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1. We oppose the current Administration bill (S. 1) for a number of reasons which include the following

(a) The bill prohibits legitimate trade in firearms while doing nothing" about the real problem: misuse and criminal use of firearms.

(b) The tone and philosophy of the bill infers that the average firearms purchaser is bent on a career of crime and violence, whereas the exact opposite is true. If the philosophy found in the first part of the "Findings and Declaration", regarding easy access to firearms being a significant factor in crime and violence, is adopted by Congress, the door will have been opened for application of this erroneous philosophy to the making of rules, regulations, and further legislation such that it will become difficult, if not impossible, for any citizen of good character to acquire firearms by any means for any reason whatever. Such a philosophy, as expressed in S. 1, stigmatizes the tens of millions of responsible citizens who engage in the shooting sports with the motives and deeds of a relative few.

(c) The provisions of S. 1 affect interstate commerce in firearms and as such these provisions belong in the Trade and Commerce Code-not the Criminal Code.

(d) The bill appears to provide for an encroachment of Federal control over State firearms laws.

(e) There are further objections but they will not be detailed as they will be adequately covered in other testimony and statements.

2. We favor and support passage of amendments to the Federal Firearms Act which will reduce the illegal acquisition of firearms in interstate commerce by juveniles and known serious offenders. One such bill, S. 1853 by Sen. Hruska, deserves the serious attention of the Committee. We do believe that the provisions for mail order purchase of a handgun should be extended to cover all firearms purchases.

We appreciate the opportunity to make our views known to the Committee and hope that these comments have been helpful. A copy of a resolution concerning firearms legislation, adopted by the club earlier this year, is attached. We respectifully request that it be included in the record with this statement.

The Committee has a difficult task before it. It is doubtful if any faction involved in the gun law controversy will be fully satisfied no matter what action is taken by Congress. Our hope is that Congress will act with prudence and consideration. Rash judgement in the field of firearms legislation may hurt the law-abiding gun buyer out of all proportion to its benefit in reducing crime and violence.

RESOLUTION ON FIREARMS LEGISLATION

Whereas persistent attempts are being made to equate crime rates with private acquisition and possession of firearms; and

Whereas this philosophy, if adopted by Congress, will open the door to laws which will disarm the law-abiding citizen, leaving him sure and easy prey to the violent, lawless and irresponsible element in our society; and

Whereas attempts to discourage criminal use of firearms by invoking measures which place severe and stringent regulations on the legal sale and possession of firearms are indirect, ineffective, and fail to disarm the lawless, but, instead, offer ever increasing harassment to those who abide by the law in acquiring firearms for legitimate purposes; and

Whereas the failure of such measures to eliminate criminal use of firearms results in ever more stringent attempts to control possession and sale of firearms with the law-abiding citizen being ultimately disarmed while the criminal element continues unrestrained and uncontrolled; and

Whereas violent crime rates in strict gun control jurisdictions are not consistently lower than in areas with little or no gun control laws; and

Whereas it is demonstrable that a citizenry possessing arms and skilled in their safe and proper use offers a marked deterrent to criminal attack; and Whereas lack of safe and convenient places for the public to engage in hunting and target shooting is an increasingly severe problem to all citizens and especially to city residents; and is used as another excuse to disarm the people; and

Whereas present defects in the Federal Firearms Laws are easily remedied and do not offer sufficient cause or justification for enactment of many currently proposed firearms control bills which would place harshly restrictive burdens on The people: Now, therefore, be it

Resolved by the Sierra Desert Gun Club, Inc., at a general Meeting, That al legislative proposals which prohibit or impose unnecessary restrictions upon interstate firearms transactions between responsible individuals or between such individuals and an importer, manufacturer, or dealer should be opposed and rejected; and be it further

Resolved, That the Federal Firearms Act be kept in Title 15, U.S. Code but that it be amended to remedy defects, long known to exist, as follows:

(1) Impose a minimum age requirement on federal firearms license holders: (2) Require a sworn affidavit to accompany each firearms order which goes to an individual or licensed importer, manufacturer, or dealer that assures the seller that the person ordering the firearm(s) is of proper age. is not falsifying his identity, and is legally entitled to receive the firearmısı (3) Provide that it is unlawful for any person or licensee to knowingly transport or ship a firearm into another state in violation of law of the state and locality to which it is being shipped; and be it further

Resolved, That criminal use of firearms be discouraged directly by enacting legislation at all levels of government that impose additional, consecutive prisoz terms for conviction of crimes committed with firearms; and be it further

Resolved, That the Congress encourage all citizens of good repute to have and to know the safe and proper use of firearms as a means of defending themselves and their neighbors against criminal attack, to know their responsibilities under the laws of man and God in thwarting criminal action, and to better underst:"d the role of law enforcement officers in maintaining law and order; and be at further

Resolved, That the Congress seek means to increase the number of safe pisey for recreational and competitive shooting as well as means to increase the 3pacity of existing facilities with special emphasis on providing such facilities and about the heavily populated metropoltan areas; and be it further Resolved, That copies of this resolution be sent to the appropriate legislators in Sacramento, California and in the Congress of the United States. Respectfully submitted.

GERALD C. INMAN, Secretary.

RESOLUTION OF THE UTAH WILDLIFE FEDERATION
FIREARMS LEGISLATION

Whereas, firearm legislation, detrimental to the sporting population, bas heer and will continue to be introduced in State and National lawmaking assemblies, such as Senate Bill No. 1 introduced by Senator Thomas J. Dodd of Connectiet and H.R. 5384 introduced in the House of Representatives by Congress Emanuel Celler of New York, and

Whereas, the majority of these proposals will not have the desired effect ef restraining persons with criminal intent: Now, therefore, be it

Resolved, That the Utah Wildlife Federation and its affiliated organization, at annual convention on April 2, 1967, resolve to assist the National Wild fe Federation and other organizations in defeating legislation which would hav an adverse effect on law abiding citizens who derive their recreation thr the use of or the collection of firearms, and be it further

Resolved, That the Utah Wildlife Federation and its affiliate organizaties support the type of bills introduced in the House of Representatives by Congres man Bob Casey of Texas (H.R. 360) and Congressman Robert L. F. Sikes of Florida (H.R. 2839), and if reintroduced, Senator Roman L. Hruska's bit amend the Firearms Act.

WABASH VALLEY GUN COLLECTORS ASSOCIATION, Isc..
Danville. Ill., June 12, 197

Re statement of Wabash Valley Gun Collectors' Association, Firearms Cen
Bill (S. 1 and Amendment No. 90 thereto).

Hon. THOMAS J. DODD,

Senator from Connecticut, United States Senate, Member, Committee on Jer ciary, Washington, D.C.

DEAR SENATOR DODD: I am writing you on behalf of and as Chairmat qử Đà Legislative Committee of the Wabash Valley Gun Collectors' Associat.on

Wabash Valley Gun Collectors' Association, Inc., is an Illinois Corporation, having a membership of approximately 1,000 persons, which is comprised of gun and arms collectors, hunters and sportsmen, and other individuals interested in guns, arms and related sports and hobbies. These members reside in various states; the majority residing in Eastern Illinois and Western Indiana.

On behalf of our organization, I would like to express to your Committee our unanimous opposition to the Senate Bill and Amendment No. 90 thereto (S. 1) and all other similar bills pertaining to gun restriction or regulation in any manner.

The reasons why our association opposes these bills are as follows:

First, our present National and Federal firearms acts completely cover lawful and unlawful use of firearms. Any further Federal control of firearms is totally unneeded and uncalled for. We recommend honest and strict enforcement of our present laws against all criminals instead of more new complicated gun legislation which would harass the legitimate gun collectors, hunters, target shooters, and sportsmen.

Second, to stop the imports of cannon, bazookas, antitank rifles, and machineguns, etc., etc., we have the Mutual Security Act of 1954, which gives the President of the United States authority to stop these imports at any time he sees fit. We suggest that the present laws are no being used or utilized by the Government. We recommend that he use this authority instead of asking for

more.

Third, we are of the opinion that present proposed gun legislation could, and in all probability, would lead to total gun registration restriction and control. It is a matter of historical fact that a disarmed people is a helpless nation and easy prey to an aggressor and criminal. We sincerely feel the possibility that the citizenry may possess arms and weapons is a deterrent to would-be aggressors and criminal trespassers. As Brigadier General Rafael Ileto, who leads the 3,000man Constabulary force fighting the Huk Communists in the Philippines says: "If you are the only man with a .38 in the barrio that barrio belongs to you."

Fourth, we believe the proposed bill, and others similar to it are founded upon the false premise that firearms themselves are the cause of crime and violence. The true fact is that the cause of crime and violence is the criminal person, not the instrument which he chooses to use to carry out his purposes. The criminal is not only more determined and capable of circumventing any gun registration or restriction laws, but is not bothered by the fact that he is not complying with them. The elimination of guns in the hands of the legitimate public merely makes the criminal possessed of a weapon, a more terrible, stronger and fearless lawbreaker.

Fifth, the proposed law seeks to prohibit the mailing, shipping or selling of firearms across State lines. This would seriously hamper gun collectors residing, as do many of the members of our organization, in close proximity to a State line from legitimately trading or selling to each other. It is inconceivable that prohibiting Mr. A in Illinois from selling or trading guns with Mr. B in Indiana, who resides 10 miles away; while permitting Mr. A in Illinois to sell or trade with Mr. C in Illinois, who resides 200 miles away, and is unknown to Mr. A, can have any effect in a reduction of a crime rate in America.

We sincerely hope and request that you and your Committee will not be influenced by the hysterical and panicky attempts brought about by the recent publicity given certain notorious crimes (the murder of President John F. Kennedy) to pass the numerous anti-gun bills. Such bills will have no effect on those who use guns for unlawful acts: Such persons will continue to commit unlawful acts if they have to use clubs to do so, and such bills will merely remove the deterrent of possible defense of habitation or person from the mind of the wouldbe criminal.

Yours very truly,

LELAND A. WHEELER,

Chairman of the Legislative Committee of Wabash Valley Gun Collectors' Association.

STATEMENTS AND LETTERS SUBMITTED FOR THE RECORD

Business Organizations

INTERNATIONAL ARMAMENT CORP.,
Alexandria, Va., August 4, 1967

Hon. THOMAS J. DODD,

Chairman, Senate Subcommittee on Juvenile Delinquency,
Senate Office Building, Washington, D.C.

DEAR MR. CHAIRMAN: I am forwarding herewith our comments on S. 1 i response to your invitation by letter dated June 2, 1967.

We would also appreciate the inclusion of this letter in the record in orde that we may set straight certain remarks about our business made during iexamination of the State Department witness on July 12th. These remarks were based on misinformation which left an impression detrimental to the excelent reputation maintained by our firm and which also implied ineffectiveness i State's Munitions Control licensing system.,

In response to the Chairman's inquiries about ambivalent arms transactions i.e., that this company had sold arms under State Department licenses to both sides of a revolution or civil disorder in a Latin American country, Mr. Job Sipes, testifying for the State Department, explained that he had no knowledge of any such transactions and in so doing pointed out that Mr. Cummings could bare supplied arms to foreign countries from sources outside of the jurisdiction of State Department licensing. The impression might be erroneously gained that International Armament Corporation and its overseas affiliates sell arms abrea: from overseas sources without regard to U.S. foreign policy and without the knowledge and approval of the State Department. It has been the firm policy and practice of Mr. Cummings and his companies to voluntarily submit all overes transactions to State Department scrutiny and to refrain from any sales which disapproves, whether or not a license from the State Department is needed. T... is done even in circumstances when it is perfectly obvious that the business w be transacted by foreign competitors despite the withholding of State Department approval. The recently released record of the testimony of Mr. Cummings before a Senate Foreign Relations Subcommittee contains abundant evidence on this point, and Mr. Sipes is understood to be prepared to verify on request that rbState Department has for some years relied upon such working arrangement with companies owned by Mr. Cummings. Because of the existence of a substantia gray area in the international trade in arms, it is important to our compa"? that the record be straight that we are not one of those so engaged. We tak considerable pride in the contribution of our company over the years to the f** therance of the U.S. national interest both in overseas arms trade and also le regularly cooperating with domestic law enforcement at all three leveis «! government.

We are taking the trouble to clarify the record with information otherwunavailable to the Subcommittee because we are sure that none of the menden intend that our company, as the largest importer of foreign firearms, be used? prejudice the complex issues of whether surplus firearms should be importate We believe that many members of the Subcommittee and its staff during deep investigation of firearms traffic have discovered that International An ment Corporation has been consistently constructive in its relations with government and sensitive to the problems of commerce of firearms.

Respectfully yours,

RICHARD S. WINTER, Vice Presiden*

STATEMENT OF RICHARD S. WINTER, VICE PRESIDENT, INTERNATIONAL ARMAMIT CORP., ALEXANDRIA, VA.

Mr. Chairman, members of the Committee, my name is Richard Winter ar I am a Vice President of International Armament Corporation. I appreciate " opportunity to comment on firearms legislation pending before you.

Our company is primarily engaged in the importation and exportation of fr arms and related commodities. We may well be the largest importer of firear

at the present time. Our products range from the full Walther line of premium rifles, shotguns and handguns made in West Germany to military surplus sporting firearms, including rifles, shotguns and handguns.

Firearms imported by our company are sold largely to wholesalers and retail dealers throughout the United States and to major nationwide merchandisers such as Sears and Montgomery Ward.

Several hundred small business manufacturers of firearms accessories and over 6,000 dealers and gunsmiths are to varying degrees dependent on the products imported by our company. We have not circulated information about this bill to our customer mailing lists, which include about 7,000 businesses and over 60,000 individuals, but we have considerable correspondence on the subject which enables me to say that there is today widespread and watchful interest by the small business part of the gun industry in any move to discriminate against them in efforts to devise a sound firearms control bill.

My sole purpose here is to ask the Committee to avoid discrimination in the treatment of virtually identical firearms under Amendment 90 of S. 1, on grounds which are irrelevant to the crime problem. In the last several years of hearings in both Houses on this subject, we have yet to hear hard evidence or logic which justifies taking firearms out of commerce, by means of import embargoes or otherwise, solely on the grounds that they are foreign or that they were made to military specifications and sold as surplus. On the contrary, the evidence of past hearings is clear that imported small arms, military or commercial, are inherently identical to sporting firearms manufactured in the United States, and available at any store under generally applicable regulations. The foreign origin of a firearm, or the fact that it was made to meet stringent military specifications, has nothing to do with a gun's susceptibility to criminal use.

Your Committee will decide whether or not an embargo on certain firearms imports is needed in addition to whatever restrictions the Committee adopts on domestic commerce in firearms. Presumably, your decision will be to place limits on interstate commerce in firearms which are justifiable and reasonable, after balancing the public interest in reducing the accessibility of firearms and the public interest in preserving the rights of individuals to buy what they want and in preserving the jurisdiction of State and local governments to exercise their traditional police powers. We believe that a case has been established for additional federal legislation to curb certain types of mail order sales. However, I would like to confine these comments to the single issue of whether your Committee should propose that certain types of firearms should be cut off at the source, as distinct from being regulated at the wholesale and retail levels of distribution. It is important to recognize the difference between regulated commerce and taking certain identical type commodities out of commerce simply because of a different geographical source. Unless the Committee is prepared to adopt a long-term effort to gradually chip away at the accessibility of firearms to the public until the American citizen is disarmed-and I do not think that this is the Committee's purpose the jusification for removing any particular class of firearms from commerce must be that such arms are inherently susceptible to criminal use and not widely used for recreation. Only destructive devices and gangster weapons (submachine guns, sawed-off shotguns) meet this standard and earn the distinction of being outlawed rather than regulated.

Our company fully subscribes to the view that military ordnance the socalled "destructive devices"-and the various machine guns, sawed-off shotguns and other weapons now covered by the $200 transfer tax in the National Firearms Act, should not be sold to the general public. Existing law does not go far enough to accomplish this purpose. Section 922 (b)(4) of Amendment 90 of S. 1 and S. 1854, each would accomplish this purpose successfully. We are all agreed that this can and should be done.

Section 922(j) of Amendment 90 of S. 1 flatly embargoes all imports without distinction. However, let us look at Section 9125(d) (3), which makes the exceptions. It says that the Secretary of the Treasury “may”—and I emphasize the “may”—let in certain defined categories of firearms. The burden is on those regulated to "establish to the satisfaction" of the Secretary that a firearm is "particularly suitable for . . . sporting purposes". To say the least, the future of any imports is uncertain.

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