Grass Roots North Carolina / Forum For Firearms Education
Post Office Box 10665, Raleigh, NC 27605
877.282.0939 (Phone) 919.573.0354 (Fax) www.GRNC.org
FOR IMMEDIATE RELEASE
Press Contact: 704.907.9206
E-mail: president@GRNC.org
Release date: June 22, 2023
July 11, 2023
Attorney General Josh Stein
114 West Edenton Street
Raleigh, NC 27603
Dear Attorney General Stein:
I have directed Grass Roots North Carolina (GRNC) since its inception in 1994, during which time GRNC has become our state’s primary Second Amendment organization.
In 1995, I was deeply involved in drafting and passing our original concealed handgun permit (CHP) law. Since then, GRNC has been central to passing concealed handgun reciprocity; legislation enabling CHP-holders to bypass purchase permits; Castle Doctrine/Stand Your Ground; and the expansion of concealed carry into restaurants, public assemblies, state and municipal parks, parades and funerals and, to a limited degree, educational properties. Our most recent project was Senate Bill 41 to repeal our Jim Crow-era pistol purchase permit law and expand concealed carry into churches which sponsor schools.
Recently, GRNC has received numerous complaints from concealed handgun instructors regarding rule changes sent by email to many (but reportedly not all) instructors on June 23, 2023. The most serious complaints are:
- No public input was sought prior to drafting the proposed changes. Although the Criminal Justice Standards Division has scheduled an August 9 public meeting to discuss them, the June 23 message from Bob Overton says, “These changes will take effect on October 1, 2023. Below is a summary of the changes that are being made by the Commission…” implying that the changes described in the memo are immutable. Also, while G.S. 150B-21.1 authorizes “temporary” rules, and 150B-21.1A “emergency” rules, both are statutorily authorized only where “adherence to the notice and hearing requirements of G.S. 150B-21.2 would be contrary to the public interest,” in addition to other conditions. It is difficult to understand how public input on purely administrative matters related to the timing and reporting of CHP courses could be considered “contrary to the public interest.”
- The requirement that instructors submit a “Pre-Delivery Report” thirty (30) days prior to a class is an onerous restriction which will make it significantly harder for lawful citizens who want concealed handgun permits to obtain the necessary training.
- The proposed “Post-Delivery Report” to be sent by instructors presents yet another burden, particularly for instructors who do not conduct training as their primary livelihood.
- The requirement that instructors keep a “roster” of students, including full legal name and “contact information” represents an invasion of privacy for students who take the course but do not, for whatever reason, choose to apply for a concealed handgun permit. Given that the state maintains a database of concealed handgun applicants, the requirement is also redundant.
Because the North Carolina Department of Justice Criminal Justice Standards Division and its director, Jeffrey Smythe, fall under your direction, GRNC considers you responsible for these egregious changes.
As I’m sure you are aware, GRNC opposes any measure which makes it more difficult for lawful North Carolinians to protect themselves and their families. In particular, implementation of the “Pre-Delivery Report” requirement will make it significantly more difficult to obtain the training for a concealed handgun permit, almost certainly suppressing applications and rendering citizens vulnerable to violent crime.
In the absence of sound evidence that changes to instructor protocols are needed, GRNC will regard additional restrictions as abuse of a regulatory agency to harass lawful gun owners, much as the Biden administration is misusing rulemaking and oversight authority via the Bureau of Alcohol, Tobacco, Firearms, and Explosives.
Accordingly, by 5:00 PM EDT on July 14, 2023 we need acknowledgement that proposed changes which burden concealed handgun instructors will be withdrawn or otherwise mitigated. Failure to do so will result in GRNC taking action up to and including asking the Republican supermajority in the NC General Assembly to make legislative changes to the concealed handgun certification process as they have recently done with the NC State Board of Elections.
Armatissimi e liberissimi,
F.Paul Valone
President, Grass Roots North Carolina
Executive Director, Rights Watch International
Radio host, Guns, Politics and Freedom
Cc: Members, NC Criminal Justice Education and Training Standards Committee
Jeffrey Smythe
Michelle Schilling
Bob Overton
Founded in 1994, Grass Roots North Carolina is an all-volunteer 501(c)(4) organization dedicated to preserving individual liberties guaranteed by the U.S. Constitution and Bill of Rights with emphasis on the Second Amendment right to keep and bear arms.
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