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 The NORML petition was then discussed at the Controlled Substances
 Advisory Committee ("CSAC") meeting held November 16, 1977. The CSAC,
 composed of prominent researchers and scientists, was established
 principally to consider and make recommendation.,; on petitions to
 schedule or reschedule controJJed substances. At the November 16, 1977
 meeting, the Committee permitted counsel for NORML to introduce a
 written memorandum and make an oral presentatkm to the Committee.
 CSAC then heard a presentation by Robert Randal4, an individual who
 receives marijuana from the federaJ government to treat his glaucoma.
 This was followed by a general discussion of the petition by the
 members of the Committee. The Committee voted to defer action on the
 petition until its next meeting°
 The next CSAC meeting was held March 15, 1978. NORML was repre g
 sented at this meeting by counsel, and by Dr. Lesl:er Grinspoon,
 professor at Harvard Medical School and author of numerous books,
 studies, and articles on marijuana and other substances. The
 Committee undertook thorough discussion of the NORML petition, and then
 voted to recommend the rescheduting of two cannabis components from
 Schedule I to Schedule II-- cannabinol and cannabidioL
 The Committee concluded the marijuana components generally nave a
 "moderate" rather than "high" potential for abuse, and that there were
 number of very promising medical uses for marijuana which were being
 recognized and facilitated by state marijuana laws. The Committee based
 its recommendations on these findings, and on it.,; intent to assist the
 state developments by easing access to marijuana for medical and
 research purposes, through the rescheduling of marijuana components
 from Schedule _ to Schedule _f in the federat law. See, 44 Fed. Reg. at
 36127 cols. 2-3
 After the CSAC recommendations on March 15, 1978, the NORNIL
 petition remained pending at HEW, with no action being taken on ito
 Counsel for NORML made repeated attempts, in writing and by telephone,
 to discover when the recommendations would be published in the Federal
 Register for public comment, including a letter of September 1, 1978
 from counsel for NORML to Secretary Califano. However °, HEW failed to
 respond to these inquiries, and failed to take any action on the NORML
 By March 1979, HEW still had taken no action on the petition, even
 though it had been more than tweEve months since the CSAC
 recommendations and more than twenty-one months since the petition

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