Does paragraph (1) mean that I cannot sell one of my rifles or shotguns to a sportsman or relative in another State and ship it to him by mail?

In section 2, paragraph (5) (b), what does "or otherwise dispose of" mean? Could a licensed dealer rent or lend a shotgun or rifle to an individual under 18 years of age? Could he rent a pistol to someone younger than 21? Sporting firearms have been rented and loaned to reliable persons all along.

It has been said by the committee that there is no intention under section 3 of requiring a rifle club that is reloading ammunition for sale to its members to have a license. We fail to find any such exemption, and what S. 1592 would or would not do is a matter of personal interpretation.

These are merely a few of the questions that have arisen about S. 1592, Mr. Chairman, and they are offered to give some explanation of why sportsmen are concerned about this proposal.

A final comment, Mr. Chairman. I do not believe that any sportsman or any organization, including the National Rifle Association, ever intentionally misrepresented S. 1592. The bill is vague and confusing in many respects. Even its author, the chairman of this subcommittee, made an unintentional error in his opening statement at the beginning of this hearing. While all such innocent mistakes are regretted, it likewise was unfortunate that Director Woodward of Colorado was queried by the chairman before the TV cameras in this hearing on May 21 on what position he had taken on S. 14 last year, when S. 14 was not introduced until this year.

Senator DODD. We have Mr. Charles Dickey, director of the National Shooting Sports Foundation, of Riverside, Conn., and with him Mr. Howard Carter.

Mr. CARTER. Senator, I am Carter, and I appeared before you a couple of years ago.

Senator DODD. Yes; I remember now.

Mr. CARTER. I would like very much if Mr. Dickey could be with me during this statement.

Senator DODD. I remember you, Mr. Carter, I remember your testimony.

Mr. CARTER. Shall I proceed?

Senator DODD. Yes.

STATEMENT OF HOWARD CARTER, JR., ATTORNEY AND DIRECTOR OF THE NATIONAL SHOOTING SPORTS FOUNDATION, INC., RIVERSIDE, CONN.; ACCOMPANIED BY CHARLES DICKEY, DIRECTOR, NATIONAL SHOOTING SPORTS FOUNDATION, INC.

Mr. CARTER. Mr. Chairman, my name is Howard Carter, Jr. I am an attorney and a director of the National Shooting Sports Foundation, Inc., of Riverside, Conn. I would like to thank this subcommittee for the opportunity to present the following statement.

The National Shooting Sports Foundation, Inc., is an organization with 87 member companies that manufacture hunting and shooting equipment.

That does not mean just guns and ammunition, but clothing, sports gear of all kinds.

Some of its members are publishers of sporting publications. A list of the membership is attached to this statement. Eight of the nine member companies of the Sporting Arms and Ammunition Manufacturers' Institute are members of the foundation; they have prepared a statement of their own for presentation June 3.

Also, other members of our organization either have or will present separate statements.

The foundation was organized in 1961 to act as a public information organization for the shooting sports industry. The members are vitally concerned with the many phases of hunting and shooting in America. With a staff of nine persons, the foundation carries on such various activities as

1. Compiling and distributing a national directory of shooting preserves.

2. Supplying State and Federal agencies as well as the Boy Scouts, 4-H Clubs, police athletic leagues, schools, and other groups with materials, pamphlets, and booklets on hunting and shooting safety. For example, over 65 million copies of the "Ten Commandments of Shooting Safety" have been distributed. This is a very important and widely accepted pamphlet on the care that should be taken. It has been in print for over 25 years.

3. Making contributions to such nonprofit organizations as Indiana University, National Education Association's outdoor educational project at Michigan State University, the Outdoor Writers Association of America, and the Athletic Institute in Chicago, Ill.

4. Working in cooperation with such conservation groups as the National Wildlife Federation, Ducks Unlimited, and the Izaak Walton League.

5. Working with State and private agencies to establish and maintain game preserves and conservation areas.

6. Expanding news coverage of hunting and shooting sports.

7. Educating sportsmen concerning legislation which would affect their recreation.

8. Working with all communications media to supply information on the hunting and shooting sports.

The shooting sports industry has worked for and still supports the Federal excise tax on the sale of firearms and ammunition under the Federal Aid in Wildlife Act, popularly known as the Pittman-Robertson Act of 1937, which has been the mainstay of the wildlife research and conservation programs of this country. In addition to the more than $255 million that has been collected under this program to date, the sportsmen of America have purchased over $80 million in "duck stamps" since 1934. The proceeds of the sale of these stamps are distributed proportionately among the various State fish and game agencies. Gun clubs and individuals spend annually an estimated $50 million in developing additional private lands for wildlife.

It must be remembered that many public lands, set aside for use by sportsmen for 2 or 3 months each year, are enjoyed by the general public for nature studies, bird watching, camping, and similar uses during most of the year. For instance, a Massachusetts Department of Fisheries and Game report states that public areas are used for 29 different recreational activities.

Hunters and shooters spend annually $1.5 billion not only for hunting licenses, but also for food, lodging, and accessories. Several of the Northeastern States as well as many areas in the North, South, and West rely on this source of revenue. For example, the Commonwealth of Pennsylvania reports that an estimated $16 million will be spent annually in connection with hunting and shooting activities.

Because of the concerted effort of our industry, sportsmen, State and private agencies, much has been done to perpetuate wildlife research and to preserve the natural beauty of this country.

These groups are seriously concerned that sweeping new antifirearms legislation could eventually curtail these programs. This is not to say that these groups are against all firearms legislation.

We are for legislation on the Federal, State, county, and local level that would attack the causes of crime. Narcotics laws, criminal use of firearms bills, and laws affecting firearms in the hands of habitual drunkards, mental incompetents and convicted felons, are all supported by the sportsmen and the industry.

Attorney General Katzenbach, on May 19, 1965, before this subcommittee, stated that S. 1592 "is not intended to curtail the ownership of guns among those legally entitled to own them" or "to deprive people of guns used either for sport or for self-protection."

We believe that S. 1592, as it now stands would, instead, place undue restrictions on millions of responsible citizens. This would be a heavy price for these citizens to pay to reach the undesirable elements of our society.

Though the specific import of the bill is to reduce crime, we feel that its overall effect would unduly penalize sportsmen, antique gun dealers and collectors, reloaders, and target shooters. We have the following comments to make on the bill in its present form:

Senator, I realize a lot of what we are to say about the bill is repetitious, but I will go through it.

Senator DODD. That is all right. Don't feel under any restriction. I have read it. I think you should say it all.

Mr. CARTER. All right. I will go through it, then.

1. As section 1, subsection 4 is now constituted, the term "destructive devices" will cover any firearm, the bore of which is a half inch or more in diameter. This definition could mean that every dealer in antique muskets, flintlock pistols, and certain big game rifles would be burdened with a $1,000 license fee. This subsection could also seriously affect the trading carried on by some 750,000 collectors, many of whom are hunting and shooting enthusiasts.

We understand that the regulations would permit the Secretary to exclude any device which he finds is not likely to be used as a weapon. However, this puts the whole status of antique guns in great doubt until any regulations are issued, and even when such regulations are issued, they may well discourage anyone from continuing this hobby. Needless to say, we approve of the term "destructive devices" when it is used to define such weapons as bazookas, antitank guns, grenades, and the like. These items obviously are for military use as well as the ammunition for such ordnance.

2. Section 1, subsection 8 defines the term "manufacturer" to mean "any person engaged in the manufacture of firearms or ammunition for purposes of sale or distribution; ***" Though it has been stated that the bill does not refer to reloading, we think that the term "manufacture for sale or distribution" is so broad that it could well be taken to cover reloading. Many persons who reload ammunition sell or distribute such ammunition to their friends. In addition, one or two members of a gun club will do the reloading, often at cost, for the members. Under this definition any person carrying on such reload

ing could be classified as a "manufacturer" and would be subject to the license fee of $500 a year. Such a broad restriction could curtail much of the reloading being conducted by an estimated 2 million persons in this country.

We are aware that the term "ammunition" in section 1, subsections 8, 9, and 15 does not affect those who reload shotgun shells, but it is fair to say that a substantial number of the reloaders in this country also reload rifle and pistol ammunitions. In light of this, we recommend the deletion of pistol or revolver ammunition and rifle ammunition from section 1, subsection 15.

3. In section 2, subsection (a) (1), we feel that the phrase "lawful purpose" although very commendable, is vague and should be more specifically defined.

In this same subsection, we believe the conditions regulating shipment of personal shotguns and rifles should be set forth in the bill itself and not left to the discretion of the Secretary.

4. Again, in section 2, subsection (a)(2), regulations delegated to the Secretary likewise should be spelled out. As now written, this section of the law would bar any transient person on a legitimate trip from purchasing a pistol, for instance, for self-protection. It would also bar transfer of pistol ownership by those attending legitimate pistol competitions, which is often done, I understand.

5. In section 2, subsection (a) (3), the shipment of a firearm for "authorized service" raises a question as to the meaning of the word "authorized." Such word should be clarified. Words like "repair," "maintenance," or "replacement" are suggested. In addition, such shipment would be subject to regulations to be prescribed by the Secretary. Here again the conditions for shipment should be outlined in the text of the bills and not relegated to regulation.

6. As section 2, subsections (b) and (c) are now written, it is submitted that they are too indefinite in the criteria of the investigation and proof required of manufacturers, importers, and particularly, dealers, and leave too much discretion in the hands of the Secretary of the Treasury, as so often occurs in this bill, which creates uncertainty and could result in undue hardship. It is urged that these subsections of the bill be made more specific.

We have no objection to subsections (d), (e), (f), (g), (h) (i), (j), (k), and (1) of section 2.

We believe that the license fees in section 3 are needlessly excessive. While such license fees might well be borne by the large manufacturer, the effect of the size of these fees could well put out of business or seriously discourage any small operator, dealer, manufacturer, or importer. We feel that these fees are not designed to cover registration costs but are confiscatory. Our special concern is with the $100 fee which a small dealer in firearms, ammunition, or both and the $500 fee which would be charged a reloader or other individual constructing his own sporting ammunition for distribution.

In regard to section 3, subsection (c) (2), we believe that the prohibition against an applicant "by reason of his business experience, financial standing, or trade connections, (is) not likely to maintain operations in compliance with this Act," can conceivably lead to arbitrary decisions. With this exception, we have no objection to subsection (c) as written.

Section 3, subsection (e) of S. 1592, as now worded, is of concern to us since we feel it could impose undue hardship on a number of very legitimate importers. We doubt that it is the intent of the bill, or those supporting it, to ban properly designed and well-made, defense-type pistols. The bill, in its present form, would bar firearms of this type from importation even though they are of a type and quality comparable to domestically manufactured models.

The phrase in paragraph (3) of subsection (e) "and would not be contrary to the public interest" is too vague and should be more specifically stated as to meaning. Major importers must financially obligate themselves for production as far as 111⁄2 years in advance of delivery. Room for arbitrary decision could impose serious financial burdens.

Importers under present regulations receive import authorization through licenses granted by the Office of Munitions Control, Department of State. Does the wording of this section now mean that authorization must come from two administrative departments? Dual authority, it would seem, could cause confusion, conflict, and, at the very least, considerable inconvenience to the importer.

As this subcommittee has undoubtedly heard, one basic objection to any antifirearms legislation has been the fear of gun registration. Senator DODD. May I interrupt at this point? I have to excuse myself to go over on the floor. I have a matter I have to speak on there. After you conclude your statement, Senator Burdick and I agree we will then take a recess for 15 or 20 minutes. We are going to have a rollcall vote.

Mr. CARTER. I can stop right now if you want to leave, Senator. Senator DODD. No, that is not necessary. I want to explain why I am going out. I mean no offense to you at all. Senator Burdick will remain until you finish your statement. Then we will recess, and come back.

Mr. CARTER. All right.

As this subcommittee has undoubtedly heard, one basic objection to any antifirearms legislation has been the fear of gun registration. Though S. 1592 does not specifically call for such registration, the recordkeeping provisions and record availability to State and local agencies, as stated in section (3), subsection (g), some feel, are first steps toward such registration. There is considerable concern on the part of all interested groups that this bill could eventually lead, either through administrative directive or through subsequent legislation, to the registration of all firearms, especially rifles and shotguns, in this country.

We realize that the supporters of S. 1592 are seriously concerned, as we are, with the crime rate in the country today. Time and again legislators on State and local levels in a conscientious effort to curb crime, propose antifirearms legislation.

In contrast, we know that many knowledgeable experts in the crime field believe that the answer to our crime problems lies not in stopgap methods, but in a full scale attack on the basic causes of crime.

As stated earlier, the industry and sportsmen for decades have taken this tack toward the crime problem. We have also vigorously supported efforts to penalize the criminal use of firearms.