Cactus Conservation Institute has long held and voiced our belief that the Native American Church should control its own destiny — including in regard to cultivation. Unfortunately, our letter to the Senator’s office was interpreted by some to indicate that CCI was independently attempting to dictate to the Native American Church how to approach and conserve their sacred medicine. It has been made known to us that many felt it was hurtful. We are deeply sorry for our own missteps and any offense we have caused and wish to reiterate our dedication not only to the conservation of peyote, and other threatened and endangered cacti, but also to the cultural and religious rights and interests of the Native American Church. 

It is not our intent to dictate that NAC members should cultivate peyote, only that they should be able to cultivate it themselves, should that be their desire, and not rely upon others to do so.

We would also like to clarify some points of misunderstanding that are incorrectly being promoted online. Based on our original letter, which has since been amended, it has been claimed that CCI is a supporter of decriminalization. It has been our long-standing policy not to make political statements or to take political positions as neutrality best serves our interests and ability to engage in conservation of threatened and endangered cacti. Our comments on cultivation are the first exception. CCI takes no position on the aims or political goals of Decriminalize Nature and has no official stance on decriminalization for personal use.

Another misunderstanding has led to a claim that CCI intends to create or operate peyote greenhouses. CCI has no interest in engaging in cultivation, either through management, oversight, or any other manner. While we believe cultivation can be an important conservation tool and will continue to publish research related to cultivation, cultivation itself falls outside the purview of CCI’s mission and activities as a non-profit organization.

The circulation of this claim appears to be based on a misunderstanding of our paper exploring the logistics and production capacities of greenhouse cultivation. This paper was intended as an example to help people grasp what is involved with producing enough plants to satisfy current demand for ceremonial use and to help them visualize how many plants are involved for cultivation to be sustainable.  Without the proper context and details it can be difficult to grasp what it means to cultivate a million plants or what is involved in a rotating sustainable harvest of a million or even millions of plants.  We stand by these estimates.

The numbers presented in that paper are useful not just for examining a greenhouse scenario producing a million plants but for examining wild harvesting as well. The footprint can easily be increased from greenhouse spacing to an average spacing of a healthy wild population. This can give a nice estimate of how many square miles of habitat will be required for sustainable harvesting using good harvesting practices and a fully informed harvesting rotation. By the latter comment, we mean that the prior harvesting history of a given field is known to the harvester. This concept is invaluable; without knowing how many plants are needed to fulfill the needs of the Native American Church and without an ability to make plans accordingly, there is a risk of falling short.

It is also worth clarifying the who and what of CCI. We should first start with what CCI is not. CCI is not a government agency and is not involved in policy making or the creation or implementation of government regulations. CCI is a 501(c)(3) educational organization. CCI engages in research and shares its observations, research findings, thoughts and evidence-based suggestions with parties invested in the preservation of at-risk, threatened, and endangered cacti, including peyote, and does so at no charge.

CCI offers one voice and one view in a field where there are multiple. It is to be expected that in any field where multiple perspectives are held, or are possible, that disagreement will occur, particularly when there are cultural and ontological differences. There is also opportunity for discovering common ground and collaboration that draws on the expertise, views, and values of multiple stakeholders. As a conservation-based organization, CCI prioritizes its mission of conservation and believes that advocating for conservation is where the expertise and experience of CCI is best applied. 

For the sake of clarity, CCI would note that conservation of peyote does not imply that people should not have access to peyote for religious ceremonies. Rather, it requires that there be enough peyote to support both religious custom and the future vitality of the cactus in its native habitat. In this regard, discussions about sustainable wild harvesting and about the logistics of greenhouse production are important parts of CCI’s activities. The actual details of how peyote cultivation greenhouses are created and operated are not within CCI’s mission. Decisions and details relating to these activities are (and should be) entirely under the direction of the people doing so.

In closing, CCI would like to make clear that CCI supports the full autonomy of the Native American Church. Efforts towards cultivation by the Native American Church should be celebrated. Most importantly, the autonomy of the Native American Church as a religious organization arising from sovereign federally recognized tribes should be recognized and respected. America’s Indigenous peoples (those recognized and those not) must be allowed to chart their own course. 

We forward to future productive dialogue with those interested in the preservation of peyote and related cacti.

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This subject involves some large numbers and is easily not accurately grasped due to that. This article was created in hopes of casting some light on what will be involved with a large scale peyote production capable of providing for the needs of the NAC. This ball-parking is for 100 ft. x 100 ft. (30.48 m x 30.48 m) greenhouses producing 1 million peyotes per year once they reach an operational age after 12–16 years.

Numbers are for a 12- or 16-year planting & harvest cycle and an 8-year reharvest cycle. The 8-year rotation cannot begin until after the first 12–16 years have passed.

Obviously 1 million is not enough now so this number will not be enough in the future but this estimation will at least be able to give a sense of the music and provide people with a tool for successfully making those plans. This looks large but we are talking about a lot of plants so relax. It is quite within the realms of possibility to do this; especially if decentralized. And this has been done before but on a grander scale. Even with the longest harvest cycle and the largest size of spacings used in the table below, the total acreage for growing 10 million peyotes would only require around 1% of what is presently enclosed in the greenhouses in Holland.

Downloadable PDF of this table.

The first harvest will not be able to occur until 12–16 years after planting; possibly longer. The re-harvest cycle appears to be 8 years or so but whether the reality is 8, 9 or 10 years will require future empirical evidence. (Our regrowth study intended to provide information enabling sustainable harvesting was poached after 8 years so we could not establish an accurate number, only that it was a number at least equal to or greater than 8 years.)

To apply this to reality:
Multiply numbers above by the numbers of millions that will be needed per year.
Multiply also by the difference in square feet if smaller greenhouses are used. i.e. for 50’x100’ multiply the totals by two. For 25’x50’ multiply by four.
Add 20% for potential losses as it is better to risk abundance than a shortfall.

This does not actually begin with seeds in each of those pots. Losses would be very high. Seedlings are first grown in trays and permitted to enlarge packed closely together until they are large enough to be transplanted into pots. A good size is between 1/2 to 1 inch in diameter (~2 cm). 

Cultivation needs to be designed large enough to accommodate the future growth of the NAC as the first harvest that will become available for members will be delayed for 12-16 years after this many greenhouses have been built and planted with peyote. One or two, or even ten, greenhouses are clearly inadequate to fulfill the current or future need. The longer the lag time before starting cultivation on a significant scale, the greater the risk of wild extirpations continuing to spread (with possible wild extinction). 

It is extremely promising that two such operations are planned (by ICPI in Texas and SIA in Oklahoma).  Their projected sizes and the anticipated dates for peyote production actually coming online are not yet known. While those are welcomed and promising it is also clear they should be supported and encouraged to expand their cultivation operations as much as they have the capacity to manage but even so are going to be inadequate as the numbers in our analysis will illustrate.

To create a cultivation program of a slow growing perennial plant with projections of annual harvests in the future, an equal number of plants need to be planted every year until the operation can become sustainable on a rotating harvest basis. For peyote that cycle may be 12-16 years or it may take longer if the locale is less favorable. Peyote can be grown more quickly though light feeding and heavy watering, or by grafting, but it will be found unsuitable for use as Medicine unless enough additional time is spent under more natural conditions of growth as the mescaline content will be low (alkaloids are plant’s response to stress).

Similarly regrowth is often more numerous but the total weight of the regrowth is much less than the crown that was harvested and this takes some time to catch back up.

This phenomenon of overharvesting creating greater numbers of smaller individuals and any existing harvesting guidelines or best  known harvesting practices being ignored in commercial harvesting activity is well known elsewhere and has been reported in fish, ginseng and other natural wild resources [See Terry et al 2011 & Ermakova & Terry 2019]. Similarly the quality of two year old regrowth was found to still be inferior to unharvested crowns but the period needed for their recovery has not been established. [Kalam et al. 2013] 

See the details in Kalam, M. et al. 2013. Journal of the Botanical Research Institute of Texas, 7(1): 435–440. A preliminary report of mescaline concentrations in small regrowth crowns vs. mature crowns of Lophophora williamsii (Cactaceae): Cultural, economic, and conservation implications.
Download as a PDF

The rotation period may be able to become 8 yrs or so once that first period is passed. The exact details remain to be determined and even if the information was available each individual operation will have results that depends on their unique circumstances. These are the present estimates based on the best available information. 

Totals will depend on:

1)  Size of the greenhouses (and their micro-climate).

2) Size and spacing of benches and aisles–also whether the operation can pull off a multi-tier operation or operates on a standard single level approach.

3)  Size of pots or spacing of plants.

4) Number of million plants needed for an annual harvest but projected for the NAC membership of 12-16 years in the future.

Band pots (3”x6” & 4”x8”) are available that will allow deep taproot development with a small footprint. These could help make both harvesting and planting out easier.

Mass harvests of millions of plants per year will require good planning. Whatever numbers are projected as the goal should have 20% added to accommodate death following harvesting or potential losses from unanticipated injury or disease.

Plants can be packed more tightly together but a commercial operation like this needs an eye for the long-term future and factoring in enough space to permit harvests, and future re-harvesting from the long-lived perennial mother plants without adversely affecting subsequent harvests due to incidental damages.  (There is no reason to not believe that peyote’s potential lifespan is more than twice that of a human being. )

Even a four-inch spacing will become a challenge if this is performed sustainably. Giving those larger plants more space could be a beneficial option despite reducing the total numbers in a given greenhouse but it may be found advantageous to harden and plant out larger clusters after a period of greenhouse service and keep replacing them with new seedlings.

Spatial consideration of access and spacing is also important to avoid causing harm or repetitive stress injury to the harvesters when performing mass harvests in awkward or tight spaces. Human health and safety should always be regarded as a precious resource to protect in any agricultural operation.

A future challenge will be resisting the temptation to begin using the cultivated plants too soon. This will be counterproductive both in terms of the project and the perceptions of its viability at producing acceptable Medicine. Young or well-watered plants will not be found acceptable by experienced peyote users.

One hurdle concerns NAC members requesting the buttons be cut deep so they will stay fresh longer (accompanied by the claim that they will rot if this is not done; which actually involves HOW they are treating, transporting, storing and drying cut plants rather than the simple fact they were cut properly). Deep cutting is likely to have even greater adverse effects in a greenhouse than in the ground.  

Better education on how to cut, transport, handle, store and dry plants appears to be needed. It may be easier to pick apples after the tree has been cut down but that approach limits there being a future.

Repopulation using plants started in a greenhouse and then hardened and replanted back into their natural habitat is valuable but there are two elements of concern. Habitat restoration is valuable not just to help with establishment of the transplants but also to encourage better seedling establishment and survival of the seeds those plants will eventually produce.

The other concern is that physical repopulation using hardened seedlings should be limited to those with genetics appropriate for the locality. Plants from other geographic regions should not have their genetics or soil introduced into a nonnative local environment.

The membership in the NAC was estimated by Prue to be ~500,000 people in 2013, so clearly many greenhouses will be necessary to produce the millions of peyotes needed each year. Prue’s estimate also illuminates there is an unseen volume of unreported peyote consumed by the NAC every year as, according to Texas Department of Public Safety records, the total reported harvest for 2012 and 2013 were 1,106,209 & 1,363,978. 

See Prue 2014 (E-published in 2013). The American Journal on Addictions, 23(2): 156–161. Prevalence of Reported Peyote Use 1985–2010; effects of the American Indian Religious Freedom Act of 1994.

The nonlinear claims appearing  in the published accounts from 1959—2019 suggest that the actual numbers may not actually be known as the basis for determining them is generally omitted so an analysis of the legitimacy and origin of those numbers is not possible.  

  See a sampling of those numbers at the end of this commentary.

If we use those numbers, that total volume of reported harvests sold by the distributor could have provided every NAC peyote user with, at most, an average number of around two peyote buttons per year (2.2 per person in 2012, 2.7 in 2013 & 1.74 in 2016). Harvests had dropped to 867,674 by 2016 with the highest reported harvest of 2,317,380 occurring in 1997.

There have commonly been estimated to be more than 70 chapters according to Edward Anderson’s The Divine Cactus. More recently, it has been claimed in Guzmán & Labate 2019 that there are more than 250 NAC organizations in the USA and Canada, many of which hold regular meetings.  They cited DPS records as the source of this number but their reference is not available.

Bobby Pedro, roadman of the Northcoast NAC, related to Cactus Conservation Institute that their chapter holds, on average, 55 meetings per year. Common estimates of personal consumption that we have been told by NAC members place the number commonly consumed as being between 8 and 12 buttons per person per meeting although many people only eat four and some eat only one.

Similarly, peyote distributors sometimes slice buttons before drying them; creating more than one peyote button per crown so the reported sales will not always accurately reflect the actual number of peyote crowns harvested and sold by them.

It appears that the NACNA may now have tighter numbers generated in an internal survey concerning volume and frequency of use but the results are considered confidential and are unavailable outside of a quote about DPS estimates of membership appearing in Guzmán & Labate 2019. Moreover, the Texas DPS has now stopped collecting the peyote sales data, so even this source of information is no longer accessible.

The pertinent take-away point to understand from this is that there is far more peyote being harvested from the wild and made available to the NAC outside of what is reported in the sales of the licensed distributors (many independent harvesters exist who leave no records) so a much larger number than they have reported is going to be needed to satisfy the demand of the recognized and authorized peyote using community.
It should be made clear that this is not suggesting some sort of illegal activity is going on here. People with the right to possess peyote were also given the right, as individuals, to harvest peyote, with landowner permission, under Texas’s rules that applied to them, landowners and distributors.

Sustainable harvesting will involve flush cutting rather than angled or deep cutting and will require record keeping and tracking so no that plant is reharvested sooner than 8 or more years after the previous harvest. This will require the cooperation of distributors with each other as one commercial harvester following best practices can easily be defeated by another who does not.

We strongly believe that that best harvesting practices can be effective if properly employed, and they may well have been able to prevent the current state of crisis but it is also clear that implementation of them at this late stage of the game is too late for the majority of known populations that are accessible to harvesters. Opening up more ranches is a short sighted solution. 

Two concerns: 1) Harvesting is commonly deliberately deep as was mentioned and 2) There is no existing means of controlling the frequency a given population is harvested from unless the distributors begin to collaborate and share where they collect and when it occurs. Enough time needs to pass between harvests for the harvested plants to actually recover and abundant new growth is typically present long before that point.

The actual numbers of members and frequency/volume of consumption are vital numbers for peyote cultivators to possess as it will not be possible to effectively plan for future peyote production without knowing how much peyote is actually needed every year before making plans to produce it. 

These factors make any impediment to cultivation a major threat not only to peyote but to the future of the NAC and other peyote people.  One such threat is an attempt at banning cultivation in California rather than simply respecting the cultivation provisions that now exist in the CSA. California is the state best suited for large commercial peyote production operations and, if successful, such an action would at least delay implementation of this important activity.

One other reason more cultivation operations are imperative is in the event something occurs to one of the operations such as an unusually hard and prolonged freeze accompanied by power failure or large hail or a tornado or a major pest invasion. That could be the end of the story for quite some time if production of such a slow growing crop was not decentralized. The ideal scenario would be greenhouse operations in the hands of every NAC chapter that was able. 

A few of the many published estimates of NAC membership

  An article on Frank Takes Gun in  a 1959 Time article, 16 February, page 71 claimed that the NAC had 50,000 members.

  La Barre 1975 The Peyote Cult, 4th Edition, p. 224 quoted Hon. Yale McFate decision rendered on 26 July 1960 as giving NAC membership as 225,000.

The details of this court decision can be found in the 1961 American Anthropologist pages 1335—1337.

  Omer C. Stewart 1987 The Peyote Religion can be found quoted with a wide range of figures as high as 400,000 but in it I have only been able to locate Frank Takes Guns estimating 225,000 during his testimony in 1960 in the case involving Mary Attakai. 

  Huston Smith 1996, One Nation Under God, estimated 250,000. This same number was also provided by the NAC to researchers at the University of Virginia in 1998 for a project entitled “New Religious Movements”.

  250,000 is the most commonly encountered number and can be found presented as a current value in assorted published accounts spanning five decades.

We mentioned earlier that Bob Prue had estimated membership to be be ~500,000 people in 2013. See Prue 2014. The American Journal on Addictions, 23(2): 156–161. Prevalence of Reported Peyote Use 1985–2010. Effects of the American Indian Religious Freedom Act of 1994. 
DOI: 10.1111/j.1521-0391.2013.12083.x 
This was e-published in August 2013.

  In 2016, Sandor Ironrope put the number of NAC members at over 300,000.
See https://www.courthousenews.com/native-american-church-uneasy-with-new-influences/

  In 2019, Guzmán  & Labate commented:
  “According to data from the Texas Department of Public Safety, there are more than 250 organizations and around 650 000 members”, citing an unpublished manuscript of Walker, Walker, & Graves, 2015. The peyote research project: A preliminary final report. Walker Research Group LTD.

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Some context about this bill.

Senator Wiener has introduced legislation that would decriminalize psychedelics in the state. This initiative follows decriminalisation measures that already passed at the city level in Oakland, Santa Cruz and the District of Columbia, as well as in the Oregon state last November.

This bill would decriminalize possession and personal use of psilocybin, psilocyn, MDMA, LSD, ketamine, DMT, mescaline and ibogaine. The bill would also expunge criminal records for people convicted of possession or personal use of these substances.

Peyote, however, has been explicitly excluded from the list, to address concerns that decriminalisation would give the impression to non-Indigenous people who are not affiliated with federally recognised tribes that they now have rights to acquire, possess, use, or transport Peyote in or from Texas and would lead to increased poaching of peyote.

The bill excludes cultivation of a plant on the basis that it is threatened, which is counterproductive to its conservation. We believe that legal cultivation is critical to the survival of peyote in its native habitat and highly recommend that SB519 be amended to allow cultivation.

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