Two Wrongs do not Make a Right

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Two Wrongs do not Make a Right

Author’s note: This is my 7th complete re-write of this article.  Each time I wrote it over the past 2 weeks, I found myself getting too negative and, in particular, getting negative towards the UW (an institution that I have great respect and affection for).

So:  Here is a less negative version.  I hope the tone helps encourage folks to take this issue seriously.  If you agree with my calls to action below, please let the UW know (the Regents, the President, the Department Chair of the Law School, and the Cannabis Law & Policy Project would all be good places to start).  Maybe the Governor and the LCB, as well.

The original title (this morning) of this draft was “Two Strikes, but not yet Out!”  Hence, the baseball analogy I carry through the document.

10 days ’till the medical transformation/genocide is complete.  Specially if the train keeps rollin’


The Washington State Liquor and Cannabis Board has been pitched two strikes recently by BOTEC.

The first was in the form of the POS (piece of shit) that comprised their final work-product allegedly estimating the size of the Medical Cannabis market.

This strike was a fastball.  It came in so fast, the batter (LCB) did not even notice the fact that primary table summarizing the results is arithmetically wrong and makes no sense.

The second strike was indirect.  It was a screwball.  While it was initially thrown by BOTEC, it’s trajectory was influenced by the University of Washington’s Cannabis Law & Policy project through their choice to replicate a portion of BOTEC’s flawed science using newer/fresher data.

It is no surprise that the UW’s work estimated a smaller medical market (needing a smaller supporting canopy and store-count).  Were anyone to choose to replicate BOTEC’s bullshit method again after July 1 of this year, they would estimate a market of ZERO size requiring ZERO supporting canopy and ZERO additional stores.  That’s what happens when you use BOTEC’s method while dispensaries are being systematically closed.

I do not use words such as bullshit and piece-of-shit lightly in the context of science.  Science tends to frown on such language (and also has a tendency to marginalize those using it).  However, those words are appropriate in this case.  If I am marginalized, so be it.   At least my birds love me.

BOTEC’s work was poorly executed, poorly reported and very poorly error-checked.  At it’s core, though, it was very poorly thought out.  Unless, of course, they perceived their mandate from the WSLCB to be one of providing an under-estimate of the size of Washington’s medical market to support some pre-conceived policy biases (or whatever).  If that were the case, then their thought processes and creative use of envelopes delivered what the client wanted.

The UW’s work was well executed, well written and seems to have been error-checked.  It was, however, largely a replication of BOTEC’s method.  Therein lies its fatal flaw.

BOTEC’s method of market size estimation, in easy form, consisted of:

  • getting a CURRENT census of how many medical dispensaries were CURRENTLY operating in the state   (the UW used the same three exact websites that BOTEC used ….. really, now,  headshopfinder as an authoritative source?)
  • surveying those dispensaries about how much they sell per month
  • taking the small subset that responded and calculating a “typical” months’ sales for a “typical” dispensary
  • doing some calculations to estimate how much flower (and canopy) would be needed to supply the flower, concentrate, and edibles mix being dispensed by those dispensaries
  • multiplying the number of dispensaries in the CURRENT census by the average per-store monthly sales
  • multiplying that by 12 to get an annual amount.  That, in BOTEC’s mind, yields a market size.


11 days from now, we will have no more dispensaries.

ZERO dispensaries TIMES $1,000,000 per store per year yields a medical market of ZERO dollars (annualized).   That estimated  market requires precisely ZERO grams of cannabis to support it’s estimated product needs.   Hence, we will find in 10 days, that precisely ZERO square feet of plant canopy are needed to supply the market.  Should we, then, reduce the amount of licensed canopy to decrease diversion?  (see …. bad info can generate lots of bad policy)

This extreme-case scenario (which will exist in 10 days) points out the fatal flaw in BOTEC’s “approved on an envelope” method of medical market-size estimation.

May BOTEC rot in hell for what they have done.  Shame on the UW for mindlessly copying BOTEC’s piece-of-shit methodology.  Unlike BOTEC, the UW Law students executed it well, but even good work on a piece of shit methodology tends to yield shit results.

I call on the UW Cannabis Law & Policy Project (BOTEC, as well … but that retched firm does not seem to give a shit about the people and patients of Washington) to retract their seminal publication.

Putting a clause in the original document that said, in effect, that “producing these estimates is tough and you should be very careful using our work to set policy” is not enough.  The students that worked on the UW paper are aspiring lawyers …. one would expect some protective language from them.  I’d be surprised if they had not so attempted to covered their asses.  They are being, after all, trained in law.

I, as a taxpayer of this State and otherwise great fan and supporter of the University of Washington, call on Director Sam Mendez to retract this document.

At a minimum, I believe that the UW should make a very clear statement that the use of BOTEC’s methodology resulted in the UW work producing an UNDER-estimate of the size of Washington’s medical Cannabis market.  Effectively, I’m asking for an “Oops … we’ll do it better next time.”

Heck, I may even be inclined to help the UW do it better next time.

That’s all I ask.  It’s a factual statement.  It should be rather easy to make …. After all, FACTS and UNIVERSITIES go well together … or at least they used to.

It is unfortunate that the UW’s BOTEC-mediated estimate of the size of the medical market is wrong (and systematically so).  That is a fact.

Their error, if left unadmitted, is likely to be enhanced in it’s negative impact by being “paired & compared” with BOTEC’s work.  If left to fester, these two pieces-of-shit may well come to define “best available science” in this area.  That would be a shame in that the poorly-informed policies that can be expected to be formed using this “research” will (quite predictably … .and I’m saying that to the lawyers at UW and at the WSLCB) CAUSE HARM TO PATIENTS AND TO THE BUSINESSES THAT HAVE SUPPORTED THEM FOR OVER A DECADE.

The character of the University of Washington, the character of it’s Cannabis Law & Policy Project, and the character, ultimately, of it’s Director (nice guy, it seems) are on the line here.

Sam — please check with the Regents (or whoever) and do the right thing. Retract your work – and do so now. If you do … good for you.  If not, that would be unfortunate.

Director Mendez has just come in to pitch relief.  If he fails to act that would, IMHO, be the third strike.

This third strike would be attributable to the UW.  I blame BOTEC for the first two.

While I’m egotistically suggesting things that others should do:. – I call on the WSLCB to remove the BOTEC POS estimate published last December from their website (I asked the Board, in person, to do this this past week).  Keeping it up on their taxpayer-supported site lends it a veneer of credibility that it does not deserve.  You may want to consider censuring BOTEC for selling you that swampland.

Relegate BOTEC’s (and the UW’s) reports to your archives …. By all means make them available to interested parties (students interested in examples of bad science, perhaps?) through the public records request channel.  Allowing the paper to remain posted continues to embarrass the Board, it’s staff, and the Governor who appointed them.

Have any of you even bothered to check that the numbers in the main table of BOTEC’s results do not add up?  I assure you, it only takes about a minute with a calculator app.

To paraphrase some lyrics I recently posted on HI-Blog, Mr. Governor Inslee, Sir:

So come on Jay, be nimble .. Jay be quick

Get off your ass and fix this shit

‘Cause Patient death is not your schtik

Don’t let the Patients die.

Governor, the LCB seems to be telling you that the transition away from a separate medical system is going well.

Just so that you know, it is not.  I believe your serfs do not want you to have yet another set of concerns in this busy election year.

Love & Stuff:  Dr. Jim


  1. Bob Montoya says:

    The State’s customers (majority) are working people who are in fear of losing their jobs if they enjoy this ” legal” product sold by the state. It is this reason alone the decision was made to absorb medical. If it were truly legal to use, the state would be hard pressed to keep it on the shelf,,,,medical would be of little consequence to the monopoly game. Discrimination in the workplace killed MMJ in WA.

    • Jim MacRae says:

      Thank-you, Bob. Interesting thought re: workplace drug-testing.
      Some of the cognitive-dissonance in Olympia could well be at play here (it’s a valid and effective drug that saved my Mum, but we still test pee that can pick up Cannabis metabolites a month old and destroy careers based on a puff).

      Medical is of great consequence to all players in the industry, whether aspiring monopolists or not.
      Medical users, as has been frequently noted, contain a disproportionate fraction of current heavy users of Cannabis, Cannabis concentrates and/or Cannabis-infused products. There are also a good many more of them representing a market much larger in size and commercial value than is typically forecast by the state and/or their paid quantitative wanna-be’s.
      Multiply more patients by more per-patient grammage and you then have a need for a lot more canopy square footage and more retail counter space.

      More dollars. More medicines. More health. More happiness.

      It’s all good if we let it be so.

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