in some form to other states 0 Preventing state?authorized marijuana activitj/from being used as a cover or pretext for the tra?icking of other illegal drugs or other illegal activity I To this end, this section examines Oregon?s role in the informal cannabis economy by measuring relative diversion rates and the connection between over-production and external markets. Additionally, geographic concentrations of diversion activity are identi?ed. Strategic Findings - Divertcd Oregon cannabis has an expansive geographic footprint and has been detected outside of the United States. 0 Six Oregon counties are tied to the majority of diversion activity in the state, accounting for ?76 percent of diversion seizures by weight and 81 percent of diversion incidents; these counties were also tied to the majority of destinations. 0 Oregon originated cannabis is trafficked to known distribution hubs across the Southeastern, Midwestern, and Northeastern United States. Speci?cally, the states of Illinois, Minnesota, New York, and Florida represent statistically signi?cant destinations. 0 There is a geographic relationship between the state-authorized Oregon Medical Marijuana Program (OMMP) registrants and dominant diversion counties (originating counties of diversion activity). 1 Cole, James M. 2014. "Guidance Regarding Marijuana Financial Crimes." US. Department February 14. Accessed September 26, 2016. justice. 2 Cambridge Dictionary. 2016. Cambridge English Dictionoiy. Accessed September 28, 2016. 3 Crawford, Seth S. 2014. "Estimating the Quasi-Underground: Oregon's In formal Marijuana Economy." Hinnboidr Janina! ofSociai Relations (36): 120. 4 Schneider, Friedrich, and Colin Williams. 2013. The Shadow Economy. Economic Report, London, Great Britain: The Institute of Economic Affairs: 9-27. 5 World Bank. 2007. The Infonna! SectorCare, and How Do We Measure Economic Report, Worid Bank. .pdf. 6 Oxford Dictionary. 2016. English arford Living Dictionaries. Accessed September 26, 2016. 7 Association of Oregon Counties. 2016. "Selected Oregon Marijuana Laws." AOC Mory?nona April 5. Accessed September 26, 2016. 9. 3 Cote, James M. 2014. "Guidance Regarding Marijuana Financiai Crimes.? UES. Deponnien! of Jnsrice. February 14. Accessed September 26, 2016. wmv}us{icegovisitesidefaulti? Eesiusao-wdwaficgacyIZO1 9 Association of Oregon Counties. 2016. "Selected Oregon Marijuana Laws." A 0C Maryanne: April 5. Accessed September 26, 20 I 6. 7. 8 Whatever the e??ects of drug legalization, declines in nationwide drug traf?ck- ing are not among them. --David W. Murray, Hudson Institute Centerfor Substance Abuse Policy Research ?0 Historically, Oregon has been the source of high?grade cannabis with a production rate that saturates the state?s domestic market. 11 According to statistics from the Drug Enforcement Administration (DEA) the state consistently ranks near the top for plant seizures with 39,198 plants or 47,038 kg (103,700 lb) of raw plant product seized in 2015 alone. 12 Estimating Oregon?s total market output for cannabis is problematic as activities in the informal economy and illicit market are not monitored. However, one can obtain an approximation by combining production information from the Oregon Liquor Control Commission (OLCC), publicly available registrant data from OMMP, and illicit 2003 grow sites? statistics with health survey data to approximate state consumption. 13? 14? 15? 16 Thus, assuming a single annual plant yield of 1.2 kg (2.64 lb), this mixed-source estimate would place total state production between 289,000 and 911,500 kg (637,100 to 2 million lb). Using consumption models from the Oregon Health Authority, National Survey on Drug Use and Health, among others would mean that Oregon 150'." consumes roughly 84,400 to 169,000 kg (186,100 to 372,600 lb) annually (See Figure 1)}7 This would leave approximately 120,300 to 827,000 kg (265,200 to 1.8 million lb) of cannabis above what Oregonians can conceivably consume. At maximum production capacity, this annual surplus is worth between 4.7 billion and 9.4 billion dollars, at end-user street prices, on the national informal economy (See Figure 2). Annual Commp?on of Cannabls In Oregon byAge Group Figure l: Calculated Annuaf Cannabis Conscription in Oregon by Age and Frequency 2016 10 Murray, David W. 2016. "Declining Under President Obama?" Hudson Institute. August 5. Accessed September 28, 2016. 2707? ll lnvestopedia. 2016. Market Saturation. Accessed October 6, 2016. 12 Drug Enforcement Administration. 2015. 2015 Domestic Cannabis EradicationiSuppression Program 13 Statistical Report. Accessed July 21, 2016. 5.pdf. 14 Crawford, Seth S. 2014. "Estimating the Quasi~Underground: Oregon's Informal Marijuana Economy." Jonmat of Social Relations (36): 131. 15 Hall, Shaun. 2016. "Report: Over-production of medical feeds black market in Oregon.? Mail Tribune. July 25. Accessed August 7, 2016. 16 Oregon Liquor Control Commission. 2016. "Dispensary Survey Results: A Snapshot of Current Practices and Conditions." Accessed September 21, 2016. l? Dilley, M.E.S., Julia, Caislin Firth, M.P.H., Erik Everson, M.P.H., and Julie Maher, 2016. "Marijuana use, attitudes and health effects in Oregon.? Marijuana Report (Oregon Health Authority Oregon Public Health Division) 48. 8509-marijuana-reportpd? Oregon has been characterized as an Oregon cannabis epicenter of cannabis production and the Production Consumption state?s crop yields are worth more than any 13, 19 other agricultural commodity. Consequently, Oregon?s cannabis market continues to operate largely outside the formal economy, and according to the Gannabi Production Heavy Usage 3 1 Portland based consulting ?rm ECONorthwest, only 30 percent of the market actiVity is captured in legal transactions. 20 Supporting this appraisal, 0a a is Production OLCC examined cannabis consumption trends in the state prior to legalization sales, 10.000 R9 xi, =Oennabis and concluded that heavy consumers would Produced remain outside Of the legal market. 21 Figure l: Conquering Potential Annual Production against Potentiai Annual Consunmrion and the Resulting Surplus Cannabis In Oregon, price catalyzes diversion as the state?s abundant crop yields cause the value of licit cannabis to plummet, mirroring basic supply and demand, giving Oregon the cheapest cannabis in the nation (See Map 1). 22?23?24 Oregon?s informal economy offers considerable savings over the legal market and inherent trust Map I: Oregon Relative to National Cannabis Prices 2017 13 Mapes, Jeff. 2015. "Oregon's big marijuana harvests: How do you bring all that put into the legal market?" Oi'egOJIIive?lie Oregonian. May 23. Accessed September 22, 2016. 19 Oregon Department of Agriculture. 2016. "Oregon Agriculture Facts Figures United States Department of Agriculture - National Agricultural Statistics Service. August. Accessed February 3, 20i 7. 20 Hall, Shaun. 2016. "Report: Over-production of medical pot feeds black market in Oregon." Mail Tribune. July 25. Accessod August 7, 2016. impairl 2i Crombie Noelle. 2015. "Heavy Marijuana Consumers Likely to Stay Away from Regulated Retail Market, OLCC Report Concludes." The Oregonian/Oregoniive. February 26. Accessed August 9, 2016 22 Bi, Frank. 2015. "Forbes." All 50 Stores Rmiked by the Cost of Weed (Hint: Oregon Wins). May 12. Accessed April 5, 2016. frankbil20l Si05l1 23 Price of Weed. 2016. Price of Weed. a Global Price Index for Marijuana. Accessed January 3, 2017. 24 Green, Johnny. 2012. ?Why is Oregon Marijuana So Cheap?" The Weed Blog. January 20. Accessed September 2016. oregon-rnarijuana-so-eheapi. 10 forged upon long-term social ties. 5?26 The state?s informal cannabis economy thrives on a surplus of high? quality products and the lucrative pro?ts reaped from a strong external state market. As Dr. Seth Crawford asserts, ?We can?t consume anywhere near what?s produced here. Three to ?ve times what?s Consumed is leaving?here.? 27 Oregon?s overproduction is linked to the state?s distinct cultivation preferences. According to the consulting ?rm ECONorthwest, an estimated 72 percent of Oregon?s cannabis is cultivated outdoors, while 28 percent is cultivated indoors. 28 Data from an OLCC dispensary survey on medical cannabis cultivation methods indicates that in the southwestern region of the state, roughly 32 percent is sourced from outdoor 29 cultivation, which is well above the 7 percent national averageGeographic Projection of OMMP July 2016 Statistical Snapshot 3" Indeed, southwestern Oregon, particularly the counties of Jackson and Josephine, provides amenable environmental conditions for outdoor cannabis cultivation due to soil composition, temperate climate, and altitude. 30 Accordingly, current OMMP information from the Oregon Health Authority (OHA) shoWs a plethora of registered cultivation sites within Oregon?s agricultural breadbasket (See Map 2).31 i 1 25 Priceoncmics. n.d. "The United States of Marijuana Priceouornics. Accessed January 5, 201?. to-bu I. 26 Critwford, Seth S. 2014. "Estimating the Quasi-Underground: Oregon?s Informal Marijuana Economy." Huniboidt Journal ofSociai Relations (36): 132. 2? Hall, Shaun. 2016. Report: Over-production of medical pot feeds black market in Oregon." tI/i?aiir Tribune. July 25. Accessed August 7, 2016. 28 ECONorthwest. 2014. Oregon Cannabis Tax Revenue Estimate. Economic Forecasting, Portland, Oregon: ECONW, 7. 29 Oregon Liquor Control Commission. 2015. "Dispensary Survey Results." Oregangov. Accessed June 30, 2016. commiss ion_minutesi20 SiDispensaryS 3O Olson, Becky. 2015. "Chart of the Week: Cannabis Cultivation Methods in Oregon vs. National Breakdown." Manama Business Daily. June 8. Accessed June 30, 2016. 31 Oregon Health Authority. 2016. he Oregon Medical Marijuana Program Statistical Snapshot July 2016." Oregon Heaith Authority. April. Accessed August 27, 2016. 11 Correspondingly, criminal operating within this space generate signi?cant profit entrepreneurs, by exploiting surplus medical cannabis and clandestinely diverting it For example in 2014, an investigation into two central Oregon residents' operation found evidence of medical cannabis diversion to eastern states, which netted them $200,000 in pro?t. 33 Further analysis indicates that there is an association between OMMP registrants and source diversion counties. 34 When compared to seizure data from the El Paso Intelligence Center (EPIC), geographic concentration of registrants? sites are coilocated with dominant diversion centers, ?Incidents name 25 Number 0! Incidents 20 Girl-1m thereby proximity and shared space are critical features to understanding diversion activities. 35?36 Moreover, the discretionary grower recordkeeping exemption under OMMP is an easily exploited loophole, which renders the program into a conduit for cannabis diversion. 37 Available cannabis seizure data from EPIC, indicates varied but persistent diversion activity. 33 While it is problematic to get direct information on clandestine activities, the extent of diversion activity becomes evident by combining out-of?state seizure I information with estimates of in~state annual crop surplus. 39 500*: mom 450m (991m 1 400w {saan 3501:; {me} some :66er 250a; issib; roots {441m 150v; mm 100 It] (210 501w it: [Bib] on: -2012 an: - 2012 Elm -2013 mama 033 -2?13 49754 -: Girl 2016 on: - 21316 OWE-1015 ?lm-2035 01M 01:1 ?2015 an: 4015 03.3 - 2 011. 334-21311 Girl-2012 01rd 4012 GM -2913 at?! - 2014 20.141 Figure 3: Chronological Trend Calculated Using Normalized Dara?'on: See Technical Appendix i for Normalization Procedures ?7 32 Crombie, Noelle. 2012. "Drug Tra?ickers Exploit Oregon Medical Marijuana Program's Lax Oversight and Loose Rules." OregonLive/ tire Oregonian. September 22. Accessed April 4, 2016. 33 Lerten, Barney. 2014. Redmond 'Medical Grow? a Cover for Shipping Operation." KTVZ. November 1. Accessed January 31, 2017. http:liwmv.ktvz.comi 34 El Paso Intelligence Center. n.d. El Paso Intelligence Center: Accessed June 18, 2016. See Appendix i for technical notes. 35 Ibid 36 Oregon Health Authority. 2016. "The Oregon Medical Marijuana Program Statistical Snapshot July 2016." Oregon Health A lilhorf?i. April. Accessed August 2016. 37 Westfall, Chris. 2016. Oregon Health A nthorily Medical Portland, OR, May 12. 33 El Paso Intelligence Center. n.d. El Paso Intelligence Center. Accessed June 18, 2016. 39 Childress, Michael. 1994.11 System of Description of the Manama Trade. Research Summary, Santa Monica: RAND Corporation - Arroyo Center Drug Policy Research Center: 2. 12 Information from the DEA Domestic Cannabis Eradication and Suppression Program indicates pervasive illicit cannabis cultivation in the state; it is done Without environmental consideration, pushing production far beyond satiation of local demand. 40 While DCEXSP enforcement efforts and subsequent data collection have dwindled since legalization, out-of-state traf?cking continues. 41 Relative to other legalized states, Oregon has a per?capita diversion rate that is comparable to much larger states. Oregon has a per capita diversion rate of 13 events or 180 kg (397 lb) per 100,000 residents; nearly twice that of Washington state (See Table 42 COLORADO 238 (525) 28 5,456,574 486 (1071) 23 39,530,000 OREGON 180 (397) 13 4,028,977 97 (214) 7 7,170,351 Table 1: Selected States Ranked by per captla Diversion Rate; Calculated rising EPIC data 2006 to 20.16 Despite having a relatively small population, Oregon outpaces Washington and has been the con?rmed source of 5,177 kg (11,413 lb) of highway cannabis diversion alone.43 This provides a strong indication that surplus cannabis is not discarded, but is in fact traf?cked out?Of?state and sold for a huge pro?t margin. 44 Oregon shares signi?cant diversion destinations with other established cannabis production states such as Colorado, Northern California, and Washington. 45 Seizure data portrays consistent traf?cking activity among legalized West Coast States heading to destinations in the Eastern United States. 46"? Distribution of Contraband Subsets- Oregon Figure 4: Distribution of Cannabis Contraband Subsets, EPIC 2006 to 2016 40 Drug Enforcement Administration (DEA). 2016. "Oregon Domestic Cannabis Eradication and Suppression Program DEA. Accessed September 25, 2016. 41 E1 Pasc Intelligence Center. n.d. El Paso Intelligence Center. Accessed one 18, 2016. 42 E1 Paso Center. n.d. El Pam Intelligence Center. Accessed June 18, 2016. See technical appendix i for anaiytic methodology used to nonnaiize data and caiculate per eaptta rate. 43 Ibid 44 Noelle. 2012. "Drug Traf?ckers Exploit Oregon Medical Marijuana Program?s Lax Oversight and Loose Ru1es." Oregonlee/ (he Oregonian September 22. Accessed Aprii 4, 2016. 45 El Paso Intelligence Center. n.d. El Paso Intelligence Center. Accessed June 18, 2016. 46 Maben, Scott. 2013. "Interstate 90 a Major Route for Traf?ckers Heading East." The Spokesman - Revlew. January 6. Accessed August 17, 2016. http:ll 4? E1 Paso Intelligence Center. n.d. El Paso Intelligence Center. Accessed June 18, 2016. 13 A review of Oregon interdiction data indicates diversion destinations across the continental United States, Alaska, and British Columbia. For Oregon, the Dominant Diversion Counties (DDCs) of Jackson, Muitnomah, Josephine, Lane, Deschutes, and Washington (listed in descending order), lead the way 1 The most frequent destinations for cannabis originating from the DDCs include Illinois, Minnesota, New York, Connecticut, Florida, Georgia, Wisconsin, and Idaho; an additional evidence that external demand fuels diversion. 50 Additionally New Economy Consulting, which monitors cannabis in Oregon estimates that nearly 80 percent of the state?s cannabis ends up leaving for the East Coasts! This estimate parallels Seizure data, which shows concentrations of diversion aetivity in the Mid?West and along the Eastern Seaboard. 52 Wholesale prices. 4 in illicit exportation of cannabis (See Map 3). 48 Collectively, over the course of ten years these counties have been the con?rmed source for 3,912 kg (8,625 lb) of diverted cannabis, conservatively valued between $13,440,625 to $19,292,961 at West Coast 9 i. Uni-Ha mm Importantly, Lane and Multnomah counties are connected to nearly half of all destinations (See Map 4). 53 Deeper review indicates the cities Portland, Eugene, Medford, and Grants Pass have the greatest level of connection to diversion destinations. 54 In closing, law enforcement is unable to keep pace with out~of~state cannabis diversion. 55 Cannabis legalization has not eliminated the black market, rather it has changed Oregon's established informal economy. Evidence indicates US. based cannabis traf?cking networks have replaced transnational cartel operations. Now, there are 48 El Paso Intelligence Center. n.d. El Paso Intelligence Center: Accessed June 18, 2016. 49 Cannabis Benchmarks. 20 i6. Carmelita Benchmarks: Weekly Repair. October 21. Accessed October 26, 2016. 50 Ibid 51 Ellis, James. 2016. "Pet is Still Lighting up the Black Market.? Newsweek. February i4. Accessed September 26, 2016. market-424706. 52 El Paso Inteliigence Center. n.d. Pare birellr?gence Center. Accessed June 18, 2016. 53 Ibid For network analysis used to caiculate centrality see appendix ii. 54 Ibid 55 Ibid For network analysis used to calculate centrality see appendix ii. 14 Map 4: Mixed Methods Geographic Projection of Durersion Activity Composed Using Degree Centr'aiiajr, i/olnrne, and Frequency 53 indications that some are working within the informal economy to circumvent the regulated market to preserve their market share. 56 In fact, various social media and online forums have sprung up to provide guidance on how to avoid the regulated market. 57 Thus, the reality of legalization is that it has provided an effective means to launder cannabis products and proceeds, where in essence, actors can exploit legal mechanisms to obscure products? origin and conceal true pro?ts, thereby blurring the boundaries of the legal market and complicating enforcement efforts. The illicit exportation of cannabis must be stemmed as it undermines the spirit of the law and the integrity of the legal market. 53 Crime, especially large scale underground trade, is dif?cult to measure and consequently, 59 distorts economic data and, complicates governance over economic issues. Indeed, there are tangible negative socioeconomic effects from cannabis diversion, paramount among them is that as a form of illicit trade it steals economic power from the market, the government, and the citizens of Oregon, and furnishes it to criminals, thereby tarnishing state compliance efforts. 60 56 James, Tom. 2016. "The Failed Promise of Legal Pot." Tlre Atlantic. May 9. Accessed September 26, 2016. 6i05l i 506i Davis, Steve. 2016. "Black Market Marijuana Growing Success Secrets Br?ands: Grow Yonr Best Manjnana Ever! Accessed September 26, 2016. http:/l 58 McDowell, John, and Gary Novis. 2001. "The Consequences of Money Laundering and Financial Crime." Economic Perspectives - An Electronic Journal ofrlre US. Department of State 643. 59 Quirk, Peter J. 1997. "Money Laundering: Muddying the Macroeconomy." International Monrary Fond. March. Accessed September 26, 2016. 99?i03lpdfiquirk.pdf. 60 McDowell, John, and Gary Novis. 2001. "The Consequences of Money Laundering and Financial Crime. Economic Perspectives - An Electronic Journal ofrhe US. Department of State 6-8. 15 State Compliance on Cannabis Distribution to Minors and Associated Adverse Public Health Consequences Executive Summary and Purpose The focal points of this section are derived from the federal guidance, issued by former DOJ Deputy Attorney General James M. Cole, on Preventing the distribution of marijuana to minors Preventing drugged driving and the exacerbation of other adverse public heaith consequences associated with marijuana use 1 To this end, this section examines impaired driving rates, treatment and associated ?nancial fallout ?om cannabis extraction, and use rates and methods by which minors acquire cannabis in the post?legalization period. Strategic Findings 1' Historically, an annual average of two percent of Oregon?s traf?c fatalities were associated solely with cannabis; this rate has not changed signi?cantly since legalization. - As of 2015, 60 percent of 11th graders reported that acquiring cannabis was ?easy?. a The cost and rate of cannabis extraction burn victims has increased substantially since legalization, with $7.6 million in federal government entitlement programs used to cover the cost of treatment. 0 Currently, 63 percent of Oregon drivers do not know when it is legal to drive?after using cannabis. Males 16 to 28 are a high?risk demographic for cannabis impaired driving and account for the majority of the activity in the state. 1 Cole, James M. 2014. "Guidance Regarding Marijuana Financia! Crimes." US. Department February 14. Accessed September 26, 2016. mvw. justice. 16 2 Association of Oregon Counties. 2016. "Selected Oregon Marijuana Laws." A 0C Mar?rrana. Aprii 5. Accessed September 26, 20t6. littgs?drivc. gong Eecomr?f'ilef dJr?OB94vanCLr-19 9. 3 Oxford Dictionary. 2016. English Oxford Living Dictionaries. Accessed September 26, 2016. 4 Association of Oregon Counties. 2016. Selected Oregon Marijuana laws.? AOC Marijuana. April 5. Accessed September 26, 2016. 5 Oxford English Living Dictionary. 2016. Oxford Dictionaries. Accessed October 26, 2016. 6 Hartman, Rebecca L, and Marilyn A Huestis. 2013. "Cannabis Effects on Driving Skills." Clinical Chemistry 479. 7 Dilley, M.E.S., Julia, Caisiin Firth, M.P.H., Erik Everson, M.P.H., and Julie Maher, 2016. "Marijuana Use, Attitudes and Health Effects in Oregon." Marijuana Report (Oregon Health Authority - Oregon Public Health Division): 3. 8 Rahn, Bailey. 2016. "Terpenes: The Flavors of Cannabis Aromatherapy." Leq?y. Accessed October 27, 2016. Ollterpenes- 9 European Monitoring Centre for Drugs and Drug Addiction. 2017. Cramabis Pro?le. Lisbon, Portugal, January 27. 17 ?Why has government been instituted at alt? Because the passions of man will not conform to the dictates of reason and justice without constraint. -Alexander Hamilton Cannabis Related Acute Public Health Threats After legalization, Oregon?s adult cannabis use rate remains higher than the national average, but has not changed signi?cantly. Additionally, the percentage of Oregonians who have tried cannabis did not change signi?cantly between 2014 and 2015 among any age group. 12 However, since legalization there has been a signi?cant increase in the level of consumption among current adult cannabis users from 29 percent in 2014 to 36 percent in 2015. 13 Data from a 2016 state survey supports this trend indicating that about 28 percent of adults self-reported more frequent cannabis use since legalization. 14 Although cannabis use is related to less than one percent of total Emergency Department (ED) visits, there has been a notable rise since legalization in the number of ED cannabis-involved visits (See Figure 1). 15Independent of changes in user rates, certain activities and actions related to cannabis use pose a hazard to public health and safety. Paramount among these are cannabis impaired driving, explosions and burns caused ??om cannabinoid extraction, and the use of cannabis products by minors. 17? 13? ?9 10 Hamilton, Alexander. 1787. "De?ciencies of the Confederation." The Founders? Constitution. December 1. Accessed January 30, 2017. ll Diliey, M.E.S., Julia, Caisiin Firth, M.P.H., Erik Everson, MPH, and Julie Matter, 2016. "Marijuana Use, Attitudes and Health Effects in Oregon.? Marijuana Report [Oregon Health Authority - Oregon Public Health Division) 1-89 NEED PAGE. 12 Ibid 13 Ibid 14 The Oregon Public Health Division. 20i6. "Prevention Panei Survey, Health Prevention Chronic Disease Prevention Section. Oregon Health Authority, October. 15 Dilley, M.E.S., Julia, Caislin Firth, M.P.H., Erik Everson, M.P.H., and Julie Maher, 2016. "Marijuana Use, Attitudes and Health Effects in Oregon." Marijuana Report (Oregon Health Authority - Oregon Public Health Division): vii . 16 Black, Bobby. 2015. "To Dab or Not to Dab?" High Times. January 2. Accessed October 21, 2016. 1? Chang, Hetty. 2015. "Danger Next Door: Butane Honey Oil "Fires Off Like a Bomb"." NBC Los Angetes. Aprii 23. Accessed October 21, 2016. http:ti. .html. 18 Compton, Richard P, and Amy Berning. 2015. Drug and A (coho! Crush Risk. Summary of Behavioral Safety Research, Washing DC: Nationai Highway Traffic Safety Administration (NHTSA) U.S. Department of Transportation. 19 Centers for Disease Control and Prevention. 2016. Impaired Driving: Get the Facts. April 15. Accessed October 21, 2016. 18 Mar-Dec 2015 1.00% 0.50% CI 40% Cl. 00% Total Cannabis Related 5,431: Mar-Der; 2015 Jan-Sap 2016 Cannabis?Related Emergency Department Vlsits March 2015 to September 2016 JaneSep 2016 3,532 To! a! Canaath irritated Figure I Cannabis Related Emergency Department Visits 201' 5 to 2016 as Reported by the Oregon Health Authority Cannabis impaired driving remains a persistent threat to Oregon. Operating a motor vehicle in Oregon is an activity inherently fraught with risk, impaired, distracted, or not, and the state has annually had roughly 5 deaths per 100,000 people (approximately half that of the national average), mostly related to alcohol (See Map 1). 20?21?22 Cannabis impedes reaction time, perception, attention, motor skills, tracking, and skilled activities, all which are fundamental to safe driving. 23. Indeed, the architecture of the brain as it relates to tetrahydrocannabinal (THC) is integral to understanding cannabis impairment. Thee areas of the brain that have the highest density of (:31 receptors (cannabinoid receptors), sites Where THC can bond to the brain, include locations responsible for motor coordination, sensory perception, and those tasked with interpreting impulses from the body; essential to operating a vehicle. 24? 25 Additionally, THC has been shown to diminish executive functions, which are used to prioritize external stimuli and environmental activities( See Table 1). 26?? 20 Centers for Disease Control and Prevention 2012. Prevention and Control: Motor Vehicie Safety. Accessed October 12, 2016. motorvehiclesaf etyistatesioccu pan t_death_rate.html . 21 National Highway Traffic Safety Administration. n.d. Fataiity Arrobrsis Reporting (FA RS). Accessed June 16, 2016. http:itmvw.nhtsa.goviFARS. 2004 to 2014. Fatatity Analysis Reporting Engictopedia. 22 Insurance Institute for Highway Safety Highway Loss Data Institute. 2015. "General Statistics." HHS HLDI. Accessed December 21, 2016. http:iiww.iihs.orgt 23 Hartman, Rebecca L, and Marilyn A Huestis. 2013. "Cannabis Effects on Driving Skilis." Clinical Chemistry 479 24 National Institute on Drug Abuse . 2016. of A ctr'orr. October 13. Accessed October 13, 2016. 25 Mackie, K. 2008. "Cannabinoid Receptors: Where Are They and What They Do." Jorrmai of 1365-2826. 26 Diamond, Adele. 2013. "Executive Functions." Annual Review of Psyciroiogy 135-168. 27 Green, Rebecca D, Susan Tapert, Arpi Minassian, Kai MacDonald, Natania A Crane, and Barbara Mason. 2012. "Effects of Chronic, Heavy Cannabis Use on Executive Functions." ofA ddierive Medicine 9-15. 19 Map 1: Geographfc Projection of Substance Involved Fara! Crashes 201'0 to 20} 5 I Adverse Effects of Shm't?Term Cannabis Use and Long-Term Cannabis Use Table I: Smumarj) ofthe Shor?f?Term and Long-Emmi ofCannabe Use 23 Blanca, Caries MD, Deborah S. Hasin, Melanie M. Wall, Ludwig MD Florez-Salamanca, Nicolas MD, MPH Hoertel, Shuai Wang, Bradley T. Kerridge, and Mark MD, MPH Offson. 2016. "Cannabis Use and Risk of Disorders: Prospective Evidence from a US National Longitudinat Study. JA MA 388-395. 20 The available epidemiological evidence on cannabis intoxication strongly suggests that users who drive while impaired increase their risk of motor vehicle crashes 2-3 times. 29? 30?? Contributing to these rates, evidence suggests that light users experience heightened driver impairment compared to heavier users. 32 Information from Oregon Health Authority indicates that between 21 to 34 percent of adult users drove within 3 hours of using cannabis and 63 percent of Oregon adults do not know when it is legal to drive after using cannabis. 33? 34 According to data from the National Highway Traf?c Safety Administration (NHTSA), between 2010 and 2015, Oregon drivers who tested positive for cannabis were involved in an average of six fatal crashes annually; this trend has persisted post- legalization. 35 However, collection gaps exist, as nearly one third of fatal crashes in the state are not subject to toxicology screening (See Figure 2). 36 Average Distribution of Substances in Traffic Fatalities 2010 to 2015 Drug/Noemi Free 7.5% Ca nnabie Only (Ma to Driver) Cannabis Oniy (Female Driver) 0-3% Figure 2: Average Distribution imroived in Fatal Crashes 201 0 {o 20} 5 from FARS 35 29 Cerda, Magdalena, Terrie E. Mof?tt, Madeline H. Meier, HonaLee Harrington, Renate Hoots, Sandhya Ramrakha, Sean Hogan, Richie Poulton, and Avshaiom Caspi. 2016. Persistent Cannabis Dependence and A icohoi Dependence Represents Risksfor?Midiife Economic and Social Pr'obierns: A Longitudinai Cohort Study. Empirical Article, Association for Science. 30 Hall, Wayne. 20 14. "What has Research over the past taro decades Reveaied about the Adverse Health Effects of Recreational Cannabis Use?" Society for the Sum)? of Addiction 21. 31 Volkow, Nora D, Ruben Baier, Wilson Compton, and Susan Weiss. 2014. "Adverse Health Effects of Marijuana Use." New EngiandJanrnai of Medicine 22194227. 32 Hartman, Rebecca L, and Marilyn A Huestis. 2013. "Cannabis Effects on Driving Skills." Clinical Chemistry 490. 33 Diiley, M.E.S., Julia, Caisiin Firth, M.P.H., Erik Everson, M.P.H., and Julie Maher, 2016. "Marijuana use, attitudes and health effects in Oregon." Mar?n'nana Report (Oregon Heaith Authority - Oregon Public Health Division) 48. 34 Dilley, Phil, M.E.S., Julia, Caislin Firth, M.P.H., Erik Everson, M.P.H., and Julie Mailer, 2016. "Marijuana Use, Attitudes and Heaitli Effects in Oregon.? Marijuana Report (Oregon Heaith Authority Oregon Public Health Division): 1-39. 35 Nationai Highway Traf?c Safety Administration. n.d. Familiar A naiysis Repairing Sysrern (FA RS). Accessed October 23, 2016. 2004 to 2014. Faraiinr Anabrsis Reporting System Enqmiopedia Accessed June 16, 2016. 36 Tef?, Brian C, Lindsay Arnold, and Jurek Grabowski. 2016. Prevalence ofMar'n'rrana involvement in Farai Crashes: Washington 2014. Meta-Anaiysis Report, Washington DC: Foundation for Traffic Safety: 5. 21 Nevertheless, studies indicate that after alcohol, cannabis is the most common recreational drug found in dead or injured drivers and data from 2010 through 2015 indicates that more than half of Oregon?s cannabis by of Driver related fatalities involve cannabis and another substance. 37? 38 This is not surprising given regular cannabis users possess a higher probability for alcohol, tobacco, and illicit narcotics use, and are found to have 12000 a higher propensity for risk?taking behavior. 39 Nationally, the largest segment of cannabis users share demographic characteristics with risk-taking males 18 10000 to 25, who also have a high drunk driving incidence.? i ??42 As an illustration of this tendency, statistics from Oregon Department of Transportation in 2014 indicate 3000 that nearly 16 percent of all crashes in 2012 involved drivers aged 15 to 20 (See Figure 3). 43 Available Fatality Analysis Reporting System (PARS) data 6000 indicates that in Oregon, drivers in cannabis-related fatalities are predominantly male (see Figure 4). 44 g? waxinwlvea 403? 2010 to 2015 15 . 10 0 5 0 who; 2010 2011 2012 2013 2014 2015 Figure 3: 2012 Distribution of Age in Crashes Oregon Department of Transportation 4? Men Women Figure 4: Distribntion by Gender of DriVers Involved in Fara? Crashes 20ft? to 2015 3? National Highway Traf?c Safety Administration. 2004 to 2014. Forcing: Anabisis Repairing System Accessed June 16, 2016. 38 Agic, Branka, Gina Stoduto, Gillian Sayer, Anca Ialoniiteanu, Christine Wickens, Robert Mann, Bernard LeFoli, and Bruna Brands. 2013. Characteristics of Peopie who Report Both Driving a?er Drinking and Driving afier Cannabis Use. Medical Research Report, Toronto, Canada: Center for Addiction and Mental Health, Toronto, Canada: 1. 39 Hall, Wayne. 2014. "What has Research over the past two decades Revealed about the Adverse Heaith Effects of Recreationai Cannabis Use?" Society for the Stnajv of Addiction 22. 40 Lacey, John H, Tara Kelly-Baker, Debia arr-Holden, Robert Voas, Eduardo Romano, Anthoney Ramirez, Katharine Brainard, Christine Moore, Pedro Torres, and Amy Berning. 2009. 2007 Nationoi Roadside Survey of A t'cohoi and Drug Use by Drivers. Technical Report, Washington DC: Nationai Highway Traffic Safety Administration. 41 Hartman, Rebecca L, and Marilyn A Huestis. 2013. ?Cannabis Effects on Driving Skilis.? Ciinieal Cheiitistty 479. 42 Substance Abuse and Mental Health Services Administration. 2004 to 2014. National Survey On Drug Use and Heaitii (NSDUHD. Accessed October 2016. 35 i 7. 43 Oregon Department of Transportation (ODOT). 2015. 2014 Oregon Motor Vehicie Traf?c Crashes Quick Facts. Technical Summary, Salem: ODOT. 44 37 National Highway Traf?c Safety Administration. 2004 to 2014. Fatality A naiysis Reporting System Accessed June 16, 2016. http?mvw? 22 Since THC is roughly associated with a doubled crash risk enforcement requires accurate detection, though the polydrug use of cannabis poses a challenge. 45? 4?3 Statewide rates of Drug Recognition I Expert (DRE) Examinations remain high while cannabis related fatalities have been low (See Figure 5). Furthermore, DRE data from 2013 to 2015 indicates that the majority of cases related to cannabis impairment involved under-aged users, who are in a particularly vulnerable stage of brain development (See Figure 6). 43? 49 Oregon Cannabis Involved Traffic Incidents DRE Evalutions vs Fatalities 2011 - 2015 2011-2015 0 i300 1000 1500 2000 2500 3000 3500 ignre 5: Comparative Distribution of Cannabis Invoivea? DRE Eraminarions and Cannabis Related Farai Crashes 2011' to 2015 i? Cannabis Related DRE Examinations by Age and Brain Development Stages 2013 to 2015 .150 1.DRE Exams Pit-2' Frontal Cortex Developing ignre 6: DRE Examinations Distribution 2013 to 2015 Broken out by Age Group and Brain Development Stages Developed w?LegaIAge ?-UnderAged 54.55 45 Hartman, Rebecca L, Jack Richrnan, Charles Hayes, and Marilyn A Huestis. 2016. Drug Recognition Expert (DRE) Examination Characteristics of Cannabis Impairment. Accident Anaiysis and Prevention 220. 46 Asbridge, Mark, Jill Hayden, and Jennifer Cartwright. 2012. "Acute Cannabis Consumption and Motor Vehicle Collusion Risk: A Systematic Review of Observa- tionai Studies." The BMJ344-536. 47 Oregon State Police. 2010 to 2015. Drug Recognition Expert Examinations." OSP. 431bid 49 Jackson, Nicholas 1, Joshua Isen, Rubin Khoddam, Daniel irons, Catherine Tuvbiad, Wiliiarn Iacono, Matt McGue, Adrian Raine, and Laura A Baker. 2016. "Impact of Adolescent Marijuana use on Inteiligence: Results from Two Longitudinal Twin Studies." Proceedings of {he Narionai A cademy of Sciences E508. 23 In spite of overwhelming empirical evidence to the contrary, most cannabis users believe they are able to compensate for performance decrements while driving, which renders education ineffective. 50?? Currently the state does not have a per se limit (a set legal threshold) for cannabis impairment, making DRE examinations all the more critical to combating DUIC and minimizing the associated traf?c fatalities. Arguably, consideration could be given to adopting zero?tolerance policy towards young driver and novice drivers when it comes to THC. 52? 53 While DUIC remains a persistent problem, the illicit production of cannabis extracts and concentrates presents a complex emergent threat. 54?55 These novel cannabis substances pose a two-fold threat for public health and safety as they not only possess all of the same adverse health effects of cannabis, but their manufacture is innately dangerous. 56?? Here again the catalyzing effect of lucrative pro?ts on the Eastern Seaboard drive in-state manufacturing.58 These substances are particularly suitable for out?of?state smuggling, since concentrates can be virtually odorless, unlike plant material, and are more easily concealed. 59 These cannabis substances are made by forcing butane, or another petroleum based solvent, into a reaction chamber with cannabis, which results in a liquid mixture of cannabis and solvent. 60?61?62This process yields a highly potent, 70 to 90 percent pure THC, semi-liquid mixture of THC and solvent that can be further re?ned. Among the most common cannabis concentrates is what has come to be known as ?Butane Hash Oil? or ?Butane Honey 0i!? (BI-10). '53 Often, the process takes place in an enclosed area, resulting in the solvent silently ?lling the space. Once exposed to an ignition source, the solvent violently explodes, burning and maiming anyone in its path (See Image 1 and Image 2). 64 50 Hartman, Rebecca L, and Marilyn A Huestis. 2013. "Cannabis Effects on Driving Skills." Clinical Chemistry 489. 51 Terry, P, and K.A. Wright. 2005. "Self-Reported Driving Behaviour and Attitudes Towards Driving Under the In?uence of Cannabis Among Three Different User Groups in England." Addictive Behaviors 619-626. -52 Logan, Barry Sherri Kacinko, and Douglas Beirness. 2016. An Evaluation of Data from Drivers Arrested for Driving Under the In?uence in Relation to Per Se Limits for Cannabis. Research Report, Washington DC: Foundation for Traffic Safety. 53 Hall, Wayne. 2014. "What has Research over the past two decades Revealed about the Adverse Health Effects of Recreational Cannabis Use?" Society for the Study of Addiction 19. 54 Crornbie, Noelle. 2016. "Blast Rocks Legal Marijuana Business in Astoria, sends 2 to Burn Unit." The OregonianlOregonlive. October 20. Accessed October 26, 2016. 6f1 55 Hallett, Alison. 2013. "How Hash Oil is Blowing Up Across the US. - Literally. Wired. February 20. Accessed October 26, 2016. 56 Horey, Jonathan. 2016. "The Dangers of Dabbing: The Health Risks Posed by the Latest Marijuana Trend." The Hrrf?ngron Post. August 12. Accessed October 27, 2016. 5? Romanowski, Kathleen MD, Alura FNP-C Barsun, Peter MD Kwan, Esther MD Tee, Tina MD, FACS, FCCM Palmieri, Soman MD, FACS Sen, Pirko MD, FACS Maguina, and David MD, FACS Greenhalgh. 2016. Bunnie Hash 0ft BumssA 7-Year Perspecri?Ve on a Growing Problem. Medical Report, Sacramento: American Burn Association: 1. 58 Jackson, Tom. 2015. "?Shatter,? Super-High Potency Pot, Now Appearing on East-Coast." Chicago Tribune. December 23. Accessed October 27, 2016. 5 59 Rubio, James. 2015. Does Vaping Really Smell? (Plus, Sneaky Ways to Deal with Vape Odor). May 25. Accessed October 23, 2016. does-vaping-realIy-smell- plu s- sneaky-\vays-to -deal -\vith-vape-o dorr' 60 Seattle Cannabis Co. 2015. ?Cannabis Concentrates - Oils, Wax, Hash and More." Sear?e Cmmabr?s Co. February 1. Accessed October 27, 2016. http? 6i Grasscity Forums. 2016. How to Make BBC to Pass Testing. Really Nice WaXIShatter. August 1 l. Accessed October 27, 2016. 122034}. 62 Abad-Santos, Alexander. 2013. "The Amateur's Guide to Dabs. The Atlantic. May 13. Accessed October 26, 2016. archivef20 I 5221!. 63 Seattle Cannabis Co. 2015. "Cannabis Concentrates Oils, Wax, Hash and More." Cannabis Co. February 1. Accessed October 27, 2016. 64 Ryan, Jim. 2017. "Fire?ghters Find BHO Lab inside Burned Oregon City Building." The OregonianIOregonLive. January 6. Accessed January 23, 2017. 24 Image 1 and Image 2: Damage ??om Ciandestr?ne 8H0 Lab in Oregon City, 201 7 6" Notwithstanding the relative safety of the professional systems compared to the ad-hoc apparatuses, both have been the cause of deadly explosions and ?ash ?res across Oregon, making the clandestine BHO lab arguably the most immediate cannabis threat facing the state. 6'5 Even professional out?ts experience catastrophic failures as was the case in Astoria in October 2016.66 Additionally, Aside from production hazards, the resulting substance contains high concentrations of THC that can exaggerate recognized adverse 67, 68 effeCtS' Oregon Bum Center Victims with Cost Unfortunately, the manufacture of cannabinoid concentrates has BHO uwon become widespread, and if escalation continues unimpeded, the incidence gr?? 109000 of BHO labs may approach the level of the methamphetamine lab epidemic that the state once faced. According to information from the Oregon Burn Center (OBC), there were at least 30 con?rmed burn victims between July 2015 to July 2016 alone, costing the center $5,154,202 to treat. ?59 Further analysis indicates the rate of victims has increased substantially since recreational cannabis was legalized, 5 the majority of which were covered under Medicaid and Medicare (See Figure 8 and Figure 9). 70 July 1. 2015 igw?e 8: Visual Comparison Related Bum Victims Recreational Use Legailzed with Cos! March 203 to Jury 2016 ?3 65 Crombie, Noelle. 2014. "Butane Hash Oil: A Quick and Powerful Marijuana High Feeds Demand, but Home Manufacturing Leads to Explosions." The Orego? nianfOregonLive. May 12. Accessed October 27, 2016. .html. 66 Crombie, Noelle. 2016. "Blast Rocks Legal Marijuana Business in Astoria, Sends 2 to Burn Unit." The OregonianfOregonlive. October 20. Accessed October 26, 2016. 6/1 6? Weinberg, 801.2014. "Hash Oil Explosions in the News. Global Gary?aReporr. May 3. Accessed October 27, 2016. 68 Horey, Jonathan. 2016. "The Dangers of Dabbing: The Health Risks Posed by the Latest Marijuana Trend." The Hrg?fr?ngton Post. August 12. Accessed October 20 i 6. 1391686.html 69 Legacy Oregon Burn Center. 2013~2016. Burn Victims." Legacy Emanuel Oregon Burn Center. Accessed 2016. 70 Ibid 25 Insurance Status 8: Cost for BHO Burn Victims 2013 - 2016 Pending or Uncovered $31,531 Other Government. $92,974 No Fault Auto Self Pay/Uninsured $5.676 $799,301 Figm?c 9: Insurance rains and Cost of Treatmenrfor Initial Admission of Oregon Burn Center for BHO Related Bums ?3 On average, a BHO burn victim costs $192,922 for initial treatment, spending 15 days in the hospital and 13 days in the intensive care unit. Typically, the victims are males near the age of 29 who have an average of 22 percent of their bodies burnt. These characteristics are consistent with ?ndings from the University of California Davis Burn Center on BBQ burns, which found that most of the patients were males with a mean age of 29 who had sustained a mean Total Burn Surface Area (TBSA) of 24.1 to 26.8 percent. (See igurc 9). Unlike DUIC rates, the frequency of BHO operation explosions has increased substantially since recreational cannabis legalization, resulting in dozens of victims. Consequently, the unconventional production of cannabis concentrates poses an evident threat to the public health and safety of Oregonians. 71 Ibid 72 Romanowski, Kathleen MD, Alura FNP-C Barsun, Peter MD Kwan, Esther MD Tee, Tina MD, FACS, FCCM Palmieri, Somali MD, FACS Sen, Pirko MD, FACS Maguina, and David MD, FACS Greenhalgh. 2016. Butane Hash Oil Barns: A 7-Year Perspective on a Growing Problem. Medical Report, Sacramento: American Barn Association: 2. 73 Legacy Oregon Burn Center. 2013-2016. Burn Victims." Legacy Emanuel Oregon Burn Center. Accessed 2016. 26 Preventing the distribution of cannabis to minors is a threat that is more complex and nuanced than those discussed above. Prior to legalization, the rate of cannabis use in the state was higher than the national average among adults (26 and older) and young adults (18 to 25). Data from the Oregon Behavioral Risk Factor Surveillance indicates that since legalization there has not been a signi?cant change in the rates of use System among adults. 74 Concurrently, according to Oregon Student Wellness Survey (OSWS), there have not been notable changes in use frequency among Oregon?s 8th and ll?h graders between 2014 and 2016, as they remain higher than the national average. 75 Yet, according to the 2016 OSWS, 11th graders in Oregon reported that acquiring cannabis would be easier than cigarettes. 76 Interestingly, since legalization there has not been a signi?cant shift in cannabis risk perception among 8th and 11th graders, with nearly 39 percent of 11th graders and 59 percent of 8th graders reporting they were at ?moderate?to-great? risk of harming themselves from cannabis. 7? Speci?cally, OSWS data indicates the risk perception of weekly cannabis use decreased among both 8th and 11th graders, although the change was not statistically signi?cant (See Figure 10. 78 Additional information from the 2015 Oregon Healthy Teens Survey (OHTS) indicates that current cannabis use among 8th and than current cigarette use, but lower than alcohol use. 79 OSWS information indicates that higher ?equency use, de?ned as a more than 40 times a month, is more common among 11?11 graders than 8th graders. 80 graders was higher 100% 90% 80% 70% 60% 0 50?6 Felt 2014 40% 2016 308th 11th ignre 10: Risk Perception among and Jim Graders 2014 (o 2016 about Weeka Cannabis Use 74 Dilley, M.E.S., Julia, Caislin Firth, M.P.H., Erik Everson, MPH, and Julie Mailer, 2016. "Marijuana use, attitudes and health effects in Oregon." Marijuana Report (Oregon Health Authority - Oregon Public Heaith Division) 22. 75 Ibid NEED PAGE. 76 Oregon Heaith Authority. 2016. 2016 Oregon Strident Survey. Annual Public Health Survey Results, Portland: Oregon Health Authority. 77 ibid 78 Dilley, Phil, MES, Julia, Caislin Firth, M.P.H., Erik Everson, M.P.H., and Juiie Mailer, 2016. "Marijuana use, attitudes and health effects in Oregon." Marijuana Report (Oregon Health Authority - Oregon Public Health Division): 41. 79 Ibid: 28-29. 80 Oregon Health Authority. 2016. 2016 Oregon Student Weiiness Survey. Annual Public Health Survey Results, Portland: Oregon Health Authority. 27 Tempering social norms to reduce cannabis use among the youth is dif?cult to accomplish solely through policing practices. Yet, according to research published in the Case Western Reserve Law Review a threat of criminal risk suf?cient to deter youth from attempting to access,? remains a feasible part of an enforcement model. 81 In this context, deterring illicit cannabis distribution would require consistent application of sanctions. 32 Successful deterrence strategy within the legal marketplace. hinges upon severe and swift license penalties for selling to minors should rapidly escalate to license revocation. 33 Within the informal economy, standard counter-narcotics techniques can be used against the peer-to-peer acquisition of cannabis among minors. Targeting these mechanics would likely prove effective as data from the National Survey on Drug Use and Health (N SDUH) indicates a signi?cant portion of younger users acquire cannabis through trade or purchase from friends, i.e. through localized distribution networks (See Figure 0% 10% 20% 30% 40% 50% 60% 80% 90% 100% "Till I Purchased Me?md 40.3 Sou rce Free from Friend Bought from Family- 10-80% 1.64% Free from Stranger 2.27% Bought from Stranger Free from Family 6.96% 0.63% Figure 1! Sources and Methods of Obtaining Cannabis among Ages 12 through 20, raken??om National Data Provided by NSDUH 34 81 Davenport, Steven, Jonathan Caulkins, and Mark AR. Kleiman. 2015. "Controlling Underage Access to Legal Cannabis." Care Western Reserve Law Review: 556. 821bid: 560. 33 ibid 84 Substance Abuse and Mental Health Services Administration. 2004 to 2014. National Survey 0n Ding Use and Heath}: (NSDUH). Accessed October 2016. dataflles 35 28 The immediate acute health effects reviewed above challenge Oregon?s public health and safety, but there are also threats that have yet to arise from long-term cannabis use among vulnerable age groups. According to an article published in the Journal of the American Medical Association, ?Use of increases the likelihood of use of other substances and the risk of abuse or dependence on those substances.? 85 Since smoking and alcohol use are, respectively, the ?rst and third leading causes of preventable death in the nation, recognizing the association of substance abuse disorders with cannabis is key to the preservation of public health. 86 Additionally, recently published ?ndings demonstrate that long-term cannabis dependence is ?more strongly linked to ?nancial difficulties? than alcohol dependence. 87 In closing, cannabis use and availability pose multiple distinct threats to the health and well-being of Oregonians, which ought to be monitored throughout the state to ensure compliance with the existing federal guidance. 85 Bianca, Carlos MD, Deborah S. Hasin, Melanie M. Wail, Ludwig MD Fiorez~Salamanca, Nicolas MD, MPH I-Ioertel, Shuai Wang, Bradley T. Kerridge, and Mark MD, MPH Olfson. 2016. "Cannabis Use and Risk of Disorders: Prospective Evidence from a US National Longitudinal Study.? JA MA 393. 86 Mokdad, AH, JS Marks, DF Stroup, and JL Gemerding. 2004. "Actual Causes of Death in the United States, 2000." JA MA 1238~1245. 87 Cerda, Magdalena, Terrie E. Mof?tt, Madeiine H. Meier, I-IonaLee Harrington, Renate Houts, Sandhya Ramrakha, Sean Hogan, Richie Poulton, and Avshaiorn Caspi. 2016. Persistent Cmrrabr?s Dependence and A [cabal Dependence Represents Risksfor' Mr'dhfe and Social A Cohort Study. Empirical Article, Association for Science: 15. 29 State Compliance on the Growing of Cannabis on Public Lands and the Attendant Public Safety and Environmental Dangers Executive Summary and Purpose The focal points of this section are derived from the federal guidance, issued by former DOJ Deputy Attorney General James M. Cole, on - - Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands 1 To this end, this section provides anexamination of current illicit cultivation on public lands in Oregon and details research on the environmental impact of this activity. Strategic Findings - To date, legalization has not affected the rate of illicit cannabis cultivation on public land. The Illinois, Applegate, and combined Rogue Watersheds are particularly vulnerable to environmental damage from illicit cannabis grow sites. - Illicit cannabis grows have consumed 1.04 billion gallons of water since 2004 and consume roughly 442,200 gallons of water daily during the growth season. 0 Eradication and enforcement efforts have a high return on investment; an average of 1,040.38 dollars? worth of illicit cannabis is returned for every dollar spent 1 Cole, James M. 2014. "Guidance Regarding Marijuana Financial Crimes." US. Depan?menr of ?rsrice. February 14. Accessed September 26, 2016. mvaustice.govlsitesldefaultl? ieslusao?\vdwallegacyl20 1 4:02! i 20Crimes%202%201 4%20 4%20%282%29.pdf. 30 ?The earth provides enough to satis?z every man. is needs, but not every man is greed. -Mahaz?ma Gandhi 2 During the late nineties, Mexican National Drug Traf?cking Organizations (DTOs) began cultivating cannabis in Southern California and spread north into Oregon. Due to the tightening of border security in the post 9/11 period in Plant Seizures on Public Land conjunction with increased domestic production, 2011,00 2016 transnational cannabis smuggling became less Home pro?table for Mexican DTOs and has all but been 1mm supplanted by growing and distributing cannabis it,? within the United States. 3 To date in Oregon, E, 80'? cannabis legalization has not had a noticeable 60,000 in?uence on Mexican National illicit cannabis cultivation operations on public lands, (see Figure 1). In fact, a review of Domestic mm Cannabis Eradication and Suppression Program data from to portrays a Figure 1: Illicit Cannabis Grow: on Public Lands 201 1 through 2016 Accor?di'ngto erratic trend among the annual totals of cannabis Records plant seizures on public lands.4 The ?uctuations in the number of annual plant seizures appear to have a stronger correlation with climatic events, enforcement models, and prosecutorial changes, than speci?c legislative changes. 2 Pisupati, Balakrishna. 201 1. "Environment, Biodiversity and Gandhiji." The Hindu. October 2. Accessed January 3, 2017. 24.ece. 3 Milestone, Jim F, Kevin Hendricks, Alan Foster, Jim Richardson, Sean Denniston, Athena Demetry, Matt Ehmann, Charles Cavalier, David Schifsky, and David Fireman. 201 1. "Continued Cultivation of Iiiegal Marijuana in the US. Western National Parks." George Wright Society Conference on Pains, Protected A teas, and Cul'tm'ol Sires. Hancock, Michigan: The George Wright Society. 209-216. 4 Drug Enforcement Administration (DEA). 2016. "Oregon Domestic Cannabis Eradication and Suppression Program Reported Statistics 201 I to 20E 6. DEA. Accessed November 13, 20i6. 31 Independent of ?uctuations in annual seizure volume, illicit grow operations leave a lasting scar on Oregon?s unique ecosystems. Illicit cannabis grows employ excessive amounts of pesticides, rodenticides, and - herbicides, thereby threatening local wildlife habitats. Additionally, many illicit grow sites clear-cut timber, furthering soil erosion and water contamination. Research on the environmental impact of illicit cannabis grows indicates that grows tend to be bunched near water sources, resulting in disproportionate impacts on ecologically important areas. 5 Calculating water consumption using data of illicit grows indicates that Oregon is robbed of roughly 122 Olympic swimming pools worth of water annually, or roughly 442,200 gallons of water daily during the growth s'eason, typically May through October (see Figure 2). 6? 7 - 20 Water consumption-oi Illicit Cannabis Grows on Pubiic Land Figure 2: Water Consumption of Iilicit Cannabis Grows on Oregon?s Public Lands 2004 to 2016; One Olympic My 1-203-5 Swimming Pooi is 660,000 Gallons 5?5 Recreational Use Lesailzed This activity results in acute water stress in some of the state?s most environmentally sensitive areas. Concentrated and prolonged illicit cannabis cultivation is particularly prevalent in the Applegate, Illinois, and combined Rogue Watersheds (see Map 1). Compared to the regulated cannabis DTOs retain a i Gram-Is- Walu re! 9 mo by ?rammed [crml - thiqu . . . the": Map 1: Distribution of?iieir Cannabis Grows across Oregon '5 Watersheds, 2011 through 20! 6 I 5 Butsic, Van, and Jacob Brenner. 20 I 6. Cannabis (Cannabis Saliva or C. Indian A g?cninne and the Enviromnenl: A Systematic, Spm?falbr-Eapiicir Survey and Potential Impacts. Environmental Impact Summary, IOP Science: 1-2. 6 Drug Enforcement Administration (DEA). 2016. "Oregon Domestic Cannabis Eradication and Suppression Program Reported Statistics 2011 to 2016. DEA. Accessed November 18, 2016. 7 O'Neill, Casey. 2015. "How Much Water Does it Take to Grow Cannabis?? The Ganjier. July 2. Accessed December 22, 2016. http? muv.theganjicr.com/201 32' competitive advantage as their pro?ts are tax-free and there is a relatively low operating cost. Additionally, due to the rapid evolution in the legal cannabis market DTOs may exploit chaos to their advantage and use the licit market as a pretext to commingle their activities. None the less the massive combined scope of cannabis agriculture, licit or not, in the state demands that it be regulated and researched on par with a conventional agricultural commodity. 8 information from 2011 to 2016 shows that the majority of cultivation activity takes place predominately on US. Forest Service lands (see Figure 2). 9 Further analysis indicates that the majority of large- scale grow operations, those over one thousand plants, were found above 1400 feet in elevation, near the headwaters of offered in this section are from wholly illicit cultivation activities, there are parallel environmental concerns about legal operations pilfering water as has been the case in the Lower Rogue Watershed. 10 There is no debating that water is a ?nite resource and unregulated cannabis cultivation consumes the state?s reserves. Annual PlantSeizures by Land Type Other Public Bureau of India" Affairs (B IA) many water Systems' While the Statlsucs Figure 2: Distribution of Land Types of Cannabis Grows 2011 to 2016 Return on investmentfor Eradication Figure 3: Store?Wide Return on Investmenrfor Cannabis Eradication Given the available information, legalization does not appear to have any noticeable impact on illicit cannabis cultivation on public lands. Illicit cannabis cultivation continues to be a threat to Oregon?s environment, and as these activities destroy local ecology they are by extension a threat to public safety. As has been previously discussed, the allure of pro?t motivates excessive production. Conversely, mitigating this threat requires spending and resource allocation for enforcement and eradication. Indeed, there is a limited relationship between spending and subsequent seizure sizes, with a statewide return on investment of 1,155 dollars? worth of cannabis for every dollar spent on enforcement (see Figure 3). 11 8 Butsic, Van, and Jacob Brenner. 2016. Cannabis (Cannabis Sativa or C. indica) Agricniture and the Environment: A Systematic, Spatially-Expiicit Survey and Potential Impacts. Environmental impact Summary, Science: 9. 9 Drug Enforcement Administration (DEA). 2016. "Oregon Domestic Cannabis Eradication and Suppression Program Reported Statistics 2011 to 2016. DEA. Accessed November 18, 2016. ?0 Mann, Damian. 2016. "Officials Worry Water Will Go to Pot." Mail Tribune. December 19. Accessed December 26, 2016. 1 Oregon State Police. 2016. Budgetary Spending 20E 1 to 2016." Salem, Oregon: OSP, December 27. 33 The size of cannabis agriculture in the state, legal or not, requires data collection and analysis to understand the environmental impact. Consideration should be given to researching adequate production thresholds, which will diminish surplus cannabis and minimize available product for diversion. It is dif?cult to prove that simply spending more money will eliminate illicit public lands? cannabis grows. Yet, it is safe to say that dedicated enforcement personnel, access to aerial assets, public outreach, and prosecutorial resolve play signi?cant roles in combating illicit cannabis grows (See Figure 3). 12 Walter, Shoshana. 2016. "In Secretive Marijuana Industry, Whispers of Abuse and Traf?cking." Reveal News. September 3. Accessed January Average Seizure Return on Flight Hours >9 10 Cannabis Piants ?39 1 Hour Ftight Time Figure 3: Average Seizure Renn'nfor Flight mire According to HIDTA Dara 2007 to 2015 23, 2017. 34 State Compliance on Prevention of Exploitation of State-?Authorized Cannabis Activities for Illicit Activity and Violence in the State?s Cannabis Industry Executive. Summary and Purpose The focal points of this section are derived from the federal guidance, issued by former DOJ Deputy Attorney General James M. Cole, on - - Preventing revenue from the sale of marijuana ?om going to criminal enterprises, gangs, and cartels Preventing violence and the use of firearms in the cultivation and distribution of marijuana - Preventing marijuana possession or use on federal property. To this end, this section provides a survey of recent events that typify the exploitation of the state?authorized cannabis industry for illicit activities. Strategic Findings - Criminals are exploiting Oregon?s cannabis industry for ?nancial crimes and fraud. 0 Legal entities in Oregon?s cannabis industry have been targeted by violent criminals and armed robberies. 1 Cole, James M. 2014. "Guidance Regarding Marijuana Financial Crimes." US. Department of Justice. February 14. Accessed September 26, 2016. 20Crimes%202%20 l4%2014%20%282%29.pdf. 35 ?Intelligence is the ability to adapt to change. - Dr: Stephen Hawkingz There are several high~pro?le cases in which criminals have exploited Oregon?s abundant cannabis supplies for illicit gain. One method commonly used to facilitate illicit gain from the state?s cannabis surplus is to use the Postal Service to ship cannabis products and proceeds. According to former Attorney General Eric Holder, ?The Postal Service is being used to facilitate drug dealing. . a clear violation of federal law and a violation of the sanctity of the U.S. Mail. 3 As a cannabis supply center, Oregon has been a source state in multi-state cannabis traf?cking networks. As indicated by court records from 2016, Stevenson Tran, Loc Bui, Quan Tran, and Peter Nguyen of Portland shipped at least 318 kg (700 lb.) of cannabis to Wisconsin, where the at least 2.5 million dollars of proceeds were structured and laundering in Wisconsin banks. 4? 5 In Eugene a coffee kiosk served as a shell for comingling ?nds from cannabis diversion by Eric Leighton Scully and his multi~state cannabis traf?cking network. Scully and his associated secured more than a million dollars from their diversion activities, which they subsequently converted into other tangible assets. 6 Oregon?s cannabis industry has become a high? risk sector for investment fraud. Tisha Silver of Cannacea Medical Marijuana Dispensary falsi?ed licensing to solicit investors and worked with Green Rush Consulting to locate unwitting investors. 7 Silver exploited the burgeoning cannabis industry in the state to entice investors to back an in illegitimate company, securing a quarter of million dollars in fraudulent gains. According to some cannabis investors fell prey to ?pump and dump? schemes and lost up to 23.3 billion dollars in 2014 alone. 3 2 The Teiegraph. n.d. Professor Stephen Hawking: 13 of His Most Inspirational Quotes." The Telegraph. Accessed January 28, 2017. 2088 8 129. 3 Postal Reporter. 2014. ?Holder: Postal Service Mail Used for 'Shocking? Amount of Drug Dealing." Postal Reporter: April 4. Accessed December 22, 2016. 4 IRS. 20} 6. "Examples of Money Laundering Investigations - Fiscal Year 2017.? IRS. December 28. Accessed February 6, 2017. 7. 5 The United States Attorney?s Of?ce Western District of Wisconsin. 2016. "Final Defendant Sentence in Marijuana Distribution and Money Laundering Case." United States Department of Justice. December 14. Accessed January 22, 2017. justice. 6 Moran, Jack. 2016. "Business Used as Front for Drug Ring." The Register~Guard. May 14. Accessed February 6, 201?. locair?34367l 7 Crotnbie, Noelle. 2016. "State Slaps Portland Dispensary Owner with $40,000 Fine in Fraud inquiry." The OregonianIOregonLive. July 29. Accessed February 6, 2017. 8 Sapient Investigations Inc. 2015. "High Times for raud." Sapient Investigations Newsletters. February 10. Accessed November 22, 20l6. 36 Financial crimes not withstanding, cannabis is a lucrative target for robbery and as recently as December 2016 a state-licensed cannabis producer was targeted for a violent armed robbery.9 In the aforementioned case, a well-known cannabis grower in Jackson County was assaulted, bound, and his harvest was taken by armed assailants. Oregon?s new cannabis industry is ?lled with hype and great deal of market volatility; appealing environmental conditions to ?nancial criminals and ?audsters. 10 These cases exemplify the range of crimes taking root in Oregon?s cannabis sector. Oregon?s cannabis businesses are cash intensive operations, and as such are easy targets for robbery and ?nancial exploitation. The ever expanding myriad of cannabis related support services and specialties poses a challenge to enforcement. Other prominent cannabis production states have had cases of sexual exploitation and forced labor linked to cannabis grows. In California?s Emerald Triangle so-called ?bud-trimmers or trimmigrants? have been raped, traf?cked, and abused by cannabis growers. While there is no credible indication that this form of human traf?cking is happening in Oregon, preventing it from taking root should be a priority. 9 Crombie, Noelle. 2016. "Masked Intruders Hit Legai Marijuana Grow -- Frist Violent Crime at Licensed Pot Farm." The Oregonian! OregonLive. December 29. Accessed January 27, 2017. 10 Consumer Reports. 2015. "Why Marijuana Stocks Might Go Up in Smoke." ConsumerRepom Money. June 28. Accessed January 15, 2017. i 37 Conclusion and Recommendations for Enhanced Compliance with Enforcement Priorities Executive Summary and Purpose The conclusions and recommendations of this section are derived from the research and analysis focused the state?s compliance with the federal enforcement priorities issued by former DOJ Deputy Attorney General James M. Cole. 1 Strategic Conclusions - These enforcement priorities require on? going performance monitoring and continual analysis to gauge the ef?cacy of the state?s regulatory regime and enforcement system. To properly evaluate these areas of concern there should be dedicated personnel to collect, analyze, and disseminate information to enforcement forces. Collaborative strategies should be developed to enhance data collection on these enforcement priorities to better evaluate Oregon?s compliance with federal guidance. - These enforcement priorities and baseline analyses should be core to the development of a state?Wide enforcement regime. 1 Cole, James M. 2014. Guidance Regarding Marijuana Financiai Crimes." U.S. Depmnnenr ofJus?ce. February 14. Accessed September 26, 2016. i 38 ?Change is the law of life. And those who look only to the past or present are certain to miss thefuture. - John Kennedy 2 Former DOJ Deputy Attorney General James M. Cole established and expectations for states who have chosen to legalize clear requirements cannabis. This report is strictly an initial evaluation Oregon?s relative position to the federal enforcement expectations using readily available information. As such, there remains a knowledge de?cit when it comes to cannabis? long-term interplay with society and which requires future analysis to improve upon the existing body of knowledge. A comprehensive review of Oregon?s position relative to federal expectations will require continuing evaluation and new information collection. To facilitate future research into cannabis enforcement efficacy and public health, reporting state agencies must agree standardize and centralize data collection. It is advisable to conduct periodic data maintenance to limit erroneous information in the meta?data related to cannabis diversion. Greater accuracy of the size of the illicit cannabis market could be obtained if drug use questionnaires were revised to better gauge self-reported consumption. improving existing data sources, will facilitate on-going evaluation and ?iture assessments on the impact of cannabis legalization on Oregonians. In the state only one third of traf?c fatalities are tested for drugs or alcohol, making it dif?cult gasp the totality of cannabis impaired driving. Some enforcement priorities cannot currently be evaluated, such as possession of cannabis on federal property; there is not an effective method to evaluate state compliance on preventing cannabis possession on federal property. Oregon?s successful deployment of a comprehensive enforcement system ought to- be developed on empiriCally sound data and objective analysis. Yet, analysis cannot be performed without information. In turn, information, devoid of standardization and aggregation is not easily retrievable or readily analyzed. A balance needs to be stuck between the number of required to process and analyze raw data with the collectors of information on cannabis related issues. Polices ought to be developed that promote uniform reporting, data retention, and facilitate third party access to cannabis related data for evaluations of performance measures. OSP will continue to evaluate the state?s relative position to the cannabis enforcement expectations. 2 Kennedy, John F. 1963. "Address in the Assembly Hall at the Paulskirche in Frankfurt." The A merit-wt Presidency Project. June 25. Accessed January 26, 2017. 03. 39 40