A question from the Harvard Law School Target Shooting Club (which was founded by my brother Sasha several years ago) - any suggestions for them? Thanks,
Eugene From: Michelle Yang [mailto:[email protected]] Sent: Monday, July 13, 2009 2:51 PM To: Volokh, Eugene Subject: Fw: Re: New rule in MA and the HLS Target Shooting Club Dear Professor Volokh, I had gotten in touch with your brother Sasha, who is a founder/alumni of the HLS Target Shooting Club, about a proposed rule in Massachusetts that would restrict our club's access to firearm ranges in Massachusetts. The new rule's broad definition of "firearm exhibitions" would likely force us to request a police detail for our trips to the local skeet/trap range--a prohibitive cost. As president of the Target Shooting Club, I am filing a comment opposing the rule and attending the public hearing on Monday, July 20. Sasha has suggested that we describe our club's situation and the impact of the rule. Would you happen to know any other arguments that would be useful against this restrictive policy? I appreciate any remedy to my woeful ignorance of state administrative law. Thank you! Best, Michelle <-----Original Message-----> From: Alexander \ [[email protected]] Sent: 7/13/2009 4:03:09 PM To: Michelle Yang Subject: Re: New rule in MA and the HLS Target Shooting Club Hi Michelle. Sorry it's taken me a few days. I hope this doesn't prevent the club from going to New Hampshire, though, right? (That's what we used to do almost all the time.) I don't really know what the club's best option would be for opposing the rule, but I'd think that GOAL has a handle on when the relevant hearings are and suchlike. I'm not sure what to write in the comments that would be persuasive, other than just to describe the club's activities, the hardship that would impose, and that we haven't had any accidents (assuming that's true); perhaps my brother, Eugene Volokh (at UCLA), who is more up on firearms policy than I am, might have some ideas. - Sasha On Fri, Jul 10, 2009 at 9:38 AM, Michelle Yang <[email protected]<mailto:[email protected]>> wrote: Hi, Sasha, I've had the pleasure of exchanging e-mails with you before as president of the HLS Target Shooting Club. Unfortunately, MA is proposing a new regulation that would essentially shut down our activities in Massachusetts. I want to file a comment on the proposal and may go up from DC to Boston to attend the hearing. What would be the best way for the Target Shooting Club to oppose this proposed rule? What should I write in the comment that would be most persuasive, legally or otherwise? I would really appreciate your advice in this urgent matter. Thank you! Best, Michelle ________________________________ Date: Fri, 3 Jul 2009 09:26:40 -0400 From: [email protected]<mailto:[email protected]> To: [email protected]<mailto:[email protected]> Subject: Another Proposal from Governor Patrick Error! Filename not specified. July 3, 2009 New Proposed Regulations to Close Public Access to Firearms Training and Education in Massachusetts GOAL has just been made aware of yet another attack on our Second Amendment rights by the Patrick Administration. Below is a copy of proposed regulations that the Administration seeks to put in place to cut off any access the general public might have to firearms education and training. These new proposed regulations would affect any events that clubs might have that involve nonmembers possibly including junior shooting programs, Women on Target, Becoming an Outdoors Woman, First Step, state required firearm training courses, the Massachusetts Outdoor Expo, trap and range days where a club might charge a nonmember fee, etc. The regulations would also end any events open to the public in regards to machine guns. As GOAL has just learned about this attack prior to the July 4th holiday weekend, we will be providing more in depth information throughout the upcoming week. Please check GOALnews.org next week for more details. The regulations are scheduled to have a public hearing on Monday, July 20, 2009 at 10:00 am at the Massachusetts State Police Headquarters, 470 Worcester Road, Framingham, MA 01702. To submit written comments in advance of the hearing, please send them attn: Catherine Bailey, Assistant General Counsel, Executive Office of Public Safety and Security, One Ashburton Place, Room 2133, Boston, MA 02108. An official copy of the proposed regulations may be obtained from the same address. The following is a hand typed copy of the regulations since no copy is available electronically, as such there may be typographical errors. 501 CMR 15.00 FIREARMS EXHIBITIONS Section 15.01 Purpose and Scope The purpose of 501 CMR 15.00 is to establish rules and regulations governing firearms exhibitions open to the general public. 501 CMR 15.00 is promulgated pursuant to M.G.L. c 140 § 122B and M.G.L. c 140 § 131(r). 15.02 Definitions Certified Firearms Safety Instructor means a basic firearms safety instructor certified by the Colonel of the State Police or a firearms instructor certified by the Municipal Police Training Committee. Firearms Exhibition means any event held at a sporting or shooting club or facility open to the general public or to non-members where firearms, rifles, shotguns or ammunition, all as defined in M.G.L. c.140 § 121, are provided to attendees for the regulated shooting on the premises of the said sporting or shooting club or facility. Regulated Shooting means any skeet, target or trap shooting. 15.03: Firearm Exhibition Requirements (1) Any sporting or shooting club or facility that hosts a firearms exhibition shall: a) Possess a valid license to sell or supply ammunition pursuant to M.G.L. 140 § 122B; b) Possess a Class A club license issued pursuant to M.G.L. 140 § 131(a); c) Provide for an adequate police detail as determined by the police department of the city or town in which the event is to occur; d) Ensure that one certified firearms safety instructor is present at the exhibition for every 20 members of the general public present at the exhibition; provided however, if persons under the age of 18 years old are to be admitted to a firearms exhibition, there shall be one firearms safety instructor present for every five individuals present at the exhibition. The certified firearms safety instructor(s) present at the exhibition shall be directly responsible for the instruction, supervision and safety of members of the general public participating in the regulated shooting during the firearms exhibition. e) Submit a basic safety plan to the municipal police department located in the town in which the firearms exhibition is to take place and to the Firearms Records Bureau of the Criminal History Systems Board not less than 30 days prior to the date of said exhibition. The basic safety plan shall include, at a minimum, the following: 1. A list of the types of weapons and ammunition that will be used to regulated shooting; 2. The number of people expected to attend the exhibition; 3. The names of the certified instructors that will be present at the exhibition and the ratio of instructors to general public; 4.. Whether persons under the age of 18 will be admitted; 5. The size of the police detail requested; and 6. A detailed description of any additional safety measures the sporting or shooting club or facility intends to implement during the firearms exhibition. (2) Machine Guns. The use of machine guns, as defined in M.G.L. c.140 § 121, is prohibited at any firearms exhibition. Forward email<http://ui.constantcontact.com/sa/fwtf.jsp?m=1101878640504&[email protected]&a=1102629922799> Error! Filename not specified.<http://visitor.constantcontact.com/d.jsp?v=00102zBK1ZSE4Z0nL_fwmc8zmbF8cThGqLkdhM4VH5UjRgiPhLmrkQYt-d1mFmnOBrjylVD05n04uJZp4GmiaUfJg%3D%3D&p=un> This email was sent to [email protected]<mailto:[email protected]> by [email protected]<mailto:[email protected]>. 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