LETTER FROM THE NAR PRESIDENT By Mark "Bunny" Bundick I'm drafting the NAR's response to Notice 968, the ATF's NPRM. I'm offering the bullet points below to further stimulate your thinking around responding. Many of you offered very helpful comments to me about this NPRM, and I've tried to incorporate them into the NAR's response. Also, be aware that I've forwarded my complete draft, now at 8 pages, and about 65% complete, I think, to our counsel for review. I'll keep plugging away on this, but since we're 3 weeks away from the deadline, I wanted to be sure that you had some of this in hand. PLEASE, PLEASE, PLEASE REMIND YOUR SECTION MEMBERS TO SUBMIT COMMENTS! Even if it's only a letter saying "I support the positions of the NAR", the absolute numbers will help, both with respect to the NPRM, and to the ongoing congressional fight. MAIL THOSE LETTERS ASAP, FOLKS! Cheers, Bunny = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = NAR opposes the imposition of the proposed regulations for the following reasons: · ATFE lacks statutory authority to regulate, in any way, propellant under Title 18 of the United States Code. · ATFE lacks statutory authority to regulate, in any way, rocket motors under Title 18 of the United States Code. · ATFE has produced no scientific evidence that rocket propellant meets the statutory definition of explosives. · Rockets are "propellant actuated devices", and thus, on a statutory basis, are wholly exempt from ATFE's explosives regulations. · The proposed regulations should be defined as a "significant regulatory action" per Executive Order 12866. · The proposed weight limit for rocket motors and propellant is offered without legal or scientific basis as to its establishment. · The proposed limit violates title 18 USC 841, which requires publication of an annual list of explosive materials subject to ATFE regulation. · The entire set of proposed magazine changes are offer without supporting rationale as to why additional requirements should be imposed, either to protect public safety or to secure regulated materials subject to magazine storage. · Physical inventory requirements are excessive, and unsupported by field experience. · Removal of DOT citations is unsupported and unnecessary. · The definition of "toy propellant devices" is incomplete. · The proposed rule would impose undue economic harm on sport rocket hobbyists due to the excessive cost of padlock requirements. · The proposed definition of a manufacturer is unclear with respect to its applicability regarding rocket motors. · Changes to the definition of "highway" are unsupported and leave permit holders with no guidance regarding the definition of a highway. · Removal of the word "public" from the definition of highway is unreasonable and does not add to public safety. · Permit renewals requiring new determinations for approved variance represent an unnecessary administrative for ATFE , impose undue burdens on permit holders and is completely arbitrary in its application.. · Exemption language for selected materials has been arbitrarily changed in a manner that may require compliance with storage provisions. · The proposed regulations have failed to comply with federal requirements for rulemaking, since they fail to properly recognize the economic impacts as required under the Regulatory Flexibility Act. · The proposed regulations have failed to comply with federal requirements for rulemaking, since they grossly understate the estimated number of respondents and the time requirements for record keeping under the Paperwork Reduction Act.
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