As my personal understanding currently stands, Agencies cannot consider constitutional issues so this DEA religious guidance is a moot point. It essentially says, write DEA a letter to ask for exemption. That is consistent with the process for states to apply for federal exemption for medical cannabis programs as well, so that is technically correct, if you want to lose against DEA. I expect anyone who applies for a DEA exemption to be denied, and that denial to not be reviewable by a court; as admin agencies appear to not have power to rule on constitutional issues like religious exemptions/1st amendment employment division vs smith compelling interest test claims. Anyone who applies for and loses with DEA will lose any appeal in court because of that issue so, I currently do not see any reason for my self to personally apply with DEA, and instead am researching other non-criminal, preemptive federal exemption solutions to the religious persecution of people like me. I could be wrong. Please consult an attorney for legal advice. I am not an attorney. The following is not legal advice and is shared here for historical posterity.
So. Here’s some absolutely critical background on WHY DEA issued guidance on petitioning processes for religious exemptions to the controlled substances act:
U.S. Department of Justice, Drug Enforcement Administration, Notice of Proposed Rule Making, Registration for Religious Organizations under the Religious Freedom Restoration Act, RIN: 1117-AB66, DEA Docket No. 649, October 2024 (not printed in the Federal Register). U.S. Government Accountability Office (“GAO”), GAO-24-106630, Report to Congressional Committees, Drug Control: DEA Should Improve its Religious Exemptions Petition Process for Psilocybin (Mushrooms) and Other Controlled Substances, May 30, 2024.
https://www.gao.gov/products/gao-24-106630
https://www.reginfo.gov/public/Forward?SearchTarget=Agenda&textfield=1117-AB66
Downloaded and posted copies of the above documents:
WeedPress: The Paper Trail 
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