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My Letter to BATF Re: Regulations

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 havenít 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



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