- Excessively unattainable application restrictions
- Illogical Security, Personnel, Equipment and Cultivation requirements
- No Home Cultivation, Co-op or Social-club models considered
- No Primary Care Giving or Compassionate Care model
- No clarity on different forms of cannabis administration
- Lack appropriate cannabis dispensing models
- Unsubstantiated INCB restrictions and quotas
- No affordable patient access to medical cannabis discussed