Reactions to the Office of National Drug Control Policy’s 2008 National Drug Control Strategy

Matthew Robinson, PhD
Professor of Criminal Justice
Appalachian State University
Boone, NC  28608
(828) 262-6560
robinsnmb@appstate.edu

This document is an assessment of the Office of National Drug Control Policy’s National Drug Control Strategy, 2008. The assessment is prepared by Dr. Matthew Robinson, co-author of Lies, Damned Lies, and Drug War Statistics: A Critical Analysis of Claims Made by the Office of National Drug Control Policy (State University of New York Press, 2007). The book assessed previous versions (2000-2006) of ONDCP’s Strategy reports for the purpose of discovering whether ONDCP is honest in its presentation of statistical information and visual graphs with regard to the effectiveness of the drug war. In a subsequent analysis, Robinson assessed the same issues with regard to the 2007 Strategy. In this document, Robinson offers a similar evaluation of the 2008 Strategy.
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 As in previous versions of the Strategy, the 2008 Strategy:

·         Reports and focuses almost exclusively on short-term declines in reported use by young people, using only Monitoring the Future (MTF) data.

·         Fails to report and focus on long-term increases in reported use by people twelve years and older according to National Survey on Drug Use and Health (NSDUH) data.

·         Fails to explain the significance of long-term drug use trends that have increased overall under ONDCP’s tenure (in spite of recent declines), and the meaning of high drug use rates relative to earlier time periods.

·         Claims to be balanced when it is not (the budget is clearly tilted in favor of reactive and supply side tactics rather than proactive and demand side methods).

·         Advocates regulation approaches rather than prohibition to reduce prescription drug abuse but fails to consider this approach for other substances that also have legitimate medical purposes (e.g., marijuana).

·         Links illicit drugs to all kinds of bad outcomes, including terrorism.

·         Sells policies such as drug testing in schools using anecdotal evidence from select schools rather than evidence from national studies.

·         Speaks about the benefits of treatment but fails to adequately fund it.

·         Claims to be winning the drug war through effective drug market disruption while simultaneously failing to report relevant statistics on price, purity, and availability.

·         Fails to present data about costs of drug use and abuse, or the drug war itself.

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These issues are discussed below with evidence from the 2008 National Drug Control Strategy.

Short-term focus

In the 2008 Strategy, as with previous versions of the Strategy, ONDCP’s focus is on the successes during the Bush Administration. It asserts that the drug war under President Bush is both balanced and effective:

Six years ago our country faced an increasing problem with drug abuse.  On February 12, 2002, the President addressed the Nation, noting that “more than 50 percent of our high school seniors have said that they’ve experi­mented with illegal drugs at least once prior to gradu­ation.” Further, a full 25 percent of high school seniors had reported using illegal drugs in the past month. It was clear that after declines in youth drug use throughout the 1980s and early 1990s, drug use in the United States had rebounded.

In response to these negative trends, the President an­nounced the release of his Administration’s first National Drug Control Strategy, a balanced approach to reducing drug use in America focusing on stopping use before it starts, healing America’s drug users, and disrupting the market for illegal drugs. The Strategy would pursue am­bitious goals: a 10 percent reduction in youth drug use in 2 years and a 25 percent reduction in youth drug use over 5 years.  … the President’s announcement marked a turning point. Results from the Monitoring the Future Study for calendar year 2002 would reveal a downturn in youth drug use after a decade in which rates of use had risen and remained at high levels.

Six years later, this decline in youth drug use continues, at a rate almost precisely consistent with the Administra­tion’s goals (p. 1).

In fact, the drug war under President Bush is not balanced as claimed, nor has it been particularly effective. Since ONDCP does not provide data on all relevant issues of the drug war (e.g., youth drug use, adult drug use, availability of drugs, price and purity of drugs, illnesses and deaths associated with drugs, treatment need and received, etc.), ONDCP cannot honestly claim its drug control policies have been effective.

This is not to say there is no good news in the drug war. The good news is that drug use among young people has fallen for several consecutive years. ONDCP’s Figure 1 shows how much use of various illicit drugs has fallen among 8^th, 10^th, and 12^th graders (combined ) between 2001 and 2007.

It is true that most forms of drug use are down during President Bush’s time in office, and it is also true that declines have been remarkably close to the two- and five-year objectives stated by ONDCP in 2002. However, these are data from “special tabulations for combined 8^th, 10^th, and 12^th graders.” ONDCP’s stated objective was to reduce drug use by 25% among 8^th, 10^th and 12^th graders, and in previous versions the Strategy, ONDCP reported on these trends separately.

Further, it is also still true that youth drug use in 2007 is significantly higher than 1991, which was three years after the creation of ONDCP (created by law in November 1988). ONDCP is silent about the significant of higher youth drug use rates twenty years after its creation. 

ONDCP’s analysis of Monitoring the Future (MTF) trends specific to individual drugs demonstrates that many forms of illicit drug use have declined among young people since 2001, as shown in ONDCP’s Figure 2. Even alcohol and tobacco use have declined, leading ONDCP to claim: “The declines in youth alcohol and tobacco use, combined with sharp declines in illegal drug use, are particularly meaningful as they demonstrate a broad shift in youth attitudes and behavior.” (p. 1). However, ONDCP is not fighting a war on alcohol and tobacco, calling into question this assertion. Further, ONDCP offers no data specifically about youth “attitudes” even though such data are available from MTF.

Later in the Strategy, ONDCP does acknowledge rapid increases in forms of other drugs — prescription drug abuse. According to ONDCP: “Although studies suggest that abuse of most substances is declining, past month nonmedical use of any prescription drug with abuse potential by 18 to 25 year-olds increased significantly from 2002 to 2007” (p. 24).

ONDCP point out: “The trends are clear. In 2006, the latest year for which data are available, past-year initiation of prescription drugs exceeded that of marijuana. Abuse of prescription drugs among 12 and 13 year-olds now exceeds marijuana use, and among 18 to 25 year-olds, it has increased 17 percent over the past 3 years” (p. 17).

Since this is the same time during which youth use of various drugs fell, is it possible youth began using more nonmedical pain relievers as a form of drug substitution? ONDCP provides no evidence to assess this possibility. In the 2008 Strategy, ONDCP still does not consider the possibility that young drug users have not really stopped using illicit drugs like LSD, Ecstasy or meth, but instead have merely switched to more readily available prescription drugs.  If true, this would suggest drug replacement rather than successful prevention.

Ignoring long-term trends

Even when the data ONDCP offers show short-term success, there is evidence of long-term failure. ONDCP downplays or altogether ignores these failures.

First, drug use among 8^th, 10^th, and 12^th graders in 2007 is still significantly higher than in 1991, the first year MTF began surveying students in all three grades. ONDCP’s Figure 1 illustrates this fact clearly, as noted above.

Second, the 2008 Strategy once again provides little discussion of drug use trends for adults (and no figures whatsoever). Its two- and five-year goals were stated not only for youth but also for adults. Yet, ONDCP does not report on progress toward its objectives of reducing adult drug use by 10% over two years and 25% over five years.

In the Strategy, it is clear that ONDCP knows what is occurring with adult drug use trends because it does mention specific statistics pertaining to adult drug use when it serves its own interests of claiming success. For example, ONDCP writes:

The Monitoring the Future Study is not the only instru­ment indicating significant declines in drug use among Americans. Data collected through workplace drug testing show similar declines in the adult workforce, providing further evidence of a cultural shift away from drug use … the percentage of work­ers testing positive for marijuana declined by 34 percent from January 2000 to December 2006. Methamphet­amine use among workers is declining after a significant increase during the first half of the decade, falling by 45 percent between 2004 and 2006. Perhaps most remarkably, overall drug test positives, as measured by Quest Diagnostics’ Drug Testing Index, show the lowest levels of drug use in the adult workforce since 1988 (pp. 1-2).

Note that nowhere in the 2008 Strategy does ONDCP provide data trends from the National Survey on Drug Use and Health (NSDUH). But it does call on such data in order to “prove” that the drug war is working (as in the above quote), as well as to generate alarm, as in the following quote: “One of the more disturbing data trends identified in the past several years is a dramatic rise in current drug use among adults aged 50-54 “ (p. 2).

It is dishonest of ONDCP to claim success in meeting its goals of reducing drug use by 10% and 25% over two and five years, respectively, when ONDCP is only assessing drug use trends for young people and not adults. How can we know if ONDCP’s efforts work when we are only shown data on youth drug trends and not adult drug trends?

Imbalanced drug war

Although ONDCP again claims its drug war is balanced, two facts illustrate the imbalanced nature of the drug war.

First, a review of the number of pages devoted to each of the three ONDCP drug war goals (reducing drug use, healing drug users, and disrupting drug markets) shows that the drug war is not balanced. For reducing use, ONDCP devotes 15 pages. For healing drug users, the Strategy offers 11 pages. Finally, for disrupting drug markets, the Strategy devotes a full 23 pages, including numerous claims and figures which firmly link the drug war to the war on terrorism. Thus, roughly 47% of the Strategy deals with market disruption, 31% with reducing drug use, and 22% with healing drug users.

Second, a review of FY 2009 spending requests also shows the imbalanced nature of the drug war. The FY 2009 drug war budget shows that funding for supply side measures will grow to 65.2% of total funds, versus only 34.8% for demand side measures.

ONDCP’s figure 7 shows the so-called “balanced” drug war budget.

This is astounding, because even after a budget format change by ONDCP in 2003 (which had the effect of creating the appearance that a larger portion of funds were going to prevention and treatment, even though the vast majority was really going to supply side measures), the disparity between supply side and demand side spending has grown rapidly. In FY 2002, supply side spending made up 55.1% of the budget, then grew to 56.6% in FY 2003, 58% in FY 2004, 60.4% in FY 2005, 63% in FY 2006, 63.4% in FY 2007, 64.4% in FY 2008, and ultimately 65.2% in FY 2009. Our Figure A illustrates the growing disparity between supply-side and demand-side spending.

To be clear, the supply-side spending is money spent on the “war” part of the drug war, including law enforcement, interdiction, and international spending.

Unfortunately for ONDCP and our nation, research shows that the most effective and cost-effective drug reduction approaches are demand side approaches such as prevention and treatment. One might then wonder why funding for these demand side measures has fallen from 49.6% in FY 2001 to only 34.8% for FY 2009.

Research very clearly points out that drug treatment works. One might then wonder why funding for drug treatment does not make up a larger portion of the drug war budget (funding for treatment in FY 2009 consists of only 24.1% of funds, and this includes money spent on treatment research)?

Research also shows that well-designed prevention messages reduce drug use among young people. One might then wonder why funding for prevention does not make up a larger portion of the drug war budget (funding for prevention in FY 2009 consists of only 10.7% of funds, and this includes money spent on prevention research)?

Thus, most of the money in ONDCP’s FY 2009 drug war budget is truly intended for “fighting” the drug war, not for those efforts that are more cost-effective and efficacious — preventing drug use & drug abuse and for healing drug abusers through treatment.

Promoting regulation of prescription drugs

ONDCP discusses prescription drug abuse in the 2008 Strategy, again pointing out that it is the second highest form of illicit drug use in the United States behind marijuana. ONDCP notes “a rising and troubling threat: the abuse of prescription drugs. The only major category of illegal drug use to have risen since 2002, prescription drug abuse poses a particular challenge, as these substances are widely available to treat legitimate medical conditions and can often be obtained within the home” (p. 3).

ONDCP notes it “is aggressively con­fronting this challenge, raising awareness of the dangers of prescription drug abuse through the National Youth Anti-Drug Media Campaign; supporting random student drug testing programs; educating families, medical profes­sionals, and school officials; investigating illegal online pharmacies, and by supporting State-level Prescription Drug Monitoring Programs (PDMPs)” (p. 3).

Further, ONDCP again advocates regulation rather than prohibition to solve the problem through the “Prescription Drug Monitoring Program (PDMP).” With prescription drug abuse, ONDCP is advocating compassionate regulation.  Yet, as in the past, ONDCP fails to consider this approach for other illicit drugs, even those that have legitimate medical purposes such as marijuana. ONDCP dismisses medicinal uses of marijuana in a text box titled “The Medical Marijuana Movement: Manipulation, Not Medicine” (pp. 18-19). In the box, ONDCP claims:

Proponents of medical marijuana legislation or ballot initiatives have generally offered testimonials, not scientific data, that smoked marijuana helps patients suffering from AIDS, cancer, and other painful diseases to “feel better.” The same report could be made by people, be they ill or healthy, who consume heroin or cocaine. But these claims are not, and never should be, the primary test for declaring a substance a recognized medication. The medical community routinely prescribes drugs with standardized modes of administration that are safe and have been shown to be effective at treat­ing the ailments that marijuana proponents claim are relieved by smoking marijuana. Bioresearch and medical judgment, not the drug legalization lobby, should determine the safety and effectiveness of drugs in America (p. 19).

ONDCP’s dismissal of the medicinal benefits of marijuana is simply inconsistent with a large body of medical evidence.

Bad outcomes of drug use

ONDCP continues to use fear-inspiring tactics about drugs, claiming for example that there are

compelling health reasons to focus on marijuana … It is now well-accepted that marijuana is addictive and that it can induce compulsive drug-seeking behavior and psychologi­cal withdrawal symptoms, as do other addictive drugs such as cocaine or heroin. One out of every four past-year marijuana users between the ages of 12 and 17 display the characteristics for abuse or dependency, now surpassing alcohol and tobacco. The record-high average potency of marijuana today—two to three times the potency of marijuana during the 1980s—further increases the danger to marijuana users (pp. 2-3).

Perhaps most alarming is ONDCP’s claim that “Recent research has shown that regular marijuana use is associated with increased risk for long-term mental health problems, including psychosis and schizophrenia” (p. 3). This claim is based on only a handful of studies with very small sample sizes demonstrating very small effect sizes, making them wholly unreliable. Further, none of the studies actually demonstrates causality, but instead just demonstrates a correlation between marijuana use and psychological conditions (raising the possibility that people with mental health issues may be more likely to smoke marijuana, rather than the other way around).

ONDCP justifies its focus on marijuana by suggesting early use is associated with more serious problems later: “Since 2002, the Campaign’s primary focus has been on marijuana—a policy decision driven by a public health goal: delay onset of use of the first drugs of abuse (mari­juana, tobacco, and alcohol) to reduce drug problems of any kind during teen years and into adulthood” (p. 17). However, ONDCP ignores the fact that most people start using drugs with tobacco and alcohol, then move onto marijuana, two drugs we are currently not fighting a war against.

Further, ONDCP assumes a “gateway effect” of marijuana. In fact, much research illustrates that this is a spurious relationship and is actually due to factors unique to individuals and situations that make individuals more likely to use marijuana as well as other drugs (both legal and illegal).

ONDCP also blames violent crime and other bad outcomes on drugs:

Dealers often operate in residential neighborhoods where children play and go to school. Drug dealers bring with them violent gang activity, property destruction, graffiti, drive-by shootings, robberies, and juvenile delinquency. Buildings, houses, and lots are left vacant and neglected by those who flee the violence. Those left behind live in fear of retaliation if they try to work with law enforcement. Daily life for any child living in such an environment is dangerous and sometimes tragic (p. 39).

Although it is true that such outcomes are associated with illicit drugs, ONDCP never considers the possibility that such outcomes are the result not of drug use but of a national drug policy similar to alcohol prohibition (which resulted in similar outcomes).

Selling drug testing

The 2008 Strategy does not abandon its belief in the value of drug testing. ONDCP writes: “In 2008, the Ad­ministration will strengthen these efforts by helping to ex­pand random student drug testing programs to hundreds of additional schools and by encouraging all 50 States to adopt prescription drug monitoring programs” (p. 4).

ONDCP argues in favor of drug testing based on logic rather than empirical evidence:

Random testing gives students a powerful incentive to ab­stain from drug use. In schools today, most students who begin using drugs are not targeted by an unknown drug dealer. The spread of drug use throughout a school often closely mirrors the way a disease is spread—from stu­dent-to-student contact, multiplying rapidly as more and more students are affected. Random testing can provide young people with a reason never to start using drugs, protecting them during a time when they are the most vulnerable to peer pressure and the adverse health effects of drug use. Increasing numbers of employers, includ­ing the Federal Government, are randomly testing their workforces for drug use; students coming from schools with a random drug testing program will be familiar with the goals of such programs and will know the benefits of a drug-free lifestyle.

In addition to acting as a powerful deterrent and early warning signal for drug use, random testing programs are also flexible enough to respond to emerging drug trends, such as the abuse of prescription drugs—America’s biggest drug problem after marijuana. By adapting test panels to reflect current usage patterns, testing programs can easily respond to new drug threats.

By addressing the continuum of drug use from pre-initiation to drug dependency, random testing can stop the pipeline to addiction, help create a culture of disap­proval toward drugs, and contribute to safer school and work environments (p. 7).

Instead of offering data from national evaluations of student drug testing programs, ONDCP discusses data from a single school district in Pulaski County, Kentucky (p. 8). ONDCP also mentions “U.S. Department of Education grantees, as well as public and nonpublic schools with non-Federally funded ran­dom testing programs” which, according to ONDCP, “have seen declines in positive test rates, suggesting reductions in drug use” (p. 8). However, ONDCP offers no data in support of such claims.

Instead, the 2008 Strategy provides a link to a new web site about student drug testing (http://www.randomstudentdrugtesting.org/). One of the links on the site is titled “Drug Testing Works” and it claims:

Reports from schools receiving Federal grants for drug testing programs give encouraging indications that this strategy can be valuable in the effort to curb student drug use. Its effectiveness as a deterrent has also been shown in other areas where drug testing is performed, such as the U.S. Military and in the workplace. In the more than 25 years since the Department of Defense began testing service members for drugs, positive use rates have dropped from nearly 30 percent to less than 2 percent. And according to the Division of Workplace Programs, drug-use positives in the U.S. Workforce have plunged from 18 percent in 1987 to 4 percent in 2006.

So, rather than offering evidence that drug testing works, the web site (and the 2008 Strategy) discusses successes in the US military and workplace.

Treatment

In the 2008 Strategy ONDCP claims that “there are more than 20 million Americans who meet the medical definition of abuse or addiction to alco­hol and illicit drugs. This means nearly 10 percent of the U.S. population over age 12 has a diagnosable substance abuse disorder. Yet the vast majority of these people— more than 94 percent—do not realize they need help and have not sought treatment or other professional care” (p. 23). Further, “[a]lthough a significant number of drug users fit the medical profile of an addict, most users fall into a much broader category of people whose use has not yet pro­gressed to addiction. For many of these users, an accident or serious trauma may be just around the corner” (p. 23).

ONDCP advocates its “Screening, Brief Intervention, and Referral to Treatment (SBIRT) cooperative agreements” and claims that:

Outcome measures from the Federal program reveal that screening and brief intervention helps reduce substance abuse and related consequences, including emergency room and trauma center visits and deaths. Screening and brief interventions also increase the per­centage of people who enter specialized treatment; have a positive impact on factors that enhance overall health, in­cluding improvements in general and mental health, em­ployment, housing, and a reduction in arrests; and may provide a shield from further drug use. Federal program outcomes indicate that these results persist even 6 months after a brief intervention. Moreover, cost-benefit analyses of Federal programs have demonstrated net healthcare cost savings from screening and brief interventions (p. 24).

ONDCP also notes that …

in July 2006 NIDA released a publication titled Principles of Drug Abuse Treatment for Criminal Justice Populations. The publication advances the concept of ad­diction as a brain disease and the importance of treating it as such, emphasizing the need for customized strate­gies that include behavioral therapies, medication, and consideration of other mental and physical illnesses. The key message is that treatment works, reducing drug abuse, criminal recidivism, and relapses to addiction” (p. 28).

Given this, one wonders why ONDCP does not prioritize treatment to a higher degree in its drug control budget, as noted earlier.

Market disruption

The 2008 Strategy yet again lays out the logic of market disruption efforts:

As prevention and treatment programs reduce the demand for drugs and the size of the drug-using market in the United States, the efforts of Federal, State, local, tribal, foreign, and international law enforcement agencies can serve to further destabilize the business of drug producers and traffickers, reducing the scale and impeding the flow of drug profits to the criminal organizations and terrorist groups that benefit from them (p. 5).

ONDCP again asserts that “drug trafficking does indeed operate like a business, with traffickers and users alike clearly responding to market forces such as changes in price and purity, risk and reward” (p. 35). One expects ONDCP to offer systematic data to assess its market disruption efforts – price and purity data on various drugs – but this is not forthcoming.

Instead, ONDCP only offers limited evidence on specific drugs that market disruption works. For example, it claims:

By altering these market forces, law enforcement has made it more likely that those who have not used illicit drugs will never initiate use, that current drug users will seek help, and that drug dealers will face greater risks and reap smaller profits. For example, when domestic law enforcement efforts dismantled the world’s largest LSD production organization in 2000, the reported rate of past-year LSD use by young people plummeted—a drop of over two-thirds from 2002 to 2006. Similarly, between 2002 and 2006 dedicated Federal, State, and local efforts to tighten controls on methamphetamine’s key ingredi­ents contributed to a 60 percent decline in the number of superlab and small toxic lab seizures and a 26 percent decrease in past-year methamphetamine use among the Nation’s youth (p. 35).

Additional examples offered provided by ONDCP include:

Internationally, the disruption of several major MDMA (Ecstasy) trafficking organizations in Europe led to an 80 percent decline in U.S. seizures of MDMA tablets from abroad between 2001 and 2004 and a nearly 50 percent drop in the rate of past-year use among young people between 2002 and 2006. Aggressive eradication reduced Colombian opium poppy cultivation by 68 percent from 2001 to 2004 and combined with increased seizures to yield a 22 percent decrease in the retail purity of Co­lombian heroin and a 33 percent increase in the retail price from 2003 to 2004. This progress continues, with eradication teams in Colombia now reporting difficulty in locating any significant concentrations of opium poppy and with poppy cultivation falling to the lowest levels since surveys began in 1996.

Most recently, domestic and international law enforce­ment efforts have combined to yield a historic cocaine shortage on U.S. streets. Law enforcement reporting and interagency analysis coordinated by the National Drug Intelligence Center (NDIC) indicate that 38 cities with large cocaine markets experienced sustained cocaine shortages between January and September 2007, a period in which Drug Enforcement Administration (DEA) reports indicated a 44 percent climb in the price per pure gram of cocaine. This cocaine shortage affected more areas of the United States for a longer period of time than any previously recorded disruption of the U.S. cocaine market (p. 35).

ONDCP then goes on to claim that cocaine use declined in response to these achievements, yet it cites workplace drug testing data and emergency room data rather than NSDUH data as proof (pp. 35-36). ONDCP calls it “a simple truth” that “when we push against the drug problem, it recedes … we have pushed back hard—and the drug problem has indeed receded” (p. 36).

However, as with past versions of the Strategy, this one also does not provide systematic data on which to assess the efficacy of drug market disruption efforts – almost no data on drug prices, availability, costs to drug dealers and profits, and so forth. Given that the data are available, even on the ONDCP web site, why doesn’t ONDCP offer the data with regard to all drugs and for a long period of time in the Strategy so that the reader can see whether or not market disruption is working? Rather than presenting data on for readers to see, ONDCP instead claims that “unprecedented disruption in the U.S cocaine market … has been identified through analyses of drug price, purity, and other data” (p. 49).

ONDCP claims that it is successfully disrupting markets, but rather than presenting all the data about prices, purity, and availability, it offers those few specific examples and makes general statements instead. One example is: “By ensuring that prevention messages reach young people, by screening for those with substance problems and intervening, and by making it more dif­ficult and costly for young people to obtain drugs, we can ensure that this generation will experience lower rates of addiction throughout the rest of their lives” (p. 2).

To ONDCP, market disruption should be taken on faith rather than evidence. Yet, honest policy evaluation requires access to the data.

ONDCP offers its Figure 17 as proof that cocaine prices are rising and purity is declining, yet the figure offers data only from 2005 through 2007, again showing ONDCP’s propensity for short-term trends rather than long-term trends. Since long-term data are available, it is simply not acceptable for ONDCP to show such short-term trends.

ONDCP’s Figure 22 is similar, showing short-term trends in methamphetamine prices and purity.

Another example of ONDCP’s short-term focus is this: “According to DEA analysis, the price per pure gram of methamphetamine also increased during the first three quarters of 2007, rising from $141 to $244, or an increase of 73 percent. At the same time the average purity of methamphetamine in the U.S. market dropped by 31 percent, from 56.9 percent to 39.1 percent. These price and purity trends, along with consistent declines in methamphetamine lab seizure incidents, indicate that a significant disruption is occurring in the U.S. metham­phetamine market” (p. 42).

In a section about drugs crossing over the southwest border, ONDCP claims: “Enhanced border security, matched by Mexico’s dedicated fight against drug trafficking organizations, has made a significant impact on drug availability in the United States” (p. 46). Yet, ONDCP offers no trend data with regard to availability of drugs, even though such data are available.

ONDCP does offer data with regard to seizures of cocaine, which collectively seem to suggest the drug war is nearly achieving its stated objectives. For example, ONDCP writes:

Last year’s National Drug Control Strategy set an aggressive 40 percent interdiction goal for calendar year 2007, as measured against the Consolidated Counterdrug Data­base (CCDB) estimate of all cocaine movement through the transit zone toward the United States during the prior fiscal year (October 1, 2005 through September 30, 2006). The FY06 CCDB total documented move­ment was 912 metric tons, making the 2007 interdic­tion target 365 metric tons.  In aggregate, U.S. and allied interdictors removed a total of 299 metric tons of cocaine (preliminary data as of January 2008), or 82 percent of the 2007 calendar year target. Going forward, to better align the annual transit zone interdiction goal with the Federal budget process, the goal will apply to the current fiscal year rather than the calendar year. Since the FY07 CCDB total documented movement through the tran­sit zone to secondary transshipment countries (such as Mexico, Central American countries, and the Caribbean) was 1,265 metric tons, the 2008 fiscal year 40 percent interdiction goal would be 506 metric tons. However, acknowledging the 2-year gap between establishment of the national goal and any opportunity to request needed increases in capability and capacity through the fed­eral budget process, the Administration is pursuing an incremental approach to the accomplishment of the goal. Therefore, the national interdiction target for FY08 is 25 percent of the total movement documented in FY07: 316 metric tons (p. 46).

In previous versions of the Strategy, ONDCP claimed that it would need to seize 50% of the cocaine entering the country in order to cause the cocaine industry to become non-profitable. The above data show that ONDCP is falling short of this mark, and ONDCP states that: “It is important to note that the CCDB estimate of all cocaine flow toward the United States is a conservative benchmark, as it reflects only the cocaine move­ment that interagency operators and analysts are aware of and as such does not represent the total flows (p. 46). In other words, ONDCP’s assessment of market disruption performance is not reliable since it does not even know how much cocaine is available.

In Afghanistan, ONDCP admits that efforts have not been successful. For example: “In 2007, the number of poppy-free provinces increased from 12 to 15, and opium poppy cultivation decreased significantly in another 8 provinces. However, progress in these areas was more than offset by increased opium poppy cultivation in the southwest region, resulting in the production of 8,000 tons of opium in 2007, 42 percent more than in 2006” (p. 54). This is a telling admission of displacement from one area to another in response to US market disruption efforts, something also seen in South America.

At times, ONDCP admits that its efforts to destroy drugs such as marijuana though crop eradication can fail. For example: “In response to interagency efforts targeting marijuana grown outdoors, law enforcement reporting indicates that many traffickers are shifting their cultivation efforts indoors, where the risk of detection is lower and the quality and quantity of harvests are higher” (p. 42).

ONDCP’s Figure 19 suggests a positive outcome in eradication of marijuana plants. Yet, ONDCP admits that: “This surge in indoor marijuana cultivation is reflected in a 70 percent increase in indoor plant eradication between 2005 and 2006” (p. 42). That is, increased eradications may simply be the result of more indoor growing. ONDCP does not say which portion of eradicated marijuana is ditchweed, a non-smokeable form of marijuana that historically has made up as much as 90% of all plants eradicated in any given year.

In the 2008 Strategy, ONDCP once again claims that strength of marijuana is increasing:

A long-term analysis of marijuana potency conducted by NIDA has also revealed that the strength of marijuana has increased substantially over the past two decades. According to the latest data from marijuana samples, the average amount of Delta-9-Tetrahydrocannabinol, or THC, in seized samples has more than doubled since 1983. The increase in potency may be leading to an increase in marijuana treatment admissions and may worsen the mental health implica­tions of marijuana use. The Treatment Episode Data Set (TEDS) reports a 164 percent increase in marijuana admissions since 1992, and the Drug Abuse Warning Network (DAWN) has found that emergency room mentions of marijuana increased nationally from 45,000 in 1995 to 119,000 in 2002 (p. 28).

Why THC content is rising in marijuana during prohibition is apparently irrelevant, as ONDCP does not address the issue. It should be noted that in the absence of meaningful regulation, ONDCP can expect to have little impact on THC levels in marijuana.

ONDCP also claims that:

Recent lab analyses, both in the United States and Can­ada, have found that a significant percentage of samples of seized MDMA (Methylenedioxymethamphetamine, commonly known as Ecstasy) contain methamphetamine. MDMA is a dangerous drug in and of itself—and can be fatal. It becomes even more dangerous when mixed with methamphetamine and consumed by unknowing, often young, individuals. Further, although MDMA use is still far below the peak levels of 2003, consumption of the drug has begun to rebound (p. 21).

ONDCP does not explain why methamphetamine is showing up in Ecstasy, but again it likely has to do with the absence of meaningful regulation in our current prohibitionist approach.

As with the 2007 Strategy, ONDCP again offers a “Preface to Chapter Three” before it discusses market disruption. No other part of the Strategy has its own preface. In the preface, ONDCP again links the drug war to the war on terrorism.

The preface is titled “The National Security Strategy: Tackling Transnational Threats” (p. 34). In this section, ONDCP notes: “The drug trade … serves as a critical source of revenue for some terrorist groups and insurgen­cies” (p. 34).

ONDCP also explicitly links the drug war to the war on terrorism:

Since 9/11, our international drug control and related na­tional security goals have been to: reduce the flow of illicit drugs into the United States; disrupt and dismantle major drug trafficking organizations; strengthen the democratic and law enforcement institutions of partner nations threatened by illegal drugs; and reduce the underlying financial and other support that drug trafficking provides to international terrorist organizations. In a post-9/11 world, U.S. counterdrug efforts serve dual purposes, pro­tecting Americans from drug trafficking and abuse while also strengthening and reinforcing our national security. The tools, expertise, authorities, and capabilities that have been used to successfully dismantle international drug or­ganizations and their cells can be used to confront a wide range of transnational threats and help the United States achieve broader national security objectives (p. 34).

While it is likely true that terrorist groups use drug funds to support their activities, ONDCP never considers the possibility that is so because of prohibition. That is, prohibition creates a black market for illicit drugs, and terrorist groups utilize this black market in order to raise money for their activities.

Costs of drugs and the drug war

And what are the costs of the drug war? ONDCP is silent on this.

For example, ONDCP offers no data about drug induced deaths, which have risen every year since its creation. Instead of focusing on actual numbers of deaths due to illicit drugs, ONDCP claims that declining drug use trends “show that when we push back against illicit drug use we can indeed make the problem smaller. And when this particular problem becomes smaller, the real-world result is that hundreds of thousands of people are spared from addiction and lives are saved” (p. 2, emphasis added).

ONDCP also does not present data with regard to emergency room mentions of drugs, except to generate alarm. For example, ONDCP notes a “drastic increases in emergency room visits involving marijuana—a nearly 200 percent increase since the mid-1990s” (p. 3). ONDCP does not explain the significance such a trend has for its drug control policies – why are more people getting sick and going to hospitals under prohibition if use is declining?

ONDCP also fails, once again, to show accurate data on spending on the drug war. How much does the drug war cost American taxpayers, including law enforcement, court, and punishment costs? And are these costs worth the efforts given the drug war’s ineffectiveness? Costs-benefits analysis of ONDCP and the drug war cannot be accomplished without a full-presentation of the data. The Strategy — which leaves out almost all data on drug policy costs — is simply not useful for policy analysis.

Conclusion

The 2008 Strategy is very similar to previous Strategy reports — a dishonest, incomplete report that is ill-suited to assist in a truthful assessment of the nation’s drug control efforts. While ONDCP highlights the good news in the nation’s drug control efforts — and there is good news — it continues to produce a flawed assessment of the nation’s drug war. The National Drug Control Strategy appears to be little else than a document that is intended to reinforce the dominant ideology of the drug war regardless of what the relevant data show.

Careful policy analysis can determine if the drug war is meeting its goals, as well as if the benefits of the drug war outweigh the costs. The National Drug Control Strategy is a document that cannot assist in such an evaluation.

ONDCP actually claims to be winning the drug war, in spite of the absence of data in the Strategy to prove it. For example, it says:

Skeptics and advocates of drug legalization have long argued that our fight against drugs is hopeless, but the results tell us yet again that our Nation’s fight against drugs is anything but. In fact, we are winning. The nearly 25 percent decline in youth drug use and the major disruptions in the cocaine and meth­amphetamine markets have saved lives and strengthened our Country (p. 57).

As noted earlier, ONDCP has stated other drug war goals, including reducing use by adults, reducing availability of other illicit drugs, and reducing deaths associated with illicit drug use. It is dishonest for ONDCP to claim “we are winning” when it offers no data on such goals.

ONDCP intends to export its Strategy to the rest of the world. It claims: “Many countries have reached out to U.S. agencies and our Embassies around the globe for guidance on ‘what works.’ In response to these inquiries ONDCP, for the first time, will produce a report for an international audience on drug policy les­sons learned in the United States” (p. 56).

This is not a good idea, for ONDCP cannot honestly claim to the world that it knows what works. What works is not included in its Strategy report.