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 91-613, atpg° 15.
 HEW's consideration of this factor is contained in a short
 paragraph which cites a number of statistics indicating that about 36
 million Americans have tried marijuana and that marijuana use is most
 heavily concentrated in the 18-25 year range° 44 Fed. Reg. at 36125 Co[.
 3. DEA expands on these statistics with additional statistics
 indicating the widespread use of marijuana in America. 44 FedoReg. at
 36123 Col. 3-36124 Co[. !.
 However, nowhere do DEA or HEW make any findings on the n social,
 economic, and ecologicaJ characteristics" of mari iuana users, which the
 House and Senate Reports require, in addition, no attempt is made to
 distinguish between the scope of marijuana use (which the DEA focuses
 on) and the scope of marijuana abuse.
 e. Scope and Significance of Abuse
 The fifth factor which must be considered is the "scope, duration
 and significance of abuse: of the substance." Section 201(c)(5). The
 House and Senate Reports state that:
 In evaluating existing abuse, not only must
 the Attorney Genera[ know the pattern of abuse, but
 he must know whether it is a passing fad, or
 whether it is a significant chronic abuse problem
 like heroin addiction. In reaching his decision,
 the Attorney General should consider the economics
 of regulation and enforcement attendant to such a
 decision. In addition, he should be aware of the
 social significance and impact of such a decision
 upon those peopJe, especially the young, that would
 be affected by it.
 H.R.Rep. No. 91-1444 at pg. 4603; &Rep. No. 91613 at pgs. 1 5-16.
 As indicated above, the DEA's consideration of the "abuse" of
 marijuana focused only on statistics concerning the prevalence of use.
 See, 44 Fed. Reg. at 36123 CoL 3, 35125 CoL 3. The DEA failed to
 consider the "significance" of abuse, to distinguish between use and
 abuse, or to consider the other criteria specified in the House and
 Senate Reports.

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