I recommend that you consider the unintended consequences from increasing the penalties on the non-medical uses of MDMA. As a result of the political pressure to portray illegal drugs as having overwhelming risks and no benefits, any increase in penalties will further stigmatize MDMA. This will have a negative effect on the ability of scientists to obtain approval from FDA and DEA and fundinng from NIMH for research into MDMA-assisted psychotherapy. I understand that the regulation of research is not in your area of responsibility. However, I appeal to you to consider including a sentence or two in your written recommendations stating that the Commission supports scientific research into MDMA's therapeutic potential. The World Health Organization (WHO) Expert Committee that recommended in 1985 that MDMA be placed in Schedule 1 internationally did include a statement urging signatory nations to the Convention on Psychotropic Substances "to facilitate [psychotherapeutic] research on this interesting substance." This statement has proven helpful when regulatory agencies have reviewed proposals to conduct MDMA research in humans.

The excessive restriction of opportunities to conduct controversial research is not unique to MDMA but has been historically the case throughout the last century for any drug whose non-medical use was criminalized. Several weeks ago, MAPS and the Marijuana Policy Project filed an Amicus Curiae brief to the U.S. Supreme Court in the US v. Oakland Cannabis Buyer's Cooperative case, whose legal issue is whether there is a medical necessity defense to the Controlled Substances Act. In that brief, we describe in detail the political obstacles that have and still obstruct scientific efforts to conduct research into the potential medical uses of marijuana.

Since MDMA was criminalized in 1985, there have been over 900 papers published in the scientific literature on MDMA. None are from controlled double-blind clinical trials examining MDMA's therapeutic benefits. As NIDA Director Dr. Leshner stated in a March 7, 2001 interview in the Journal of the American Medical Association, "There's an awful lot of hype that ecstasy is a medicine, but there's no evidence... The plural of anecdote is not evidence." This lack of evidence is not for lack of trying by scientific teams around the world.

From 1985 to 1992, FDA rejected all applications to conduct research into the therapeutic uses of MDMA. FDA rejected a protocol by Dr. Greer to study MDMA-assisted psychotherapy in treating pain and depression in a terminal cancer patient whom he had successfully treated prior to MDMA's criminalization. FDA also rejected an application from an experienced researcher to administer MDMA to a woman suffering from unipolar depression who had failed to obtain relief from available drugs or from several courses of Electroshock Therapy, which has risks far in excess of therapeutic doses of MDMA. This woman, who was my grandmother, subsequently died as a direct result of her depression, having weakened herself by refusing to eat. MDMA may not have helped her, but we should have been permitted to find out.

In 1992, FDA finally permitted human research with MDMA, though initially into its risks, not its benefits. In 1999, FDA indicated that it would approve well-designed studies into MDMA's therapeutic uses. This April 2001, MAPS-supported researchers plan to submit a protocol to FDA seeking permission to conduct a study in patients suffering from post-traumatic stress disorder, mostly as a result of sexual assault. This summer, Dr. Grob plans to submit his protocol to study MDMA in cancer patients.