June 4, 2025

Mr. John Melander, Esq.

Deputy General Counsel

Executive Office of Public Safety and Security

One Ashburton Place, Room 2133

Boston, MA 02108

Dear Atty. Melander,

On behalf of Gun Owners’ Action League (GOAL), our members, our board of directors and our staff, it is once again an understatement to say that we have concerns about the proposed regulations regarding mandatory live-fire training for License to Carry (LTC) applicants in the Commonwealth. We appreciate the opportunity to comment on this matter before EOPSS submits its report to the Legislature, it is important that gun owners and those concerned with range operation have input on this important regulation.

Like our registration and serialization testimony, we would just like to voice that most of our concerns relate to the statute itself and we will take this opportunity to put our feelings on the record, we are also interested in ensuring that the regulations are not overly onerous and difficult to follow – like Chapter 135 itself.

Massachusetts is unique, the Commonwealth has no public ranges and unfortunately, there are very few for-profit ranges here as well. This means that the large majority, realistically almost all, of the gun ranges in MA are at private clubs. This means that the majority of these classes must take place at these private clubs if it is to be accessible to all who want to exercise their Second Amendment Civil Right. This will only work if the ranges decide to allow these classes or if the Commonwealth forces them to take it on. In the latter case, there are 5^th and 14^th Amendment taking concerns that will likely need to be addressed if the state intends to use some type of enforcement. 

If clubs are indeed forced to take on this extra responsibility, the state must have a conversation about capacity, limitations, insurance coverage, fair and just compensation including possible expansion, maintenance and possibly loosening zoning restrictions, noise ordinances and other regulations around the use and siting of ranges.

This matter also calls on the state to address a fairness and access issue: what about those citizens who live in what we’ve termed “range deserts” like in the City of Boston? Where are they supposed to get their training? Will the state consider addressing possible transportation or facility location issues? These questions need to be answered if this system is to be fairly applied to the MA population as whole – not everyone has ready, close access to a facility with the functions necessary to provide this training, making their Second Amendment rights unavailable to them.

There are also questions regarding what this training will look like as the curriculum has not yet been established. Before we can really accurately comment on the new requirements in order to give an accurate report, the course of fire including distance, caliber, number of shots, placement, etc. should be made available and allow for comments before implementation as well. We think that this, as well as holding the hearings in accordance with § 152 of Chapter 135 would have made EOPSS’s report more accurate. Direct input from clubs in the form of visits, conversations, etc. would be helpful for the report as they would be able to give you a more precise view of the limitations and abilities of ranges to handle training for the estimated 30,000 to 40,000 new applicants the state has been seeing in recent years.

Additionally, the Commonwealth should consider funding and creating public ranges. However, we are not so sure if they will, prior to, and anticipation of, the passage of Ch. 135, GOAL attempted to file an amendment to the budget that would fund a number of public shooting ranges: we could not get a sponsor in either chamber or either party. As we’ve already covered, this solution in search of a problem has its very own problem: access, and no one seems to want to address it on the Legislative level, so hopefully your report will reflect this and other concerns before any new requirements are implemented.

We have included a copy of the proposed amendment to this document as well. In complete honesty, it was drafted to start a conversation, so the accuracy of the numbers could be questionable as they are rough estimates. However, the provisions outlining the needs and requirements for such facilities to be successful are accurate.

Do not misunderstand, GOAL as an organization provides education, training and shooting instruction as an integral part of our mission. In addition, we advocate for folks to get as much quality firearms training as one can possibly get, and we consider being trained in the use of your equipment to be of paramount importance if one wants to be a responsible gun owner.

In no way should our opposition to this mandate be interpreted as an indictment of firearms training, we simply and strongly feel that this responsibility should be left up to the individual as they alone hold that responsibility and this requirement could preclude some citizens from exercising their constitutional civil rights.

Sincerely,

Mike Harris

Director of Public Policy

Gun Owners’ Action League

Amendment #__ to H4600

Establishing firearm safety training facilities

___________ of ______________ moves to amend the bill in section 2, in item 8000-0313, in

line 1, by inserting after the word “programs” the following: “and provided further, that not less

than $12,000,000 shall be expended to acquire property, retrofit and build fourteen (14) public

firearm ranges, one in each county, in order to fulfill anticipated live-fire training mandates.

Each public facility shall be indoors, available twelve (12) months a year, have at least five (5)

lanes minimum, be at minimum the required length to fulfill such training mandates, situated

near public transportation, ADA accessible, contain a classroom capable of holding a minimum

of twenty (20) students with required A/V equipment, and whatever other local and state

building codes require. The facilities shall also be exempt from local zoning ordinances, noise

ordinances, setbacks, and other required ordinances. The Secretary of the Executive Office of

Public Safety and Security, the Colonel of the State Police, and Firearms Records Bureau shall

promulgate the necessary regulations and assist in the search for, and acquisition of, the property

required to build such facilities keeping in mind the necessity to ensure underserved

communities and urban areas are equipped with the necessary facilities to ensure any citizen who

wants to and qualifies for, their License to Carry or Firearms Identification Card (or the

equivalent of), can do so with little more effort than those who live outside of such areas.

Further, when necessary, the Commonwealth shall take steps to indemnify private gun clubs and

ranges during the hours they are used for such state mandated training.”; and in said item by

striking out the figures “$100,000” and inserting in place thereof the figures “$12,100,000”.