In this proposed regulation regarding industrial hemp extracts ...
The definition of “Cannabinoid” references CBD, CBDA, Delta 9 THC and Delta 9 THCa however, it does not reference Delta 8 THC whatsoever. Delta-8 THC has a very similar chemical formula as Delta 9 THC, with a slight difference in molecular structure. Therefore, they cannot be considered as “the same”. To suggest so is disingenuous. Delta 8 THC must be specially referenced and not tethered to Delta 9 THC or any other cannabinoid. Each MUST be respectfully defined and addressed.

Delta-8 THC is considered legal at the federal level because it is derived from the hemp plant, instead of marijuana. Delta-8 THC is one of over 100 cannabinoids produced naturally by the cannabis plant but is not found in significant amounts in the cannabis plant. As a result, concentrated amounts of Delta 8 THC are typically manufactured from hemp-derived cannabidiol (CBD).

Further, NIH PMID: 34797727. DOI: 10.1089/can.2021.0124. Concludes that harm reduction is a central component of public health. Although the legal environment is becoming more restrictive for Delta 8 THC in comparison to Delta 9 THC, results suggest that Delta 8 THC may be equally effective for desired purposes of cannabis use and lower in undesirable or adverse effects.
With no mention of Delta 8 THC in the cannabinoid definition it brings to question if you intend to include it within the Delta 9 THC cannabinoids. Which is misleading. Wouldn't it be prudent to address them individually?

To outlaw Delta 8 THC, which is not identified or referenced anywhere in these proposed cannabis regulations, is to cut the lifeline of so many small businesses, like myself and others, in the newly emerging and lucrative industry in The Commonwealth of Virginia.