Testimony before the Maine Joint Committee on Appropriations and Financial Affairs Regarding Providing Additional Monies to offset the Proposed Ban on the Sale of Flavored Tobacco and Vapor Products

Chairwoman Breen, Chairwoman Pierce, Members of the Committee:

Thank you for your time today to discuss the issue of providing one-time monies to offset the potential loss of revenue due to a possible ban on the sale of tobacco and vapor products in Maine. My name is Lindsey Stroud and I am a Policy Analyst with the Taxpayers Protection Alliance (TPA). TPA is a non-profit, non-partisan organization dedicated to educating the public through the research, analysis and dissemination of information on the government’s effects on the economy.

As lawmakers attempt to address the critical issue of youth use of age- restricted products (including electronic cigarettes and vapor products), some policymakers are seeking to ban sales of flavored tobacco and vapor products. As Maine lawmakers understand, this policy would create a fiscal loss in revenue, but would ultimately provide even less money to programs that can both help smokers quit and prevent youth use of age restricted products.

One-Time Funding Will Not Address Future Funding Deficit in Wake of Ban

Prior to announcing a flavor ban, cigarette tax revenue was already decreasing in Maine. In 2017, the Pine Tree State collected $130.2 million in cigarette tax revenue, this amount decreased by 13.4 percent to only $112.8 million in 2019. (See Supplemental Graph 1)

In the latest budget, Gov. Janet Mills introduced a one-time funding increase of “$32 million to replace the lost revenue from ending the sale of flavored tobacco products.” This legislation will not address the future costs of the ban, and heavily relies on one-time funding relief from the federal government.

With certainty, a ban on flavored tobacco and vapor products would lead to an even greater loss of revenue without decreasing smoking rates as menthol smokers in Maine are likely to travel to neighboring states to purchase menthol products. This has been demonstrated in Massachusetts, which banned the sale of flavored tobacco and vapor products, including menthol cigarettes and took effect June 1, 2020.

An analysis by the Tax Foundation found that “Massachusetts’ flavor ban has not limited use, just changed where Bay Staters purchase cigarettes.”[i] The analysis noted that sales of cigarette tax stamps in the Northeast “have stayed remarkably stable,” and that “Massachusetts sales plummeted, but only because those sales went elsewhere.”

The Tax Foundation’s analysis found that sales of cigarettes “skyrocketed” in New Hampshire and Rhode Island – growing 55.8 percent and 56 percent, respectively, between June 2019 and June 2020.

Indeed, in fiscal year (FY) 2019, New Hampshire collected $198.8 million in tobacco tax revenue, this increased by 6.9 percent to $212.5 million at the end of FY 2020.[ii] For the first 6 months of FY 2021, the Granite State has collected $130.6 million in tobacco tax revenue – nearly 66 percent of what the state collected in FY 2019.

Meanwhile, Massachusetts is losing even more tobacco revenue in the aftermath of the statewide flavor ban. While it was projected that the state would lose an estimated $93 million in the year after implementing the ban, it is now projected that Massachusetts may actually “forgo more than $120 million in tobacco taxes over this fiscal year.”[iii]

Better Allocation of Existing Funding – Not Bans Would Address Youth Use, Help Adults Quit

While Gov. Mills’ intentions of setting aside one-time funding of $32 million to help offset the costs associated with loss revenue, Maine lawmakers do have the tools available to address both youth use and help smokers quit: allocating additional monies from tobacco revenues to tobacco control programs.

Early on, the Pine Tree State was lauded in a 2003 U.S. Senate hearing for dedicating substantial portions of their tobacco settlement payments “to fund comprehensive tobacco prevention programs.”[iv] It was noted that, “Maine went, in 4 years, from a state with the worst youth smoking rates to one of the best, from over 39 percent to 20 percent.”

Sadly, Maine, each year, Maine allocates less and less funding on tobacco control programs – including education, cessation, and prevention.

Between 2000 and 2019, the Pine Tree State allocated only $231.9 million towards tobacco control programs.[v] This is only 9.8 percent of what Maine collected in cigarette taxes in the 19-year time span between 2000 and 2019 and only 21.9 percent of MSA payments the state collected in the 20 years. To put it in further perspective, in 19 years, Maine allocated only 6.7 percent of tobacco settlement payments and taxes on programs to prevent tobacco use. (See Supplemental Graph 2)

Breaking the numbers down leads to an even bleaker picture as Maine has consistently dedicated less and less funding towards tobacco control programs, even as the state as received increased cigarette tax revenue and tobacco settlement payments stemming from the 1998 lawsuit in which Maine, with 45 other states, reached “the largest civil litigation settlement in U.S. history” through the Master Settlement Agreement (MSA).[vi]

For example, in 2000, the Pine Tree State received an estimated $74.9 million in cigarette taxes and $44.3 million in MSA payments. In the same year, the state allocated $18.8 million in state funding towards tobacco control programs. In 2019, Maine received $112.8 million in cigarette tax revenue and $78 million in MSA payments, yet spent only $4.8 million in state funding on tobacco control programs.

Between 2000 and 2019, cigarette tax revenue increased by 50.6 percent and MSA payments increased by 76.1 percent, yet state spending on tobacco control funding decreased by 74.5 percent. Further, annual cigarette tax revenue collections and MSA payments received have increased, on average, 3.1 and 3.8 percent, respectively. State tobacco control funding has decreased on average, by 5.9 percent annually.

Tobacco Control Funding Breakdown

In 2019, 17.6 percent of adults in the Pine Tree State were current smokers, amounting to 192,785 smokers.[vii] Further 13.9 percent of Maine adults (152,256 adults) were daily smokers. When figuring a pack-per-day, more than 1.1 billion cigarettes were smoked in 2019 by Maine adults, or about three million per day.[viii]

In 2019, Maine imposed a $2.00 excise tax on a pack of cigarettes.[ix] In 2019, Maine collected $111.1 million in cigarette excise taxes, when figuring for a pack-a-day habit. This amounts to $730.00 per smoker per year.

During 2019, Maine allocated only $4.8 million in state funding towards tobacco control program. This amounts to $24.90 per smoker per year, and $19.29 per resident under 18 years. Moreover, $4.8 million is only 2.5 percent of what Maine collected $190.8 million in cigarette taxes and MSA payments in 2019.

To put it into further perspective, for every $1 Maine received in cigarette taxes and MSA payments, the state allocated only $0.025 cents on tobacco control programs. Further, for every $1 a pack-per-day smokers spent in cigarette taxes in 2019, the state allocated only $0.034 on programs to help them quit.

Tobacco and Vapor Product Use Among Maine Youth

The latest data on youth tobacco and vapor product use comes from the 2019 Maine Integrated Youth Health Survey Data (MIYHS)[x] and the Centers for Disease Control and Prevention’s Youth Risk Behavior Survey (YRBS).[xi]

In 2019, according to the MIYHS, among Maine high school students, only 23 percent reported ever trying a combustible cigarette, and only 7.1 percent reported using a cigarette on at least one occasion in the past 30 days. Regarding vapor product use, among Maine high school students in 2019, 45.1 percent reported every trying an e-cigarette and 28.7 percent reported using a vapor product on at least one occasion in the 30 days prior to the survey.

According to data from the CDC’s YRBS, in 2019, 46.3 percent of Maine high school students reported ever-trying e-cigarettes, 30.2 percent reported past 30-day use, and 6.3 percent reported using vapor products daily. (See Supplemental Graph 3)

It is worthy to note that youth combustible cigarette use is at an all-time low. In 2019, 6.8 percent of Maine high school students reported using a cigarette in the past 30 days, an 82 percent decrease from 1995, when 37.8 percent of high school students smoked cigarettes. Further, daily cigarette use has decreased by 91.9 percent from 16 percent of high school students reporting daily smoking in 1995 to 1.3 percent in 2019. (See Supplemental Graph 4)

Vapor Product Emergence Correlates with Lower Young Adult Smoking, Has Reduced Over All Smoking

Electronic cigarettes and vapor products were first introduced to the U.S. in 2007 “and between 2009 and 2012, retail sales of e-cigarettes expanded to all major markets in the United States.”[xii] Examining data from the Centers for Disease Control and Prevention’s Behavioral Risk Factor Surveillance Survey finds that e-cigarettes’ market emergence has been more effective than MSA payments in reducing smoking rates among young adults in Maine.

In 1997, among current adult smokers in Maine, 32.9 percent were 18 to 24 years old. In 2007, this had decreased by 12.8 percent to 28.7 percent of adult smokers in Maine being between 18 to 24 years old. Conversely, 10 years after e-cigarette’s market emergence in 2009, smoking rates among current smokers aged 18 to 24 years old decreased by 24.5 percent. Indeed, in 2009, among current smokers in Maine, 18.4 percent were between 18 to 24 years old. In 2019, only 13.9 percent of current smokers were 18 to 24 years old.

Further e-cigarettes’ market emergence was associated with a larger decline in average annual percent decreases among all current smokers. Between 1997 and 2007, the percentage of current smokers decreased on average 0.98 percent each year. Between 2009 and 2019, annual percentage declines average at 1.8 percent. (See Supplemental Graph 5)

Flavors and Youth E-Cigarette Use

Despite media alarmism, many American high school students are not overwhelmingly using vapor products due to flavors. Indeed, in analyses of state youth tobacco use surveys, other factors including social sources are most often cited among youth for reasons to use e-cigarettes and vapor products.

In 2017, among Hawaiian high school students that had ever used e-cigarettes, 26.4 percent cited flavors as a reason for e-cigarette use, compared to 38.9 percent that reported “other.”[xiii]

According to results from the 2018 YRBS, Maryland high school students reported using flavored vapor products, but flavors weren’t overwhelmingly cited by e-cigarette users as a reason for use.[xiv] When asked about the “main reason” Maryland high school users used flavors only 3.2 percent responded “flavors.” Conversely, 13 percent reported because “friend/family used them,” 11.7 percent reported “other,” and 3.8 percent reported using e-cigarettes because they were less harmful than other tobacco products.

In 2019, among all Montana high school students, only 7 percent reported using vapor products because of flavors, compared to 13.5 percent that reported using e-cigarettes because of “friend or family member used them.”[xv] Further, 25.9 percent of Montana high school students reported using vapor products for “some other reason.”

In 2019, among all students, only 4.5 percent of Rhode Island high school students claimed to have used e-cigarettes because they were available in flavors, while 12.5 cited the influence of a friend and/or family member who used them and 15.9 percent reported using e-cigarettes “for some other reason.”[xvi]

In 2017, among current e-cigarette users, only 17 percent of Vermont high school students reported flavors as a reason to use e-cigarettes. Comparatively, 35 percent cited friends and/or family members and 33 percent cited “other.”[xvii]

In 2019, among high school students that were current e-cigarette users, only 10 percent of Vermont youth that used e-cigarettes cited flavors as a primary reason for using e-cigarettes, while 17 percent of Vermont high school students reported using e-cigarettes because their family and/or friends used them.[xviii]

Lastly, in 2017, among all Virginia high school students, only 6.2 percent reported using e-cigarettes because of flavors, while 11.3 percent used them because a friend and/or family member used them.[xix] In 2019, among all Virginia high school students, only 3.9 percent reported using e-cigarettes because of flavors, 12.1 used for some other reason, and 9.6 used them because of friends and/or family members.[xx] (See Supplemental Graph 6)

Effects of Flavor Bans

Flavor bans have had little effect on reducing youth e-cigarette use and may lead to increased combustible cigarette rates, as evidenced in San Francisco, California.[xxi]

In April 2018, a ban on the sale of flavored e-cigarettes and vapor products went into effect in San Francisco and in January of 2020, the city implemented a full ban on any electronic vapor product. Unfortunately, these measures have failed to lower youth tobacco and vapor product use.

Data from an analysis of the 2019 Youth Risk Behavior Survey show that 16 percent of San Francisco high school students had used a vapor product on at least one occasion in 2019 – a 125 percent increase from 2017 when 7.1 percent of San Francisco high school students reported using an e-cigarette.[xxii] Daily use more than doubled, from 0.7 percent of high school students in 2017, to 1.9 percent of San Francisco high school students reporting using an e-cigarette or vapor product every day in 2019.

Worse, despite nearly a decade of significant declines, youth use of combustible cigarettes seems to be on the rise in Frisco. In 2009, 35.6 percent of San Francisco high school students reported ever trying combustible cigarettes. This figure continued to decline to 16.7 percent in 2017.  In 2019, the declining trend reversed and 18.6 percent of high school students reported ever trying a combustible cigarette. Similarly, current cigarette use increased from 4.7 percent of San Francisco high school students in 2017 to 6.5 percent in 2019.

An April 2020 study in Addictive Behavior Reports examined the impact of San Francisco’s flavor ban on young adults by surveying a sample of San Francisco residents aged 18 to 34 years.[xxiii] Although the ban did have an effect in decreasing vaping rates, the authors noted “a significant increase in cigarette smoking” among participants aged 18 to 24 years old.

Other municipal flavor bans have also had no effect on youth e-cigarette use.[xxiv] For example, Santa Clara County, California, banned flavored tobacco products to age-restricted stores in 2014. Despite this, youth e-cigarette use increased. In the 2015-16 California Youth Tobacco Survey (CYTS), 7.5 percent of Santa Clara high school students reported current use of e-cigarettes. In the 2017-18 CYTS, this increased to 10.7 percent.

Menthol Bans Have Little Effect on Smoking Rates, Lead to Black Markets, Lost Revenue and Will Create Racial Tension

Beyond e-cigarettes, policymakers’ fears about the role of menthol and flavorings in cigarettes and cigars are overblown and banning these products will likely lead to black markets.

Data from the National Health Interview Survey (NHIS) finds nearly a third of all American adult smokers smoke menthol cigarettes. In a 2015 NHIS survey, “of the 36.5 million American adult smokers, about 10.7 million reported that they smoked menthol cigarettes,” and white menthol smokers “far outnumbered” the black and African American menthol smokers.[xxv]

Although lawmakers believe banning menthol cigarettes will deter persons from smoking those, such a ban will likely lead to black markets. A 2012 study featured in the journal Addiction found a quarter of menthol smokers surveyed indicated they would find a way to purchase, even illegally, menthol cigarettes should a menthol ban go into place.[xxvi] Further, there is little evidence that smokers would actually quit under a menthol ban. A 2015 study in Nicotine & Tobacco Research found only 28 percent of menthol smokers would give up cigarettes if menthol cigarettes were banned.[xxvii]

Moreover, there is no evidence to suggest that menthol cigarettes lead to youth tobacco use. Analysts at the Reason Foundation examined youth tobacco rates and menthol cigarette sales.[xxviii] The authors of the 2020 report found that states “with more menthol cigarette consumption relative to all cigarettes have lower rates of child smoking.” Indeed, the only “predictive relationship” is between child and adult smoking rates, finding that “states with higher rates of adult use cause higher rates of youth use.”

Lawmakers should take note that menthol sales bans will strain minority communities. Although white Americans smoke more menthol cigarettes than black or African Americans, “black smokers [are] 10-11 times more likely to smoke” menthol cigarettes than white smokers.[xxix]

Given African Americans’ preference for menthol cigarettes, a ban on menthol cigarettes would force police to further scrutinize African Americans and likely lead to unintended consequences. 

A 2015 analysis from the National Research Council examined characteristics in the illicit tobacco market.[xxx] The researchers found that although lower income persons were less likely to travel to purchase lower-taxed cigarettes, “having a higher share of non-white households was associated with a lower probability of finding a local tax stamp” and “neighborhoods with higher proportions of minorities are more likely to have formal or informal networks that allow circumvention of the cigarette taxes.”

Lawmakers in Maine should reexamine the case of Eric Garner, a man killed in 2014 while being arrested for selling single cigarettes in the city. In a 2019 letter to the New York City council, Garner’s mother, as well as Trayvon Martin’s mother, implored officials to “pay very close attention to the unintended consequences of a ban on menthol cigarettes and what it would mean for communities of color.”[xxxi] Both mothers noted that a menthol ban would “create a whole new market for loosies and re-introduce another version of stop and frisk in black, financially challenged communities.”  

Conclusion & Policy Recommendations:

It is disingenuous that lawmakers would purport to protect public health yet restrict access to safer products. Rather than restricting access to tobacco harm reduction products and flavored tobacco products, lawmakers should encourage the use of e-cigarettes and work towards earmarking adequate funding for smoking education and prevention programs.

• To address youth use of age-restricted products, as well as adult use of deadly combustible cigarettes, Maine must allocate adequate funding towards tobacco control programs – including cessation services and education and prevention programs.
• In 19 years, the Pine Tree State allocated only $231.9 million toward tobacco control programs. During the same time period, Maine received an estimated $2.377 billion in cigarette tax revenue and $1.058 billion in tobacco tax settlement payments.
• During 2019, Maine allocated only $4.8 million in state funding towards tobacco control program.
• This amounts to $24.90 per smoker per year, and $19.29 per resident under 18 years.
• For every $1 Maine received in cigarette taxes and MSA payments, the state allocated only $0.025 on tobacco control programs.
• For every $1 a pack-per-day smokers spent in cigarette taxes in 2019, the state allocated only $0.034 on programs to help them quit.
• Between 2000 and 2019, state spending on tobacco control funding decreased by 74.5 percent and has decreased on average, by 5.9 percent annually.
• Existing research from other state youth surveys establish consistent findings that flavors are not the number one driver of youth e-cigarette use. Banning flavors does not address the more cited reasons that youth use e-cigarettes, including because their friends and/or family members use them, and because of “other” reasons.
• The efficacy of e-cigarettes in reducing smoking rates among young adults in Maine is apparent in CDC surveys. Indeed, 10 years after e-cigarettes’ market emergence, smoking rates among 18- to 24-year-old Maine residents decreased by 24.5 percent, from 18.9 percent in 2009 to 13. 9 percent in 2019.
• Lawmakers’ must face the reality of a larger illicit market in the wake of a ban on flavored tobacco and vapor products – prohibition does not automatically translate into reduced use, just different markets.

[i] Urlrik Boesen, “Massachusetts Ban of Flavored Cigarettes Is Getting Expensive,” Tax Foundation, August 3, 2020, https://taxfoundation.org/massachusetts-ban-on-flavored-cigarettes-is-getting-expensive/.

[ii] Department of Administrative Services, “Monthly Tobacco Tax Revenue,” New Hampshire Department of Revenue, December 2020, https://www.revenue.nh.gov/transparency/documents/new-tobacco-monthly.pdf.

[iii] Nick Murray, “What would banning flavored tobacco products mean for Maine’s budget?” Maine in Focus, Maine Policy Institute, February 11, 2021, https://mainepolicy.org/what-would-banning-flavored-tobacco-products-mean-for-maines-budget/.

[iv] Committee on Commerce, Science, and Transportation, “State Spending of Tobacco Settlement Revenues,” U.S. Senate, November 12, 2003, https://www.govinfo.gov/content/pkg/CHRG-108shrg21176/html/CHRG-108shrg21176.htm.

[v] Campaign for Tobacco-Free Kids, “Appendix A: History of Spending for State Tobacco Prevention Programs,” 2021, https://www.tobaccofreekids.org/assets/factsheets/0209.pdf.

[vi] Tobacco Control Legal Consortium, “The Master Settlement Agreement: An Overview,” August 2015, p. 1, http://publichealthlawcenter.org/sites/default/files/resources/tclc-fs-msa-overview-2015.pdf.

[vii] “BRFSS Prevalence & Trends Data,” Centers for Disease Control and Prevention, 2019, https://www.cdc.gov/brfss/brfssprevalence/.

[viii] “Quick Facts,” United States Census Bureau, 2020, https://www.census.gov/quickfacts/CT.

[ix] Maine, Tobacco Harm Reduction 101, https://www.thr101.org/maine.  

[x] Maine Public Health, “Maine Integrated Youth Health Survey Data,” 2019, https://data.mainepublichealth.gov/miyhs/home.

[xi] Centers for Disease Control and Prevention, “High School YRBS 2019 Results,” 2019, https://nccd.cdc.gov/Youthonline/App/Default.aspx.

[xii] National Center for Chronic Disease Prevention and Health Promotion, “E-Cigarette Use Among Youth and Young Adults: A Report of the Surgeon General,” 2016, https://www.ncbi.nlm.nih.gov/books/NBK538679/.

[xiii] Lance Ching, Ph.D., et al., “Data Highlights from the 2017 Hawai’i Youth Tobacco Survey,” Hawai’i State Department of Health, June 29, 2018, http://www.hawaiihealthmatters.org/content/sites/hawaii/YTS_2017_Report.pdf.

[xiv] Maryland Department of Public Health, “Maryland High School Survey Detail Tables – Weighted Data,” 2018 Youth Risk Behavior Survey, 2018, https://phpa.health.maryland.gov/ccdpc/Reports/Documents/2018%20YRBS%20YTS%20Reports/Maryland/2018MDH%20Detail%20Tables.pdf.

[xv] Montana Office of Public Instruction, “2019 Montana Youth Risk Behavior Survey High School Results,” 2019, http://opi.mt.gov/Portals/182/Page%20Files/YRBS/2019YRBS/2019_MT_YRBS_FullReport.pdf?ver=2019-08-23-083248-820.

[xvi] State of Rhode Island Department of Health, “Rhode Island High School Survey Detail Tables – Weighted Data,” 2019 Youth Risk Behavior Survey Results, 2019, https://health.ri.gov/materialbyothers/yrbs/2019HighSchoolDetailTables.pdf. 

[xvii] Vermont Department of Health, “2017 Vermont Youth Risk Behavior Survey Report Winooski SD Report,” 2018, https://www.healthvermont.gov/sites/default/files/documents/pdf/WINOOSKI_SD_%28SU017%29.pdf.

[xviii] Vermont Department of Health, “2019 Vermont Youth Risk Behavior Survey Statewide Results,” March, 2020, https://www.healthvermont.gov/sites/default/files/documents/pdf/CHS_YRBS_statewide_report.pdf.

[xix] Virginia Department of Health, “Virginia High School Survey Detail Tables – Weighted Data,” 2017 Youth Risk Behavior Survey, 2017, https://www.vdh.virginia.gov/content/uploads/sites/69/2018/04/2017VAH-Detail-Tables.pdf.

[xx] Virginia Department of Health, “Virginia High School Survey Detail Tables – Weighted Data,” 2019 Youth Risk Behavior Survey Results, 2019, https://www.vdh.virginia.gov/content/uploads/sites/69/2020/06/2019VAH-Detail-Tables.pdf.

[xxi] Lindsey Stroud, “Vaping Up, Smoking Increasing Among Teens in San Francisco – Despite Bans,” Tobacco Harm Reduction 101, July 28, 2020, https://www.thr101.org/research/2020/vaping-up-smoking-increasing-among-teens-in-san-francisco-despite-bans.

[xxii] Centers for Disease Control and Prevention, “San Francisco, CA 2017 Results,” High School Youth Risk Behavior Survey, 2017, https://nccd.cdc.gov/youthonline/App/Results.aspx?LID=SF.

[xxiii] Yong Yang et al., “The Impact of a Comprehensive Tobacco Product Flavor Ban in San Francisco Among Young Adults,” Addictive Behavior Reports, April 1, 2020, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7186365/#!po=0.961538.

[xxiv] Lindsey Stroud, “Flavor Bans Do Not Reduce Youth E-Cigarette Use,” Tobacco Harm Reduction 101, 2019, https://www.thr101.org/research/2019/flavor-bans-do-not-reduce-youth-e-cigarette-use.

[xxv] Brad Rodu, “Who Smokes Menthol Cigarettes?” Tobacco Truth, December 4, 2018, https://rodutobaccotruth.blogspot.com/2018/12/who-smokes-menthol-cigarettes.html.

[xxvi] RJ O’Connor et al., “What would menthol smokers do if menthol in cigarettes were banned?” Addiction, April 4, 2012, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3370153/.

[xxvii] Olivia A. Wackowski, PhD, MPH, et al., “Switching to E-Cigarettes in the Event of a Menthol Cigarette Ban,” Nicotine & Tobacco Research, January 29, 2015, https://www.researchgate.net/publication/271592485_Switching_to_E-Cigarettes_in_the_Event_of_a_Menthol_Cigarette_Ban.

[xxviii] Guy Bentley and J.J. Rich, “Does Menthol Cigarette Distribution Affect Child or Adult Cigarette Use?” Policy Study, Reason Foundation, January 30, 2020, https://reason.org/policy-study/does-menthol-cigarette-distribution-affect-child-or-adult-cigarette-use/.

[xxix] D. Lawrence et al., “National patterns and correlates of mentholated cigarette use in the United States,” Addiction, December, 2010, https://www.ncbi.nlm.nih.gov/pubmed/21059133.

[xxx] National Research Council, “Understanding the U.S. Illicit Tobacco Market: Characteristics, Policy Context and Lessons from International Experiences,” The National Academies Press, 2015, https://www.nap.edu/download/19016.

[xxxi] Carl Campanile, “Menthol cig ban will lead to more stop-and-frisk: Moms of Garner, Martin,” New York Post, October 16, 2019, https://nypost.com/2019/10/16/menthol-cig-ban-will-lead-to-more-stop-and-frisk-moms-of-garner-martin/.