Federal Cannabis (Kaneh-Bos) Religious Permit and Correspondence

Federal Religious Cannabis (Kaneh-Bos) Permit of Anne Armstrong and Alan Gordon
Application Amendments, Correspondence and Final Permit
On Mar 24, 2015, at 5:23 PM, Smith, Jennifer <jennifer_smith@nps.gov> wrote:
Anne: As we discussed, please complete the application and drop off at my office along with the $50
application fee. I will, then, set up a meeting to discuss your application and event details with the
Superintendent.
Please let me know if you have any questions as you are filling out the application. A pleasure to speak with
you. Jen
http://www.nps.gov/rowi/planyourvisit/upload/Revised-NPS-Form-10-930_10-2010_ROWI.pdf
Jennifer Smith
Site Manager
Roger Williams National Memorial
282 North Main Street
Providence, RI 02903
O: 401.521.7266
C: 401.595.8394
www.nps.gov/rowi
On Thursday, March 26, 2015, Anne Armstrong <annearmstrongri@gmail.com> wrote:
Thank you very much. We'll be by early next week to drop off the permit. I think we might be able to restrict our
use of open flame to two candles held by careful grown-ups.
Bless you.
Anne Armstrong
From: "Smith, Jennifer" <jennifer_smith@nps.gov>
Date: March 27, 2015 at 7:15:17 AM EDT
To: Anne Armstrong <annearmstrongri@gmail.com>
Subject: Re: Link to Special Use Permit
Thank you, Anne. Will be on the lookout for it. Jen
From: "Smith, Jennifer" <jennifer_smith@nps.gov>
Date: April 13, 2015 at 2:30:14 PM EDT
To: Anne Armstrong <annearmstrongri@gmail.com>
Subject: Roger WilliamsNM Special Use Permit isready
Ms. Armstrong: I just left you a voicemail requesting that we meet either this afternoon or Friday afternoon to go
over the permit for your event on May 23, 2015. I apologize for the late notice in requesting to meet with you
today. I just put the finishing touches on the permit a few hours ago. Unfortunately, I am out of the office

Tuesday-Thursday this week at a training course so this afternoon and Friday afternoon are my only
opportunities to meet with you this week. Please let me know what your availability is. Thank you, Jen
Jennifer Smith
Site Manager
O: 401.521.7266
C: 401.595.8394
www.nps.gov/rowi
from: Alan
Gordon <judges1412@gmail.com>
to: jennifer_smith@nps.gov,
Anne Armstrong
<annearmstrongri@gmail.com>
date: Tue, Apr 14, 2015 at 9:57 AM
subject: cannabis permit application
RE: Contested Cannabis Religious Use Permit
14th April 2015
Dear Jennifer Smith (cc Anne Armstrong):
1. Pursuant to yesterday’s telephone indication from you about Anne Armstrong’s
pending application to use religious cannabis in National Park Service jurisdiction, our
understanding is that you, as the wielder of discretion, are not initially leaning towards
approval of that part of the permit application, though it is the very essence and purpose
of the application.
2. I am Anne Armstrong’s authorized agent in this matter. As I understood it, a
solicitor or attorney for the relevant federal district has advised you that you do not have

discretion to issue permits for the use of substances banned by the Controlled
Substances Act, which seemingly bans the substance in question -- but for exceptions
provided by law, which we mean to draw to your attention in time to prevent litigation
which we feel sure of winning, but would prefer not to file.
3. For the reference of any instructing/advising attorneys, the Secretary of the Interior,
or other parties to whose advice you are contractually beholden, below please find our
representations for Park Service consideration in the exercise of discretion, so that all
relevant facts and law can be considered.
4. If the law said “all National Park visitors must have their shoes tied”, enforcing it
strictly would be inappropriate if any of the following were true:
A. If another law allowed for untied shoes in particular circumstances; or
B. If the Constitution protected all levels of shoelace preparedness, tied or
untied; or
C. If the US Supreme Court has found the untied laces ban to be
unconstitutional for previous Park visitors
5. The exercise of discretion requires all relevant facts and laws to be considered, not
just the ones which a US attorney wishes to be considered. In this case, there seems to
be a clash between the statutory cannabis ban, on one hand, and on the other hand, the
following federally-applicable binding law:
A. The federal Religious Freedoms Restoration Act (abbreviated RFRA, 42
U.S. CodeChapter 21B) sets forth a series of test hurdles for the Government
to clear for proper handling of generally-applicable laws (such as the

cannabis ban) when they collide with the fundamental constitutional right to
religious practice:
B. The unanimous 8-0 US Supreme Court decision in a previous religious
substance use case, Gonzales v. O Centro Espirita Beneficente Uniao do
Vegetal, 546 U.S.418 (2006). (abbreviated UDV). UDV was a test case for
how RFRA applies to a powerful hallucinogen (dimethltryptamine or DMT,
an LSD-like drug) in the same federal schedule as cannabis.
C. The First Amendment to the US Constitution itself, which guarantees
the right to religious practice.
6. As it turns out, prior to the passage of RFRA and the UDV case, even the older,
stricter law would even have allowed the cannabis use we seek, because of a “due
process” and “fair hearing” violation in the permit application process (see Paragraph
10 below at “DUE PROCESS”).
7. RFRA was passed by a nearly unanimous Congress (both houses) as a response to
an unpopular Supreme Court decision in a religious hallucinogen case
called Employment Division, Department of Human Resources of Oregon vs. Smith,
494 U.S. 872 (Smith). In Smith, the religious drug use was not permitted in that case,
but in the Supreme Court ruling, Justice Thomas’ opinion for the majority, at the top of
page 3, said that if a generally-applicable law blocked a religious practice and also
featured due process or fair trial violations, that was unconstitutional unto itself even if
the law’s interference with religious practice was not strictly intentional or
unconstitutional unto itself (shy of the due process problem).
8. Since Smith, RFRA and UDV, religious protections for otherwise banned behavior
have increased dramatically. With those laws, now, if Government means to ban a
sincere[1]religious practice, even incidentally, with a generally applicable law, they
must first successfully pass through every one of several hurdles:
A. “Compelling Interest” test -- Government must prove, via evidence, a
“compelling interest” in a ban without an exception. Under the UDV case,

reference to the ban itself does not suffice for compelling interest -- it must be
shown via evidence (to a greater than 50% likelihood), which may be rebutted
with contradictory evidence.
In other words, saying “because it is illegal” is not a compelling interest,
whereas why it is illegal could be a compelling interest -- if it is proved, by
Government. The burden of proof is Government’s, the standard is “more likely
than not”, and Government’s evidence may be rebutted with contradictory
evidence.
B. “Essential” test -- Government must show that the ban (without
exceptions) is “essential” to the compelling interest alleged. This must be
proved via evidence, with proof’s burden on Government, to a greater-than-50%
standard, just like compelling interest.
C. “Least Restrictive Means” test -- Government must prove, via evidence,
that a total ban, without exceptions, is the least restrictive means of essentially
achieving their compelling interest, with the same level of proof as compelling
interest.
9. In the first and only religious drug test of RFRA in the US Supreme Court, the court
was unanimous in favor of the religious activity, in UDV, despite the powerfully
hallucinogenic subject matter (DMT) -- which the courts accepted as sincere religious
practice.
10. With any due respect to Government’s position, it seems highly unlikely that
Government can prove the cannabis ban is essential to any compelling interest, given
that statistically, the cannabis ban has backfired and worsened any problems caused by
cannabis. In the case of applicant Anne Armstrong, she sincerely believes that cannabis
is in the Bible, referred to as “Kaneh-Bos” (a Hebrew sacramental healing plant quite
cannabis-like in its Biblical depictions). Ms. Armstrong’s faith, identical to mine, is
complex, multi-layered, self-consistent, and well thought-out. This is evidence of our
belief, more of which is available directly from her, in person, if required, though any
attempt by Government to rebut our sincerity will likely fall flat, given our demonstrable
utter religious devotion in day-to-day life and established public history[2] as religious
cannabis users.

11. Further, with regard to “compelling interest,” Government seems unlikely to be able
to prove cannabis is even harmful, since the highly publicized recent de-bunking of
studies claiming it caused brain changes, psychosis, addiction to other substances, and
cancer -- when in fact, cannabis is an excellent treatment for those conditions in many
cases. Every longitudinal study of cannabis use consistently finds no long term harm
attributable to cannabis; anti-cannabis studies and propaganda are largely funded and
deliberately mis-interpreted in public education by conflicting corporate interests such
as the pharmaceutical pill industry, alcohol industry, and prison industry. If
Government establishes a compelling interest somehow, they will not be able to prove
that a ban (with no religious exemption) is essential to that interest, just as they were
unable to in the UDV case in which a truly mind-bending substance (barely known to
science) was at stake.
12. Finally, Government will not be able to show that refusing a religious exemption is
the “least restrictive” method of achieving any compelling interest. Jamaica, India, Italy
and even the US allow religious cannabis or other banned substances without
problems. Several US religions use substances with far greater danger potential than
cannabis (whether DMT in the UDV case, or alcohol served to minors as Communion
wine).
FAIR HEARING/ DUE PROCESS BREACHES
13. The United States Constitution’s 5th,6th and 14th amendments guarantee fair hearing
and due process, rights which extend to all uses of discretion.
14. Due to racially/ethnically/culturally/religiously pejorative language in the cannabis
ban statute (see below), and also due to self-contradictions in that statute, fair trial and
due process guarantees for Government discretion in our religious land use application
are insufficient. In other words, any result but an approval will result in us rightly
claiming that the discretion-wielder was at too high a risk of having been “inherently
prejudiced” due to the wrong (offensive) and self-contradictory language of the law
itself.
15. According to relevant US Supreme Court case law (Holbrook v Flynn 475 U.S. 560
(1986) (Holbrook), discretion-wielders, once exposed to prejudicial language in
proceedings, may not even gauge their own prejudice level, but are thereafter too tainted
with risk of prejudice to wield discretion appropriately.

16. The exercise of discretion in the ongoing cannabis application is made more
complex by prejudicial language that the relevant discretion wielder (and fact-finding
tribunal) has been repeatedly exposed to. Under Holbrook, this language is fatal to our
right to a fair hearing and due process. Unfortunately, the law purportedly banning
cannabis at the federal level was enacted with demonstrably racist, nationalist, ethnicist,
and religiously discriminatory intent, and in so doing, used a word “Marihuana” [sic] or
“Marijuana” [sic]
(HEREINAFTER “THE DEPLORABLE WORD”)
which was deliberately (or even accidentally, but intolerably so) culturally/racially/
ethnically/religiously inflammatory, in that it was a slang Mexican word -- not used in
the law of Mexico, or any other country but the US -- and spelled wrong, introduced
into American parlance with overtly deliberately racist, ethnicist, nationalist, culturalist
and religiousicist intentions from the outset of cannabis prohibition.
17. Additionally, the tribunal-of-fact and wielder-of-discretion has also been placed at
too high a risk of bias by factually-incorrect language in the law, language which is so
contrary to real-world fact that the legislature’s intent is actually subject to question
(Chapman v. United States, 500 U.S. 453 (1991) ), 464-5, citing United States v.
Rodgers, 466 U. S. 475, 466 U. S. 484 (1984).
18. For example, the law purportedly banning cannabis improperly classifies it as an
“hallucinogen” at 21CFR1308.11 (d)(23), when it is not an hallucinogen. Additionally, the
law specifies that cannabis allegedly has no medical value (as a member of Schedule I
at 21CFR1308.11, but cannabis clearly does have medical value, and this has been the
subject of high profile federal litigation elsewhere.
CONCLUSION
19. In order to make the correct decision with the available discretion, all relevant laws
must be weighed, not just a single offensive law in a proverbial vacuum, since laws do
not operate that way.
20. There are established guidelines for how to balance conflicting religious rights and
substance laws, and they must be followed.

21. Correct use of discretion requires due process for applicants. That includes an
adequate opportunity to see and rebut any evidence the Government sets forth to back
up its absurd claim that cannabis is harmful enough to ban its religious use, or that their
attempts to stop cannabis have helped in any way. Applicants additionally have a right
to a fair, impartial process, one free of pejorative or inflammatory language or actions
conducted without essential or legitimate interest. Given the racial etc. problems with
the cannabis statute, and it factually-deficient language, the law itself prevents fair
hearing about it, and so any rejection will be litigated on those grounds.
22. This case seems, in common language, a bit “slam dunk”-ish for us, and represents
a capricious waste of federal resources should it be fought. The precedent that district
authorities may seek to avoid will likely include a larger geography and more publicity
if the permit is denied than if it is quietly granted.
23. The burden of proof is Government’s, not the applicant’s, and any discretion-
wielder thinking otherwise is likely suffering the effects of the prejudicial language of
the relevant statute, which leads listeners to see cannabis use as “wrong” regardless of
legal rights, constitutional rights, or fact.
24. Please for your convenience find links to relevant statutes and case laws, below.
25. Please let us know if you have any need for clarification, on any matter, or if the
Government sets out any cannabis facts we may wish to rebut (they have a reputation
for setting out false “facts” about cannabis, you know).
Regards,
Alan Gordon, authorized agent for Anne Armstrong, primary applicant
cc Anne Armstrong

[1] In the case of Anne Armstrong and myself, and our “Cannabist” faith, the religious use of cannabis is deeply held,
demonstrably sincere,and exquisitely supported by the standardBible. It is not the discretion-wielder’s dutyto determine
whether or not the Bible actually refers to cannabis with the Hebrew word “Kaneh-Bos” (in context, describing a quite
cannabis-like holy plant). It is instead the discretion-wielder’s duty to assess, based on available evidence, whether the
applicant is sincere in her/his belief that the Bible refers to cannabis.
[2] For example:
 630 AM WPRO Protesters Disrupt Cannabis Press Conference
 NJ.Com Dozens Smoke Pot Outside N.J. Statehouse During 'Spring Smoke Out' Rally
For Marijuana Legalization
To Alan Gordon, Jennifer Smith
Alan performed this excellent legal research and analysis at my request. He speaks for me as a fellow believer
and co-applicant.
Thank you.
Jah Bless,
Anne Armstrong
Anne
Armstrong <annearmstrongri@gmail.com
>
to: JenniferSmith
<jennifer_smith@nps.gov>,
AlanGordon
<judges1412@gmail.com>
date: Thu, Apr16, 2015 at 12:57
PM
We agree to an extension of time of three days for your response to our application for a special use permit for
our Pentecost service in Roger Williams National Memorial Park.

Thank You
Anne Armstrong
...I have a vision for our State where common sense, compassion, and cooperation can re-create Rhode Island
into a place where everyone can live in abundance.
from: Smith,
Jennifer <jennifer_smith@nps.gov>
to: Anne Armstrong
cc: AlanGordon judges1412@gmail.com
Anne:Iapologize thatI didnotask for clarificationwhetherthe three dayextensionisthree
businessdaysorthree calendardays.Please letme know,andIwill letmyteamknow.Thank
youfor your flexibility.Jen
JenniferSmith
Site Manager
RogerWilliamsNational Memorial
282 NorthMain Street
Providence,RI02903
O: 401.521.7266
C: 401.595.8394
www.nps.gov/rowi

from: Anne
Armstrong <annearmstrongri@gmail.com>
to: "Smith, Jennifer"
<jennifer_smith@nps.gov>
cc: Alan Gordon <judges1412@gmail.com>
date: Thu, Apr 16, 2015 at 3:25 PM
subject: Re: Permit application
Three business days.
from: Smith,
to: Anne Armstrong
<annearmstrongri@gmail.com>,
Alan Gordon
subject: Questions re: Special Use Permit
application
Anne and Alan: Thank you for taking my call this afternoon. In order for us to finalize the review of your
application and capture information for the administrative record related to this application, I have a few
additional questions. Please respond in writing as soon as you are able to that we may continue our review.
1. Will you be distributing cannabis to the attendees of the ceremony or will attendees be bringing their own?
2. How much cannabis do you expect each attendee to consume? And what method will be used for
consumption of the cannabis?
3. Are only church members invited to participate in the ceremony?
4. If you expect only church members to participate, how will you assure us of that?
5. What materials can you provide to us to help us understand how it is that a cannabis prohibition would
infringe upon your exercise of religion?
Thank you, both. Jen
Jennifer Smith
Site Manager

O: 401.521.7266
C: 401.595.8394
www.nps.gov/rowi
rom: Alan
to: jennifer_smith@nps.gov,
Anne Armstrong
date: Fri, Apr 17, 2015 at 1:51 AM
subject: Permit ap questions answered
ATTACHED .PDFAS FOLLOWS:
Jennifer Smith
Site Manager,
Roger Williams National Monument
National Park Service
United States Department of the Interior
16th April 2015
Dear Jennifer Smith:
Thank you for your careful attention to our requested permit, and for the dedication and
professionalism with which we have been treated.
The questions you asked are highly pertinent ones, and so we shall give detailed

answers to them, one at a time, below (your questions highlighted in boldface), after
some introductory remarks.
As a general overarching principle behind the National Park Service’s use of discretion,
we recognize that common sense guidelines for health, safety, order and respect for the
public’s rights are relevant to any special use permit.
In the case of banned or semi-banned sacramental religious substances, for example:
1. The Catholic Church operating within Grand Canyon National Park serves
alcohol wine to children, but does so within the context of a long-established,
long-accepted practice, even on federal land, by what appears to be self-policing
(see EXHIBIT 1) and an implied federal recognition of the validity of self-policing.
2. The faithful in the UDV Supreme Court case previously cited, for whom an
hallucinogenic, generally-banned tea (ayahuasca) was a sacrament, had a series
of protocols in place for health, safety and good faith which were specifically
tailored to the substance in question, based on experiential knowledge and
common sense. The protocols included techniques for preventing the spread of
the sacrament to those outside the church, especially for secular use.
We recognize that while our request is analogous to the 2 previous cases, each of those
sacred materials are different from cannabis, and the cultural background context of this
specific permit application differs greatly as well.
The most important three distinctions we raise to those analogous cases are:
1. Our sacred matter is safer than alcohol, because it does not cause crime/
violence, and cannot cause lethal overdose.
2. Our Bible tells the story of a people persecuted for using “Kaneh-Bos”, and so we
are wary of non-users’ long history of attempts to suppress our faith. For that
reason, for the purposes of this permit application, and recognizing that we mean
to practice in public, we will take pains (described below) to see that no
participating attendees:
A. Are harmed by cannabis or use it unsafely.
B. Take away cannabis that was not theirs prior to the religious service.
C. Are outside of, or insincere about, their adherence to our faith, or who we
do not know for certain are trained to use cannabis only safely.

D. Litter, make nuisances, or in any other way degrade the property or
mission of the relevant site, neighboring property, or the rights of the
public (such as reasonable use and enjoyment) and of the dedicated
National Park Service employees who steward that site for the public’s
benefit.
Therefore, in order to achieve the appropriate balance of our rights and the rights and
duties of others, we offer below, in our answers to your questions, a practical set of
solutions specifically tailored for the unique substance, religion, participants, time and
place.
1. Will you be distributing cannabis to the attendees of the ceremony or will
attendees be bringing their own?
We will share cannabis-based sacred matter with fellow Cannabists as described in
Paragraph “2.” Below.
The answer to questions number 3 & 4 below (regarding church members and limitation
of who participates) also speak to this.
2. How much cannabis do you expect each attendee to consume? And what
method will be used for consumption of the cannabis?
METHODS OF USE:
We will be using:
A. A small quantity (1-2 drops, just enough to trace a symbol on the forehead) per
person of the Holy Anointing Oil recipe from the Book of Exodus 30:23,
containing primarily olive oil, along with “Kaneh-Bos” (cannabis), “Kinnamon”,
“Flowing Myrrh” (moringa oil, since modern myrrh does not flow) and Cardamom
(“Kata”, often translated as “Cassia”, but which cannot be cassia, since cassia is
just a toxic variety of cinnamon). The mental effects of the topical cannabis, at
such doses, is far less than that from a sip of wine, for a seasoned user of the
relevant substance; and
B. A sip of “bhang kefir”, a fermented milk-and-honey drink that contains small
amounts of cannabis and which has
1) no appreciable amounts of alcohol (akin to sour cream fermentations),

2) been spiritually imbued with health-enhancing properties via prayer.
This drink, in the relevant amount, would have no appreciable effect on any
regular cannabis user greater than that from the anointing rite described in our
answer to question “1.” above. We will bring, and take home, permanent ceramic
dishes, so as not to generate needless waste or accidental wind-drive litter on
the Memorial grounds or nearby State property, as a matter of spiritual duty.
C. In order to reproduce the “aroma soothing to the Lord”1, we will share a
communal “chalice” or “chillum” pipe of a type which can be used without direct
mouth contact (for sanitary purposes) and which does not risk the accidental
leaving of any “butts”, “roaches”, residue, litter, or take-away material for
bystanders. As members of a faith which our Bible says was persecuted, even in
the Biblical era/narrative itself, we exercise a discretion of our own, for our own
safety, even here in Rhode Island, the most cannabis-heavy of the US States in
terms of per capita use rates.
AMOUNT PER PERSON:
Attendees, seasoned cannabis users all, will consume far less cannabis than might
bring about negative consequences worthy of being a “compelling interest”.
That amount varies from person to person, because cannabis’ effects are largely
determined by the relative goodness or badness of faith of the person consuming it.
This is backed by our scripture and by modern science. Our faith is heavily centered
around cannabis science, and from that, we know that the human endocannabinoid
receptor – which modulate cannabis’ effects in the nervous system -- is hard-wired to
the so-called “placebo effect”2 (governing depth of belief and its health effects).
1 E.g. Leviticus 2:2 where burninganointingoil madea smoke to soothe the angry, jeaous Hebrew God’s wrath, or
all of the Old Testament’s sacrificeinstructions,in which the fatty tissues of the tribe’s healthiestgrazinganimals
made the same “God-soothing” aroma on the altar-fireas did theKaneh-Bos oil. Also see 2 Corinthians 2:14-17,
e.g. where it is written:
But thanks be to God, who . . . uses us to spread the aroma of the knowledge of Him everywhere. For we are
to God the pleasing aroma of Christ among those who are being saved and those who are perishing. To the
one we are an aroma that brings death; to the other, an aroma that brings life. And who is equal to such a
task? Unlike so many, we do not peddle the word of God for profit. On the contrary, in Christ we speak before
God with sincerity, as those sent from God.
2 Benedetti F, Amanzio M, Rosato R, Blanchard C.Nonopioid placebo analgesia ismediated by CB1 cannabinoid
receptors. Nat Med. 2011 Oct 2;17(10):1228-30.doi: 10.1038/nm.2435

This means that when a person uses cannabis, her/his depth of belief is heightened.
Therefore, if prayer and good faith have positive health benefits (and the lack of them
fails to bring good health) as is commonly known fact attested to by science3 and the
Bible4,5 then cannabis amplifies the health effects, good or bad, of faith.
Because scripture agrees with science about this point, we believe that the safe and
healthy amount of Kaneh-Bos (cannabis) for any person to use is truly a matter of that
person’s good faith, because no one would in good faith even risk using too much
cannabis, nor would have any desire to use more than an appropriate amount.
For example, in the Book of Numbers, 11:16-29, seventy elders of the Hebrew tribe are
anointed with Kaneh-Bos oil via special permit, but 2 more men anoint themselves
without any such license. Nonetheless, the 2 men who have no license are in good
faith, and so they obtain the best health benefits from the Kaneh-Bos anointing --
despite their statutory non-compliance with the Kaneh-Bos restriction -- and are given
only praise when a legal complaint is filed against them to Moses.
The answer to questions number 3 & 4 below (regarding church members and limitation
of who participates) also speak to this.
3. Are only church members invited to participate in the ceremony?
Attendance is open to seekers, however, we will share our personal sacred matter
(“Kaneh-Bos”/cannabis) only with a small closely-held circle of co-Believers, as defined
with more precision in EXHIBIT 2.
4. If you expect only church members to participate, how will you assure us of
that?
This question’s simple answer is: by not sharing sacred matter (“Kaneh-Bos”/cannabis)
with any persons who are not closely held co-faithful Cannabists. All attending
Cannabists will be familiar with this protocol.
5. What materials can you provide to us to help us understand how it is that a
cannabis prohibition would infringe upon your exercise of religion?
3 Benson, Hebert MD. The Relaxation Response. Harper CollinsNew York 1975, reissue2000.
4 Luke 17:19, when Jesus tells a grateful ex-leper that his faith has made him whole.
5 James 5:14-15, where James writes
“Is any among you sick? Let them call the elders of the church to pray over them and anoint them with oil
in the name of the Lord and the prayer offered in faith will make the sick person well. The Lord will raise
them up. If they have sinned, they will be forgiven.

The primary material is this, our statement of sincerely held religious belief that we must
exercise our faith, in the described manner, at the applied-for time.
To be more specific, it is our belief that the ancient Hebrew prophets saw forward in
time to this era, and saw this dispute, in the State of Rhode Island, in federal Park
jurisdiction, calling public awareness to the overarching theme of Roger Williams
National Monument: it is the birthplace of, arguably, global (and not just US) religious
freedom.
We believe that this time and place were fore-ordained for this act, and that we are
called to the task as a matter of duty, on the day foretold, Pentecost, Shavuot,
Havdalah, 5/23/2015.
Our religious practice is a sincere and genuine (if rare) one, involving a detailed, rich
belief system regarding Kaneh-Bos in scripture and its central relevance to the Bible’s
narrative.
To deny a permit would substantially interfere with our religious duty to act, and only if
necessary negotiate-or-litigate, because:
A. We were given to believe that the Park Service’s initial leaning, based upon legal
advice, was that permits could not be issued for substances banned by the
Controlled Substances Act, which indicates that the use of cannabis (a sacred
material to us, which we are certain is the same as the Bible’s “Kaneh-Bos”) was
the reason for concern. Therefore, a denied permit to gather for the very
purpose we seek to fulfill represents a denial of permission to use our most
central sacred substance, a substantial burden to our religious practice.
B. Use of a public park always requires (for the public’s shared sake) orderly
arrangements, so that everyone’s rights are always balanced. Use of the park at
this scale, and which borders on being controversial, no matter how lawful,
properly requires a permit and planning with site staff, as a matter of public order
and plain decency (e.g. if 2 religious groups want to use the same spot/time,
there must be a way to share), and so lack of a permit could make the gathering
a prima facie offense against orderly use of public land, exposing the attendees
to criminal or civil burdens or sanctions -- a significant burden to religious
practice.
C. Most importantly, given the prevailing attitude among discretion-wielders that
cannabis is unlawful regardless of specific exceptions to the law, a permit denied
on those grounds would leave us presumptively subject to criminal and/or civil
burdens such as investigation, property confiscation, arrest (including violent
force), charge, bail guarantee, court appearances, legal expenses, and actual

formal penalties beyond that. In truth, the fear those procedures engender is
probably a religious burden unto itself, but, given that we have announced our
certain intention to carry out our ritual (as the prophets predicted), we would be
highly vulnerable to near-certain persecution without the applied-for permit. It
cannot be acceptable to tell a person who is in good faith seeking religious rights
against an administrative ban, that they may or may not be criminally burdened
for it, and therefore may not ask after the right until they suffer abuse of it.
Thank you for the opportunity to further explain our further explain and practices.
Please do not hesitate to ask for clarification or details, or, should any party raise a
relevant concern we have not covered, we welcome our opportunity to meet or
rebut the concern once raised, and look forward to your reply in any event. We
realize this is not the easiest permit request to field, and are deeply grateful for your
challenging work at the National Park Service.
Grateful regards,
Anne Armstrong and Alan Gordon, co-applicants
99 HudsonPondRd. WestGreenwich,RI02817
401-304-6020/304-6543 Anne Armstrong email Alan Gordon email
This joint correspondence will be sent via email from both signatories, as indication of
its mutuality.
2 ATTACHMENTS:
1. Exhibit 1
2. Exhibit 2
EXHIBIT 1
From http://www.usccb.org/prayer-and-worship/the-mass/order-of-mass/liturgy-of-the-
eucharist/guidelines-for-the-reception-of-communion.cfm accessed 16th April 2015
GUIDELINES FOR THE RECEPTION OF COMMUNION
On November 14,1996,the National Conference of Catholic Bishops approved the following guidelines on the
reception of Communion. These guidelines replace the guidelines approved by the Administrative Committee ofthe

NCCB in November 1986.The guidelines,which are to be included in missalettes and other participation aids
published in the United States, seek to remind all those who may attend Catholic liturgies of the present discipline of
the Church with regard to the sharing of Eucharistic Communion.
FOR CATHOLICS
As Catholics, we fully participate in the celebration of the Eucharistwhen we receive Holy Communion. We are
encouraged to receive Communion devoutlyand frequently. In order to be properlydisposed to receive Communion,
participants should notbe conscious ofgrave sin and normallyshould have fasted for one hour. A person who is
conscious ofgrave sin is not to receive the Body and Blood of the Lord without prior sacramental confession except
for a grave reason where there is no opportunity for confession. In this case,the person is to be mindful ofthe
obligation to make an act of perfect contrition, including the intention ofconfessing as soon as possible (canon 916).
A frequent reception of the Sacramentof Penance is encouraged for all.
FOR OUR FELLOW CHRISTIANS
We welcome our fellow Christians to this celebration ofthe Eucharist as our brothers and sisters.We pray that our
common baptism and the action of the Holy Spirit in this Eucharist will draw us closer to one another and begin to
dispel the sad divisions which separate us.We pray that these will lessen and finallydisappear, in keeping with
Christ's prayer for us "that they may all be one" (Jn 17:21).
Because Catholics believe that the celebration ofthe Eucharist is a sign of the reality of the oneness offaith,life, and
worship,members ofthose churches with whom we are not yet fully united are ordinarilynot admitted to Holy
Communion. Eucharistic sharing in exceptional circumstances byother Christians requires permission according to
the directives of the diocesan bishop and the provisions ofcanon law (canon 844 §4). Members ofthe Orthodox
Churches, the Assyrian Church of the East, and the Polish National Catholic Church are urged to respectthe
discipline oftheir own Churches. According to Roman Catholic discipline, the Code of Canon Law does notobjectto
the reception of Communion byChristians ofthese Churches (canon 844 §3).
FOR THOSE NOT RECEIV ING HOLY COM M UNION
All who are not receiving Holy Communion are encouraged to express in their hearts a prayerful desire for unity with
the Lord Jesus and with one another.
FOR NON-CHRISTIANS
We also welcome to this celebration those who do not share our faith in Jesus Christ.While we cannot admitthem to
Holy Communion, we ask them to offer their prayers for the peace and the unity of the human family.
© 1996, United States Conference of Catholic Bishops
EXHIBIT 2
Definition of “Cannabists” With Whom We Will Limit the Sharing of Sacred Matter
For the purposes of this application, “Cannabists” are those persons whom we have
seen over time, in their day to day lives (and not just at weekly services) demonstrate a

shared, sustained commitment to the following values:
A. Recognition and scholarly study of the role of cannabis (“Kaneh-Bos”) in
standard Judeo-Christian scripture as a healing sacrament(al), and the legal
battles surrounding its use depicted in scripture.
B. Recognition that taking any sacramental or medicine -- no matter how inert -- in
bad faith can bring either negative consequences, and/or bring about the failure
of intended benefit as per:
1) the Kaneh-Bos anointing oil example Numbers 11:16-29; and
2) 1 Corinthians 11:27:34 , where it was noted that those faking good
faith, to get sacrament, were not made well by it, and that their
discomfort was but just an earthly reminder of the One to whom they
were lying.
3) Matthew 15:16, where it is said that a man’s conscience is more
important to his health than the statutory compliance with which he
selects his foods.
C. Recognition that a person not known to be in generally good conscience, and
sincere in their faith, is not a person with whom to share sacred matter.
D. Recognition that sacred matter is to be treated with great reverence, even amidst
the faith, hope and compassion with which all sacred sharing -- whether in
celebration or mourning -- should occur.
E. Recognition that in novice users, cannabis can cause anxiety, but that it is easily
remediable via a number of over the counter items, such as the smell of fresh
cracked black pepper6.
6 Russo E. Taming THC: potential cannabis synergy and phytocannabinoid-terpenoid entourage effects. Br J
Pharmacol.2011 Aug; 163(7):1344–1364.

rom: Smith,
to: Anne Armstrong
Alan Gordon
subject: Re: Questions re: Special Use
Permit application
Anne and Alan: Thank you for your quick response to our questions. I will forward on to the
members of our internal review team. I neglected to include one question and I apologize for
asking for more clarification.

How will you prevent those who have ingested cannabis from driving impaired after the
ceremony?
Thank you, in advance, for you reply. Jen
from: Alan
cc: Anne Armstrong
subject: Re: Questions re: Special Use
Permit application
Dear Jennifer Smith --
Thank you for the follow up question, as it is one we are used to considering. We're going to have to factor
several points in formulating our answer.
First and foremost, few of us were planning to drive, so we had not devised any extraordinary or special
measures beyond the day-to-day driving safety which all driving-licensed Cannabists manage. Evidence of this
is the fact that none of us have ever been even charged with cannabis-impaired driving despite years and
years of use.
Second, and equally important, the dosage amounts and methods to be used are not ones capable of causing
impairment in the experienced users in attendance after the duration between the ceremony and its end (when
people could drive). This is often true of Catholic Communion wine, as well, but that institution is never asked
to prove it, or to have prevention protocols in place. Unlike the Catholic Church, we do not give sacred matter
to strangers, or persons unknown to us, or even persons whom we do not positively know can manage safe
transportation.
The Catholic Church in Grand Canyon National Park (an area where safety and alertness are important)
has no policy regarding sobriety of those who take communion wine, nor any practical way of stopping non-
Catholics from taking wine, other than the honor system in front of God.
EXHIBIT 1 shows the Catholic policy for wine safeguards, and it includes quite little substance beyond warning
of God's judgment (nothing of children, alcoholism, or impairment). While shuttle buses run the Canyon's South

Rim, allowing religious wine-drinking persons to Commune without driving at all, downtown Providence has an
even greater range of transportation services available which Believers may use.
Due to the site's wider range of transportation options (compared to the Grand Canyon South Rim Church site),
and due to our refusal to share Communion with those not known to us as long-term safe users, we therefore
legitimately claim to exercise even more caution than that asked of the Catholic Church's use of wine on
children (some of whom are old enough to drive and may be licensed or permitted to do so without sobriety
checks).
Catholic wine communion is known of and trusted by society, and so that Church is not asked to provide as
many safeguards or proofs of safety despite their drug's horrible reputation for addiction, diseases, impairment
and violence. In our case, our faith is unusual to people, and so society may expect a higher standard from us
despite the relative safety of our sacred matter. Nonetheless, religious freedom should not be tailored to meet
other people's desires, only the latter persons' rights if the two collide. For this reason, we do not feel it is
appropriate to accept any more burden upon our religious practice than is asked of the Grand Canyon Catholic
Church.
If Government claims that driving from religious worship is so dangerous that it must be stopped, then
1. it is their burden to show it under RFRA (and we must have a chance to rebut), and
2. the "least restrictive means" test from the RFRA law shows that Government, if they wish more safety than
the discretion asked of alcohol users, has the burden, option and responsibility to prevent impaired driving (and
not prevent worship per se over it) unless they are prepared to prove that a total ban is the only safe way.
Finally, if you or other parties wish to suggest any novel, low-to-no burden solutions to the driving issue, we are
always willing to listen and work with those approaching us in good faith, so that we may strengthen our Faith's
position in the world.
We hope these answers are satisfactory, and we remain eager to address any Park Service concerns for the
good of all parties.
rom: Smith,
to: Anne Armstrong
Alan Gordon
date: Wed, Apr 22, 2015 at 12:53 PM

subject: Roger Williams NM Special Use
Permit
Anne and Alan: I am writing to let you know that I have just put the permit in the mail to you to the address from
your application. Please review all of the materials I have sent and if you agree with the terms and conditions of
the permit, please sign and mail back to me. I will get the necessary signatures on my end and will send the
executed permit to you. If you have any questions leading up to your event, please do not hesitate to contact
me. Have a great day. Jen
Jennifer Smith
Site Manager
O: 401.521.7266 ext. 201
C: 401.595.8394
www.nps.gov/rowi
from: Anne
subject: Re: Roger Williams NM Special Use Permit
Hi, Jennifer,
Thank you for your assistance in this matter. May we please have an electronic copy of the permit and terms
and conditions today before COB?
We have previously granted an extension, and are most eager to review what is written therein. Time is of the
essence for us, because 5/23/15 is a once - ever convergence for humanity in the global awakening.
Thank you very much for everything you do.
Jah Bless,
Anne Armstrong
from: Smith,
to: Anne Armstrong

cc: Alan Gordon
subject: Re: Roger Williams NM Special Use
Permit
Sure, Anne. Please see attached. Thank you, Jen
Jennifer Smith
Site Manager
O: 401.521.7266 ext. 201
C: 401.595.8394
www.nps.gov/rowi
ATTACHMENTS ASFOLLOWS:

(PAGES4-6 TRUNCATED FORBREVITY)

from: Anne
date: Thu, Apr 23, 2015 at 9:30 AM
subject: Re: Roger Williams NM Special Use Permit
Thank you for your response.
We require a permit for our worship service which includes communion and sharing of our KNH BOS based
sacramental matter.
Can you please change the wording on the permit to say 'Communion Service Based on Exodus 30:23' instead
of prayer service?
Also, can you please amend the cover letter to make it explicitly clear that no law enacted by Congress or any
other agency of the State abridges our right to worship according to our interpretation of scripture?
It would help if you could also make clear that your Park Police will protect our First Amendment rights against
encroachment by any other agencies. As it stands, the text of your cover letter is chilling and causes me
anxiety by raising the spectre of arrest if we should share sacramental matter in communion in this site devoted
to religious freedom.
Jah Bless,
Anne Armstrong
from: Smith,
to: Anne Armstrong
cc: Alan Gordon
subject: Re: Roger Williams NM Special Use
Permit
Anne and Alan: Thank you for your email in response to my sending the electronic version of the Special Use
Permit for your event on May 23. We have provided a draft permit to gather and conduct a religious service, for
the time and the numbers you requested. None of the requests noted in your email dated April 23 would seem
to require any changes to the language of the permit. In order for the permit to be fully executed, I will need you
to return the signed permit to me. I will, then, get the signatures needed on my end and will return a final copy
to you for your records. Thank you very much. Jen

Jennifer Smith
Site Manager
O: 401.521.7266 ext. 201
C: 401.595.8394
www.nps.gov/rowi

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