some cannabis flower in a jar

Michigan’s Cannabis Flower Shortage

You’ve probably heard about or personally experienced cannabis flower shortage in Michigan. Now, people will tell you there’s plenty of cannabis in Michigan and perhaps that’s true. Our caregivers have been growing excellent product for the last ten years. The cannabis flower shortage that independent provisioning centers are suffering from comes from a snag in the supply chain and an issue with Michigan marijuana regulations.

cannabis flowerWe propose two solutions to the issue at hand, moving the cannabis from the caregiver to testing and to the provisioning center and/or allowing cannabis to be sold between provisioning centers.

One thing we like about Michigan’s new Marijuana Regulatory Agency is that Director Brisbo is accessible and open to ideas. We wrote to him recently on behalf of our independent cannabis clients who are struggling with keeping cannabis flower in stock.

 

We urge others, especially patients, to be proactive about this issue. The solutions are simple and we need action now.

Here’s our letter:

Marijuana Regulatory Agency
Department of Licensing and Regulation
Attn:  Andrew Brisbo, Director
P.O. Box 30083
Lansing, MI  48909

Re:       MMFLA Licensing Provisioning Centers

Dear Mr. Brisbo:

As you may have heard from others, quite a few of the independent licensed provisioning centers are suffering from a dearth of product for sale.  The larger grower and processor companies which could afford vertical integration can well control the distribution of their product and shut out the smaller, independent provisioning centers.  In addition, the larger, vertically integrated entities can take in product from a caregiver through their licensed grower and processor and run it right into their own provisioning center.  Stand-alone provisioning centers cannot do so.

I am requesting on behalf of the smaller, independent, non-vertically integrated provisioning centers either:

  • Going back to the past position from the Agency which allowed direct sale of tested and transported product from a caregiver to a licensed provisioning center; or
  • Allowing licensed provisioning centers to sell the product between themselves in order to keep a balance of product. For example, one has more product than necessary and another has none.  If they were owned by the same ownership under MRTMA, they could shift inventory.  It seems only fair that independent provisioning centers be allowed the same rights to balance product amongst themselves.

Thank you for your attention to this request.  I would be happy to discuss it further with you or others on behalf of these independent, smaller, non-vertically integrated provisioning centers.  I recognize that my firm represents the vertically integrated entities as well, which somewhat causes a conflict of competitive advantage.  However, in hopes of making the business entirely successful for all presently licensed and future facilities, I pose this proposal.

 

Very truly yours,

Benham R. Wrigley, Jr.

WRIGLEY HOFFMAN, P.C.