Cawdor,
Interesting discussion. My letter is signed by Edward M. Owen, Chief of the Firearms Technology Branch. These are the people that are supposed to settle disputes. I'm not surprised to see different interpretations from different field offices. Now we have differences between branches at BATF. Without seeing the law as written in the US Code or the preamble to the regulation, I would guess that the intent was to require notification, but that the regulation was poorly written (Those damned punctuation marks!). I work a lot with Dept of Transportation regulations and have files of hundreds of letters of interpretation and clarification and have never seen conflicting opinions from DOT HQ. I think the reason is that all requests are sent to one office and not handled by whichever branch gets the initial inquiry.
[This message has been edited by EOD Guy (edited September 16, 2000).]
Interesting discussion. My letter is signed by Edward M. Owen, Chief of the Firearms Technology Branch. These are the people that are supposed to settle disputes. I'm not surprised to see different interpretations from different field offices. Now we have differences between branches at BATF. Without seeing the law as written in the US Code or the preamble to the regulation, I would guess that the intent was to require notification, but that the regulation was poorly written (Those damned punctuation marks!). I work a lot with Dept of Transportation regulations and have files of hundreds of letters of interpretation and clarification and have never seen conflicting opinions from DOT HQ. I think the reason is that all requests are sent to one office and not handled by whichever branch gets the initial inquiry.
[This message has been edited by EOD Guy (edited September 16, 2000).]