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Sanctuary ATC

568 Tenney Mountain Highway

Plymouth, NH 03264

March 27, 2019

Dear Senator Sherman and Members of the Senate Health and Human Services

On behalf of Sanctuary ATC, please accept this letter as a clarification to the

testimony offered on our behalf at yesterday’s public hearing on House Bill 364
While Sanctuary ATC opposes some aspects of HB364, we support the right of
qualifying patients to cultivate their own cannabis, and we would support an
amended version of this bill. Sanctuary ATC is committed to supporting New
Hampshire qualifying patients, and the passage of HB364 would clearly provide a
benefit to some patients with regard to cost, access, and strain availability. Our
concerns are based on some of the specifics of the legislation and not on the ability
of qualifying New Hampshire patients to cultivate a limited amount of therapeutic
With the following concerns addressed by an amendment to HB364, Sanctuary
ATC would fully support passage of the respective legislation:
 The bill introduces the terms “immature plants” and “mature plants.” We
recommend that these terms be defined. Establishing these definitions
would create a more defined structure for compliance and enforcement of
the permitted plant counts.

 Additionally, with respect to the cultivation location, Sanctuary ATC would

support legislation that limits cultivation to patients’ and caregivers’
residences only. Permitting the use of retail, commercial, or industrial
zoned properties for cultivation would act against the intended purpose of
the legislation.
Sanctuary ATC
568 Tenney Mountain Highway
Plymouth, NH 03264

 Lastly, the opportunity for diversion is increased when the ability to

cultivate at home is expanded. Allowing the gifting of cannabis further
increases the opportunity for diversion. Specifically, allowing NH patients
and caregivers to gift cannabis to out-of-state patients, which would be
allowed under this legislation, invites a re-examination of the current law
which prohibits the state’s Alternative Treatment Centers from serving
visiting qualifying patients. Currently, ATCs can dispense only to in-state

Sanctuary’s goal is to provide the citizens and legislators of New Hampshire

with information that will allow the state’s Therapeutic Cannabis Program and any
ancillary legislation to continue to move forward. Sanctuary is committed to
providing high-quality services to New Hampshire citizens. For the record, in 2018
Sanctuary’s discount policies were available to 57% of all patients, which resulted
in $347,282 worth of price reductions. Sanctuary offers discounts for veterans, low
income individuals, Medicaid recipients, and those on SSI and SSDI. Sanctuary
will continue to strive to provide education and safe, high-quality products for the
citizens of New Hampshire.
In closing, we believe that the passage of HB364, with the above concerns
addressed, would enhance the Therapeutic Cannabis Program and provide patients
with the option to cultivate their own medicine as needed, while restricting
cultivation from commercial spaces and limiting opportunities for diversion.


Jason Sidman, CEO

Sanctuary ATC