Dear Chair, Commissioners, and Executive Director of the Oregon Liquor Control Commission:
Thank you again for your tireless work on behalf of Oregonians. As a result of your efforts, marijuana businesses in Oregon have been able to remain open and operating throughout the COVID19 crisis, and public, safe access to marijuana for adults, caregivers, and patients has been maintained. We continue to be impressed not only with the Commission’s professional response, but also with your receptivity and openness to stakeholder concerns. You should be proud of the staff and operations of the agency.
As you are probably aware, retail licensees have seen an unprecedented increase in the volume of their delivery sales relative to in-person sales. Deliveries appear to create less opportunity for social contact, and thus increase the efficacy of Governor Brown’s social distancing order. Moreover, if the frequency of delivery orders could be decreased, that would in turn reduce the amount of contact between delivery personnel and customers, and thus improve public health and safety outcomes.
We believe there is a safe and effective way to decrease the number of deliveries while still maintaining safe access, and which also complies with all applicable statutory provisions. In a nutshell, we believe the Commission should consider increasing the quantities of cannabis and cannabis products available for purchase via home delivery.
This would be permitted under Oregon law; for example, while ORS 475B.337 only allows possession of one ounce of usable marijuana in a public place, it also allows possession of less than eight ounces of usable marijuana in a non-public place, such as one’s home. The latter limit would apply to home deliveries, and thus home delivery of, for example, two ounces of usable marijuana by a retail licensee, would be lawful, if the current rules were changed to accommodate it.
Because temporary rule changes to allow larger delivery quantities would be both lawful and would promote the goals of Governor Brown’s social distancing order, we humbly suggest that the Commission consider evaluating and adopting such temporary rule changes. Again, thank you for your service in this difficult time, and for your consideration of the foregoing.
Andrew C. DeWeese
Attorney, Green Light Law Group
4531 SE Belmont St.,Suite 207 Portland, OR 97215
Office: 503.488.5424 Direct: 971.270.4497 firstname.lastname@example.org
Oregon Retailers of Cannabis Association
PO Box 42516 Portland, OR 97202
Members of ORCA have communicated to us that they are very supportive of this proposed change, and that the higher purchasing limit is more in line with the economics of how many consumers purchase cannabis. Many consumers prefer to purchase cannabis by the ounce for the volume discount, but often they also enjoy more than one type of cannabis over a period of time. It's also more consistent with current regulations for limits on alcohol purchases [Due to other limitations in state law, the OLCC would only have the statutory authority to increase the purchase limit for home delivery orders, and not in-store sales].
To have the best chance of making a real impact with the OLCC, we need to show how broad the base of support for this change is. Please add your name to the petition and forward this message to others, urging them to join us as well. With this change, we can help out our industry's frontline employees, the cannabis businesses weathering this storm, and cannabis consumers alike.
If you support our proposal to increase the purchase limits for home delivery orders up to two ounces of usable cannabis, then please join us and add your name (and business name, if applicable) by clicking on the link below.
We will be sending the letter to the OLCC later this week, so please sign the petition and share it with as many people as possible if you can.
Together We Stand, Divided We Fall!
As you all know, we deeply appreciate our member's commitment to ORCA and the health and well-being of the cannabis industry as a whole.
Please don't hesitate to reach out to us with any questions, concerns, or ideas you may have. Our success is directly tied to your input and engagement.
In fact, the idea for this very petition came from conversations with members.
Thanks for taking the time to read our call to action and signing our petition. You're a great citizen, and we appreciate your assistance.
Stay healthy, stay safe, and stay tuned!