No, they set out findings of fact that you haven't been able to refute in any particular.
They basically assume that anything that is involved in interstate commerce is subject to Congressional regulation.
Your statement just begged the question. Ironic.
The CSA relies on supreme court jurisprudence which, I also demonstrate in my essay, was faulty. YOU are the one begging the question. In order for the question of a substance having a "substantial effect" on interstate commerce to be relevant, you must first demonstrate that the commerce clause was intended to confer on Congress the power to regulate all activity directly or indirectly connected to commerce.
So, prove it. Or else it is YOU who is begging the question. Show me the founding father who comprehended the commerce clause in such a way. Refute my quotes above from James Madison on the subject.