CRE Open Letter to Ms. Valerie B. Jarrett, Senior Advisor and Assistant to President Obama

Publishers Note: CRE very much appreciates the insights our readers have displayed in their comments and are transmitting them to Administration officials.

Ms. Valerie B. Jarrett

Senior Advisor and Assistant to the President for Intergovernmental Affairs and Public Engagement

Re: CRE’s Creation of a Kratom Scheduling Docket

Dear Ms. Jarrett:

In his Open Government Directive,[1] President Obama called for creating and institutionalizing a “Culture of Open Government.” The President explained that to

create an unprecedented and sustained level of openness and accountability in every agency, senior leaders should strive to incorporate the values of transparency, participation, and collaboration into the ongoing work of their agency.

An Open Letter to the Obama White House Staff

Publisher’s Note: A similar letter or email from members of your Congressional delegation to the White House staff would be very helpful.

DEA Is Creating a Black Market Which Will Finance Organized Crime and Terrorist Groups

At the end of this month, September 30, 2016, the DEA will create a black market as a result of its ban of kratom. The ban will go into effect on October 1 unless it is modified prior to that date.

The effective date of the ban should be extended from October 1, 2016 to July 1, 2017 in order to allow the public to comment on the proposed ban.

The Black Market: Part 2

One thing an Interactive Public Docket ( IPD) does is that it provides an open forum for the public not only to express their views on a topic but it allows others to comment on their comments.

The post we made yesterday  resulted in a number of  very notable contributions in that many of the comments  addressed the  two critical questions raised in our post:

  1. If kratom is banned will a new black market come into existence?
  2. Is there an elephant in the room?

In one instance a comment answered a question CRE did not ask, namely the identification of the elephant or elephants.

The Birth Of A New Black Market: Is There an Elephant In The Room?

We encourage your comments in the space below.

Kratom is legal in Canada; Kratom is legal in Mexico.

The United States has a significant number of its population in dire need of kratom because other products  do not live up to their claims. This is a textbook definition of the birth of a black market since the country in which a product is banned is surrounded by countries, which on each and every of its borders, sale the product legally.

Does one really believe that one of the premier law enforcement agencies in the world is ignorant of such an observation; we think this only a remote possibility but have no information to substantiate our underlying hypothesis.

2nd CRE Letter to Department of Justice: A Roadmap to Sensible Regulation

On September 12 CRE sent a letter ( cre-dea-kratom-1 ) which contains a roadmap for the Drug Enforcement Administration to address the alleged problems with kratom through the adoption of a transparent and public process.

CRE concluded in the aforementioned letter:

However in this instance, the DEA action to ban Kratom, the conflict is considerably wider in scope. In this instance there is a sharp disagreement among a number of federal agencies. Consequently if there were ever a time for an OMB intervention this is it.

CRE recommends the following:

Welcome to the Kratom Interactive Public Docket (IPD)

An Interactive Public Docket (IPD) is a shadow docket of a federal regulatory docket.  Specific characteristics of an IPD are described here and here.

This IPD will contain a description of the most recent developments concerning Kratom.  To this end CRE compliments those interested public citizens who have made hundreds of comments on the subject, see the “Comment” discussion forum to the right of this post.

These posts made by the public are of extreme importance because they are provided to regulators on a 24/7 basis.