While the submission does not explicitly recommend setting 21 as the legal age for consumption of marijuana, it says that “delaying use is one of the best ways to reduce the risk of harm to the developing brain.”

It notes that numerous public health bodies are calling for 21 as the minimum and others are calling for the ages for legal consumption of alcohol, tobacco and cannabis to be aligned.

Alberta’s legal age for drinking and smoking tobacco is 18.

“Cannabis legalization represents an opportunity for Alberta to consider raising the tobacco and alcohol minimum age,” says the submission written by Dr. Gerald Predy, AHS’s chief medical officer of health.

AHS declined to comment further or make Predy available for an interview.

The brief from AHS was just one of more than 60 written submissions received by the government through its consultation process, with age a recurring issue. The Alberta Medical Association came out firmly for setting 21 as the legal age for pot consumption, while a submission by two health researchers at the University of Calgary argued for 18, saying the health risks have been overstated in many cases.

Hospitality industry bodies, such as the Alberta Hotel and Lodging Association and the Banff and Lake Louise Hospitality Association, also called for a minimum age of 18.

“Instituting a higher legal age than the age for liquor and tobacco use will likely lead to more of an illegal market for cannabis,” said the submission from the Banff group.

Alberta’s NDP government has not yet outlined its approach in areas such as taxation, minimum ages and retail systems, all of which will fall under the responsibility of the provinces as the Liberal government moves to legalize marijuana on July 1, 2018.

Ontario became the first province to address some of the issues last week, with the government announcing plans for the Liquor Control Board of Ontario — the Crown corporation that operates the province’s liquor stores — to set up a network of stand-alone pot retailers.

While Alberta has no government-run liquor stores, AHS said the province should be in control of cannabis sales.

“A government controlled system of distribution and retail would be most effective to ensure that public health goals (not profit) are the primary consideration for policy development,” said the report.

The Alberta Liquor Stores Association, however, believes cannabis sales should be done through the province’s 1,400 liquor retailers, which are regulated by the government.

“We have a proven record of safely delivering alcohol to Albertans daily, thanks to trained staff, responsible marketing communications and genuine connections to the communities we live and operate in,” said ALSA’s submission.

That was opposed by the Association of Canadian Distillers, which noted that the federal task force on legalization had recommended against the co-location of alcohol and marijuana sales as “an increased health and safety risk.”

The Cannabis Canada Association, one of a number of cannabis businesses or industry groups that made submissions to the government, said private competitive retail is the best option. In contrast to AHS, it also said marijuana companies need some ability to advertise and promote their products because of the lack of public information available.

The Alberta College of Pharmacists, meanwhile, is adamant that marijuana not be sold through pharmacies because of the potential health issues associated with cannabis use.

Numerous submissions to the government addressed issues such as driving under the influence of cannabis and safety on work sites.

Les Hagen, executive director of Action on Smoking and Health, said there is a fight going on around cannabis legalization between health and commercial concerns.

Hagen said the AHS submission in particular is a needed corrective to what he sees as a “full-throttle” push to commercialize legal marijuana by the Trudeau government, with Alberta potentially following Ottawa’s direction.

“I see Alberta moving in lockstep with the status quo … rather than saying public health is more than lip service,” he said.

The government did not make Justice Minister Kathleen Ganley available for an interview Friday.

But, in a statement, the province said that it met with over 100 stakeholder groups, including law-enforcement, industry and Indigenous groups, and that it received over 45,000 responses to its online survey on cannabis legalization — “one of the most successful government surveys in Alberta’s history.”

When the government releases its draft this fall, it will set off another round of consultations, said spokeswoman Jennifer Mitok.

“This will provide more opportunities for Albertans to share their input on the approach proposed in the cannabis framework.”

jwood@postmedia.com