Originally published on this website November 23, 2000
Subject: TO BATF Ref: Notice #902
November 23, 2000
TO: Bureau of Alcohol, Tobacco and Firearms
Chief, Regulations Division
P.O. Box 50221
Washington, DC 20091-0221
ATTN: Notice No. 902
RE: Public Comment on Proposed Regulation Calling for Inspections Upon Demand
of Licensed Federal Firearms Dealers
Email: nprm@atfhq.atf.treas.gov
Dear Sir or Madam;
I have reviewed your proposed regulation (contained at page 52054 et seq. in
the Federal Register of August 28, 2000), which would require FFLs to conduct
gun inventories upon request, along with further unspecified but presumably
onerous requirements to be forced upon the honest gun dealer.
As you have requested public comments, I must inform you that it is my
opinion that the proposed regulations fail the first test for such rules, to
"First, do no harm". Even without letting paranoia read too much into
the open-ended "additional regulatory requirements", it is apparent
that the burden on small business will be immense. This will have the effect of
driving many small shops out of business, which should not be the intent of a
regulatory agency. If this is your actual intent, I question the need for your
organization to continue to exist.
My second test for the proposed regulation is an assessment of the value
added or benefit of enactment of the new requirements. I regret to inform you
that, in my personal opinion, your claimed benefits are not creditable, at least
on the basis of the supporting information you provided.
In conclusion, I am adamantly opposed to implementation of your
"Proposed Regulation Calling for Inspections Upon Demand of Licensed
Federal Firearms Dealers", and feel that its sole intent is to restrict my
civil rights by destroying the retail base I exercise to buy the firearms and
ammunition needed to protect my family. The proposed regulation carries an
underlying impression that you feel all firearms dealers are criminals that you
haven’t been able to catch yet and, by extrapolation, all firearms owners are
kindred spirits. If that impression is correct, it is apparent that your
organization has outlived its usefulness to the country. I hope this is a
misunderstanding.
Thank you,
Richard R. Hopkins
