Publisher’s Note: We appreciate the splendid reaction you have made to our posts. Your comments are viewed by regulators, the press and Congressional staff. We apologize for not responding to the questions you raised in your comments or the questions you raised in the submissions to CRE via the contact link on this website. Rest assured a member of our staff reads all submissions and the comments are placed in a database which we use for our advocacy operations. That said, we simply do not have the resources to be as responsive to your requests as your have been to ours.
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, 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.
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.
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:
- If kratom is banned will a new black market come into existence?
- 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.
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.
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:
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.