GOAL Responds to Target Shooters Regulations

 During the last week of July 2007 the long awaited Formal Target Shooting Firearms Roster regulations were activated. The regulations were so poorly written, that it is likely the roster will take another year to be created.

These new regulations for target firearms require the manufacturer to submit the following:

• A report to the GCAB that certifies by affidavit that the firearm is solely designed and sold for formal target shooting competition,

• the report shall identify specifications and features of the firearm which make it a formal target shooting competition firearm,

• a list of specific types of formal target shooting competition for which the firearm was designed and sold,

• any advertising or marketing materials sufficient to demonstrate that the firearm is solely sold for formal target shooting competition.

There is nothing in Chapter 177of the Acts of 2006 that implies or grants the authority to require anything of the manufacturers. As a result, GOAL has sent the following letter to the Executive Office of Public Safety, the agency responsible for drafting the regulations and creating the new roster.

_______________________________________________________

Secretary Kevin Burke

Executive Office of Public Safety

One Ashburton Place

Boston, MA 02108

Dear Mr. Secretary,

We are writing to express our strong dismay with the manufacturer’s requirements set forth in the regulations promulgated by your agency regarding Chapter 177 of the Acts of 2006, “The Formal Target Shooting Firearms Roster”. By requiring the manufacturers to certify to the state that their guns meet the regulatory definition of a "target pistol", we believe that the regulations are in conflict with the legislative intent of the law that we drafted.

In pertinent part, Chapter 177 of the Acts of 2006 states "The secretary of public safety shall compile a list, on a bi-annual basis, of firearms designated as formal target shooting firearms in accordance with this paragraph. Such list shall be made available for distribution by the executive office of public safety." Note that the Secretary of Public Safety is to designate what a formal target shooting firearm is and thus compile the list. This law places no requirements on manufacturers to certify their products in any way, nor provides any authority for the state to impose any such requirements on manufacturers.

When GOAL was approached by the Gun Control Advisory Board to help produce the regulatory characteristics of a Formal Target Shooting Firearm, we did so. The GCAB then created the physical features list that the state would use to determine if a firearm could be placed on the new roster. This list of requirements for physical features and characteristics should have been sufficient for anyone with a basic knowledge of firearms to produce a list. Such a list could have easily been compiled in a few short weeks after the bill’s passage.

Our argument is further reinforced by the fact that when your agency compiled the "Large Capacity Weapons Roster" no requirements were placed on manufacturers to prove that their products should be placed on the list. The work in creating this list of firearms meeting the statutory definition found in Chapter 140, §131 was done by members of the Gun Control Advisory Board. In this case, the GCAB used a working definition and was able to utilize manufacturer’s catalogs to quickly determine which guns that met that definition, just as it should have been done in the case of the “Formal Target Shooting Firearm Roster”.

Mr. Secretary, it is now a year after the signing of Chapter 177 and the state is nowhere close to producing a roster that should have only taken a few weeks if the legislative intent of the law was adhered to. We strongly urge that your office rewrite the regulations to adhere to the law by removing any manufacturer requirements. Once this is done, a comprehensive roster could be produced using the same approach as was done with the “Large Capacity Weapons Roster”. Fairness and adherence to the legislative intent of the law is all we are seeking.

Sincerely,

James L. Wallace

Executive Director