My Thoughts on the GDL Rule-Making Public Hearing
Following up on our post 'The ISP Have Issued Impractical & Incoherent Rules for Gun Dealer Licensing' I wanted to talk about my observations of the GDL rule-making public hearing I attended on October 24.
ISP has received, but not read, more than 5,000 comments on Gun Dealer Licensing.
I'll go out on a limb here and say most of the comments were in opposition. The two participants from the ISP were a staff attorney, and the Major tasked with GDL implementation.
There were 50-60 attendees at the hearing.
Most of the participants were FFL's who own small sole proprietor shops, or home-based FFL's. This made sense to me given how disproportionately these requirements for video/security/micromanagement would increase costs for them. For many of these business owners coming to Springfield meant closing their shops for the day just so they could attend and express their dissatisfaction publicly. I'm very glad they came.
Commentators were allowed three minutes each, and some of us elected to have a second three minute piece.
- Most comments were focused on ruinous cost, or unavailability of the proposed alarm and video requirements.
- My comments focused on the broken rule-making process, and all of us expressed a willingness to work with ISP to fix these rules. You can check out my comments here.
- The Gun Violence Prevention PAC representative didn't seem to have anything of real substance to contribute. Plus, he was the only GDL proponent/anti-gun voice to speak.
ISP appeared unaware of GDL's conflicts with existing law.
For example: it's impossible to comply with their "facial recognition" recording without violating the Biometric Information Privacy Act. Just ask Great America how much fun it is to be sued for violating this law.
What Happens Now
ISP will consider the comments given in person, and by email, and may issue revised rules. I am hopeful that FFL-IL will have a seat at the table for this new rule-making. This Act is law, so while we'd all like to see it overturned in the courts or by the legislature, those outcomes are not going to happen in a meaningful time frame.
After another 45 day comment period, the rules will go to the Joint Committee on Administrative Rules, whose co-chairman is the legislation's sponsor, Senator Don Harmon (D, Oak Park). As of now, no licenses have been issued, and there is nothing more to do. So stay tuned...
Owner of Maxon Shooter's Supplies & Indoor Range, and president of FFL-IL