Gunleaders Blog

Archive for September, 2011

Proof that public comments work

by on Sep.28, 2011, under Uncategorized

If you have ever wondered if public comments make a difference, they do.  If you don’t believe commenting on rule making, information collections & various other administrative actions by the government is worth it…  You’re wrong

1 public comment STOPS Coast Guard rule dead in its tracks.

Just one public comment stopped this rule.

Now – please:  Help some brothers & sisters out in Arizona.


Update:  Here is the newly proposed rule, conforming to the public comments.

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AZ BLM attempt to ban guns

by on Sep.28, 2011, under Uncategorized

BLM is soliciting public comments on management plans for the Sonoran Desert National Monument.  2 of the plans under consideration eliminate the ability to shoot on these lands.

Hat tip to AzCDL, among others who have posted about this.

Here is the AzCDL Alert message:

President 0bama promised that he was going to implement efforts to erase your right to bear arms “under the radar.” Now, he’s brought the fight to Arizona.

Using the Bureau of Land Management (BLM), the 0bama administration has proposed banning recreational shooting in the half-million acres of Sonoran Desert National Monument.

BLM has released proposed plans for the future management of nearly 1.4 million acres located southwest of Phoenix, in parts of Maricopa, Pinal, Pima, Gila and Yuma Counties. Of that total, over 486,000 acres are within the Sonoran Desert National Monument. The proposals can be found at: .

Two of the possible alternatives (“D” and “E”) propose closing the area to recreational shooters. Presently, some 63 sites in the national monument are used by recreational shooters. The proposed plans also address other issues of importance to shooters and hunters, including the designation of roads and trails for motorized vehicles and areas that could be managed as wilderness.

If you ride, hike, hunt or shoot in the Sonoran Desert National Monument, you need to get involved in this planning process!

The public comment period is open through November 25.
Instructions for making comments can be found at: .
Comments can be faxed or mailed to BLM, Phoenix District Office.

At the BLM website ( you will also find a series of public BLM meetings, being held in October, to discuss the proposal to ban recreational shooting in the Sonoran Desert National Monument. Meetings will be held in Phoenix, Mesa, Casa Grande, Buckeye, Gila Bend and Ajo. We urge you to attend as many of these meetings as possible.

This is not the first time that the BLM has attempted to close an entire national monument to shooters, making no attempt to provide places for and access to shooting sites. The Ironwood National Monument shooting ban was defeated because of the outcry from concerned citizens (you!).

Together, we can defeat the 0bama administration’s proposed Sonoran Desert National Monument shooting ban!

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DOJ requesting more comments on proposed FOIA rule changes

by on Sep.21, 2011, under Uncategorized

The Department of Justice proposed FOIA rule changes back in March of 2011 and the comment period has been re-opened and extended through October 19, 2011.  There are substantial changes proposed for the FOIA application & rules at DOJ. This has implications for the blogosphere, NFA community & various other RKBA supporters.

The original entry in the Federal Register  is here: (very long)

The DOJ is soliciting public comments and you should comment.  The inventory page for this rule is at:   You can review the other comments submitted, as well as submit your own comments.  There are several changes being attempted, some of which seem benign.  Others are not.

In particular Fee changes are detailed in section 16.10 in the notice.  The duplication charge for photocopying will decrease to five cents a page, while document search and review charges will increase to $16.50 and $13.00 per quarter hour for professional and administrative time, respectively. The amount at or below which the Department will not charge a fee will increase from $14.00 to $25.00.  As the comments submitted by OMB Watch point out, “These [fee increase] changes would replace charges per quarter hour of $4.00 for clerical personnel, $7.00 for professional personnel, and $10.25 for managerial personnel with a new fee structure of $13.00 for administrative personnel and $16.50 for professional personnel.

These changes could increase fees by as much as $36 per hour, an increase of 225 percent.

There have been some informative comments already by advocacy groups but also by the NARA Office of Government Information Services.  They made some significant recommendations on several proposed changes.  The impact of the fees above – A government secretary or intern will cost almost 1 US Dollar per minute to process FOIA requests!  under the proposed rule change.

Just to put things in perspective a September, 2011 OIG report shows the DOJ spent lavishly on “conferences” from 2007 – 2009, spending 4.4 MILLION dollars on just 10 conferences. Anyone in the computer / IT field knows that these conferences vary in their effectiveness and they are largely “meet and greet” working vacations on the taxpayer’s dime.

USRKBA believes that rather than fee increases, fee decreases are in order.

Please take the time to submit a comment  on the proposed DOJ FOIA rules.

*  FOIA fee increases should be stricken.  Given the DOJ poor stewardship of taxpayer money & outright wasteful spending, as pointed out in the OIG report DOJ clearly has a surplus of money.  Accordingly, Fees for document search and review for professional and administrative time should be reduced to $3.50 & $4.60 per quarter hour respectively.

The NARA OGIS submitted comments contain many good points.  Feel free to copy as many as you agree with and add to your own comments.


Some examples:

(c) Description of records sought.

OGIS recommends that DOJ address the new requirements in 5 U.S.C. 552 § (a)(6)(A)(ii)(I) that agencies may make one request to requesters for information pertaining generally to the request and toll the 20-day period while it awaits a reply. (See “OIP Guidance: New Limitations on Tolling the FOIA’s Response Time,” FOIA Post, November 18, 2008

e) Markings on released documents.

OGIS recommends that DOJ specifically address the new requirements in 5 U.S.C. 552 § (b) that agencies shall (1) indicate, if technically feasible, the amount of information deleted and the exemption under which the deletion is made at the place in the record where the deletion is made, and (2) indicate the exemption under which a deletion is made on the released portion of the record, unless including that indication would harm an interest protected by the exemption.

(k) Requirements for waiver or reduction of fees.

OGIS suggests DOJ consider adding a broader provision that allows for waiving fees generally “as a matter of administrative discretion.”  For example, the CIA’s FOIA regulations allow administrative discretion to release records without charge or at a reduced rate whenever the Agency determines “[t]hat, as a matter of administrative discretion, the interest of the United States Government would be served.” ( OGIS has seen fee disputes that have consumed agency resources that in the end were not worth fighting, serving only to waste agency resources and delay release of requested documents. OGIS suggests this in the interest of better serving FOIA and making government more efficient.


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