Hopefully by now, most everyone here is aware of the proposed changes to ITAR that will essentially make the continued operation and growth of technically-oriented firearms and ammunition sites (building, modification, development, service, reloading, and ballistics performance are the areas that would be most affected) unfeasible. Since State Department preapproval will be necessary to divulge this information to public servers where foreign persons can access it easily (here and abroad), the only solution for forums is to forbid discussion of those topics.
Link to the docket where you can click the big "Comment Now" button
Please don't toss up a one-sentence objection; the purpose of these comment periods is to convince the feds that there are many legal vulnerabilities to this action that make it not worth their time, and most importantly, require them to address a multitude of varied concerns (as ordered by law) before implementation, buying us crucial time to muster a legislative opposition to stymie this hot mess. The ATF is still sifting through all those M855 comments, whether they like it or not. The State Dept only has 7200 comments to sort through on ITAR; it won't hold them long.
Areas of concern to be sure to mention;
-Clear placement of unconstitutional prior restraint on lawful communcations (1st Amendment)
-Disastrous effect on communications critical to the proper function of the right to keep and bear arms (2nd Amendment)
-Expense of implementation (the scope of the proposal is massive)
-Expense of compliance (a large new class of private citizens would have to pay thousands in ITAR registration to pursue their hobby)
-Difficulty of compliance (there is no practical way for a public internet forum to host information that would be considered 'defense articles' under the proposal as they freely do currently)
-Growth of oversight (whole new bureaus would be required to oversee this)
-Entirely new registration scope (i.e. private citizens, whereas to my knowledge practically no one is ITAR registered outside direct job functions in government, industry, or academia)
-New compliance costs by business, small and large, associate with firearms accessories (since manufacturer FFLs usually pay ITAR already) will drive up consumer prices for these items tremendously
-Significant/adverse impact on private innovation in the fields of firearms, accessories, and ammunition; cutting-edge tech will be disfavored since dealing or developing it will require licensure
-Proposed changes are intentionally vague and expansive; types of 'technical information' are not described in any level of detail beyond the most basic terms, and as written pertain to nearly all practical firearms knowledge
-Massive troves of available and soon-to-be present data will fall under regulation, the multitudes of citizens involved, and the number of sites online all mean that diligent enforcement would generate an incredible burden for the legal system, with scant standards at present for the scope of prosecution
The State Dept has to address each and every last topic you raise a grievance with. That's a few man-minutes or so per topic per complaint (maybe more, seeing as it's government workers
). Do what you can to make your comment count the most.
Some background info:
Letter from Senators Ron Johnson and Chuck Grassley to State Dept/John Kerry about the proposed change's implications. No response has been made thus far, as the comment period draws to a close, despite very serious constitutional concerns.
Link to a press conference, where the extent of the proposal is stated to apply directly to private gun owners posting technical information about their weapons online. The censorship, licensing, and approval processes will not only apply to government employees and military contractors.
Link to the docket where you can click the big "Comment Now" button
Please don't toss up a one-sentence objection; the purpose of these comment periods is to convince the feds that there are many legal vulnerabilities to this action that make it not worth their time, and most importantly, require them to address a multitude of varied concerns (as ordered by law) before implementation, buying us crucial time to muster a legislative opposition to stymie this hot mess. The ATF is still sifting through all those M855 comments, whether they like it or not. The State Dept only has 7200 comments to sort through on ITAR; it won't hold them long.
Areas of concern to be sure to mention;
-Clear placement of unconstitutional prior restraint on lawful communcations (1st Amendment)
-Disastrous effect on communications critical to the proper function of the right to keep and bear arms (2nd Amendment)
-Expense of implementation (the scope of the proposal is massive)
-Expense of compliance (a large new class of private citizens would have to pay thousands in ITAR registration to pursue their hobby)
-Difficulty of compliance (there is no practical way for a public internet forum to host information that would be considered 'defense articles' under the proposal as they freely do currently)
-Growth of oversight (whole new bureaus would be required to oversee this)
-Entirely new registration scope (i.e. private citizens, whereas to my knowledge practically no one is ITAR registered outside direct job functions in government, industry, or academia)
-New compliance costs by business, small and large, associate with firearms accessories (since manufacturer FFLs usually pay ITAR already) will drive up consumer prices for these items tremendously
-Significant/adverse impact on private innovation in the fields of firearms, accessories, and ammunition; cutting-edge tech will be disfavored since dealing or developing it will require licensure
-Proposed changes are intentionally vague and expansive; types of 'technical information' are not described in any level of detail beyond the most basic terms, and as written pertain to nearly all practical firearms knowledge
-Massive troves of available and soon-to-be present data will fall under regulation, the multitudes of citizens involved, and the number of sites online all mean that diligent enforcement would generate an incredible burden for the legal system, with scant standards at present for the scope of prosecution
The State Dept has to address each and every last topic you raise a grievance with. That's a few man-minutes or so per topic per complaint (maybe more, seeing as it's government workers
). Do what you can to make your comment count the most.Some background info:
Letter from Senators Ron Johnson and Chuck Grassley to State Dept/John Kerry about the proposed change's implications. No response has been made thus far, as the comment period draws to a close, despite very serious constitutional concerns.
Link to a press conference, where the extent of the proposal is stated to apply directly to private gun owners posting technical information about their weapons online. The censorship, licensing, and approval processes will not only apply to government employees and military contractors.