The ISP Have Issued Impractical & Incoherent Rules for Gun Dealer Licensing
And gun stores across the state are already closing their doors.
Don't worry though, we are not closing our doors anytime soon. In late August, the Illinois State Police issued proposed rules for the Firearm Dealer License Certification Act, which Governor Pritzker signed into law in January. You can review the rules they proposed for yourself, although it is 29 pages long, and let us know what you think.
The Act went into effect this summer but, as of now, not a single FFL has been issued a certificate. Even before any rules have been published, Illinois is losing FFL's. From September 2018 to September 2019 the number of Illinois Type 01 (retail and gunsmith) FFL's have dropped form 2,049, to 1,700.
That's a 17% drop. And this was even before any rules had been set.
Today is the last day of the first comment period on these rules. Please consider filing your comments with ISP, and the Joint Committee on Administrative Rules (JCAR).
Our quick take on the rules:
- Video surveillance requirements are impossible to implement (bandwidth restrictions), and conflict with existing Illinois law regarding the collection of biometric data.
- Definitions in these rules (eg: what is a retail location) conflict with the FDLC Act, and guidance given from ISP with the application.
- Rule-making authority is exceeded in micro-managing storage, battery backups, alarm configuration, storage of firearms and ammunition, and on and on.
- These rules appear to have been written by people who have no idea how an FFL operates. A more cynical inference upon reading these rules is that the rules' author is attempting to heap excessive costs on small businesses.
- ISP did NOT consult with any industry groups when formulating these rules. Why not?
What You Can Do
The process is simple: email ISP and FFL-IL today and express your concerns that these rules will continue to drive IL FFL's out of business, denying you your right to own firearms.
ISP email: ISP.Rulemaking@illinois.gov
FFL-IL email: firstname.lastname@example.org
FFL-IL has requested public hearings and will bring all comments received.
The Process from Here:
The first 45 day comment period is coming to a close, and we expect public hearings soon. All of these comments will be sent to the Illinois General Assembly's Joint Committee on Administrative Rules (JCAR) to open up another 45-day comment period. Once the comment periods are over, JCAR can either approve and adopt the new rules, or request new changes.
These rules must be fixed if there are to be any FFL's left in the state.
Angrily calling for lawsuits against the state might make people feel good, and they may in time yield a favorable outcome, but the immediate need is to stop this rule set from becoming law.
Please offer your comments, and please support the efforts of FFL-IL, which is deeply engaged in pushing back on this mess. Thank you everyone who has read this far, we truly appreciate your concerns and involvement in this debacle.