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Dealer Licensing Rules Officially Posted and Open for Public Comment


Molly B.

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If you are a weed dispensary, you are not required to have the off-site or cloud storage of your video.

 

http://www.ilga.gov/commission/jcar/admincode/068/068012900G04100R.html

Great point

Counterpoint- Weed is good. Guns are Bad

 

 

 

Sent from my iPhone using Tapatalk

 

 

You know your State is screwed up when it is easier to by weed than ammo.

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If you are a weed dispensary, you are not required to have the off-site or cloud storage of your video.

 

http://www.ilga.gov/commission/jcar/admincode/068/068012900G04100R.html

Great point

Counterpoint- Weed is good. Guns are Bad

 

Weed (albiet still prohibited) is a privilege to use, I would not fucus much on comparing restrictions/infringements on privileges vs exercising a protected right, even though it's clear they lifted the requirements from that law and added more.

 

We should look at places where other rights are exercised and compare the requirements to operate those to what they propose for gun stores, places like libraries, book stores, magazine stands, places of worship, voting booths and so on, the 2nd is a civil right and we need to focus on treating it as such and let the anti-gunners focus on the fallacy of comparing it to a privilege and call them out when they do.

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The fact that the World Shooting recreational Complex in Sparta is exempted causes this law to be a violation of equal protection.

 

Good point, since we are talking about exercising a civil right, exemptions for a select some while enforcing it against others is a clear violation of the equal protection clause of the 14th!

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Anyone know if this is being challenged in the courts?

 

ISRA filed a lawsuit the day it was signed.

And the Atty General filed a motion to dismiss.

 

Hearing is 9/5.

 

http://records.sangamoncountycircuitclerk.org/sccc/Home.sc

 

Docket detail for case 2019-CH-000253

 

08/20/2019

Notice of Hearing Filed by Defendant and Attorney: KWAME RAOUL & SUNIL BHAVE

 

Motion or Petition Hearing on Sep 5, 2019 at 10:30 AM

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Anyone know if this is being challenged in the courts?

ISRA filed a lawsuit the day it was signed.

And the Atty General filed a motion to dismiss.

 

Hearing is 9/5.

 

http://records.sangamoncountycircuitclerk.org/sccc/Home.sc

 

Docket detail for case 2019-CH-000253

 

08/20/2019

Notice of Hearing Filed by Defendant and Attorney: KWAME RAOUL & SUNIL BHAVE

 

Motion or Petition Hearing on Sep 5, 2019 at 10:30 AM

 

 

IMO it's time for the ISRA to file an ammended complaint.

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I know I'm a little late to the game on a response, but if you're looking for a real world amount of bandwidth needed, We just finished a 23 camera install at a place utilizing 5 ptzs, and the other 18 cameras were all hd, Before I left I checked the camera servers nic, it was clocking 212 Mbps Bandwidth utilization, and that was a dedicated camera server. I didn't play alot with compression settings on that. And that was using Axis 3375 cameras, so between 500 and 1k for the fixed ones depending on how good your status is with the distributor, and wether you want weather proof.

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I know I'm a little late to the game on a response, but if you're looking for a real world amount of bandwidth needed, We just finished a 23 camera install at a place utilizing 5 ptzs, and the other 18 cameras were all hd, Before I left I checked the camera servers nic, it was clocking 212 Mbps Bandwidth utilization, and that was a dedicated camera server. I didn't play alot with compression settings on that. And that was using Axis 3375 cameras, so between 500 and 1k for the fixed ones depending on how good your status is with the distributor, and wether you want weather proof.

 

Not late at all, thanks for real life numbers, this shows exactly how impractical this is cost wise and especially bandwidth wise. Using your real life numbers of about 9Mbps per camera it will only take 4 maybe 5 cameras or less to fully saturate most consumer broadband connections upload capacity. Higher compressin will cut those numbers a bit but may run contrary to the requirements of image quality in the law.

 

Either way, the off-site data-retention is a death sentence to a vast majority (nearly all) gun shops as they will simply not be able to comply as the required bandwidth isn't available or is far, far, far too cost prohibitive to them same with upfront cost, to sink $10s of thousands into a camera system isn't viable for many small gun shops.

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I did some real rough calculations for 10 cameras at full HD (2k) quality and 15FPS rough and tough 18T of data after 90 days. You would need about 1Gbit connection to send that to the cloud and the software to convert that to a cloud storage format.

 

Rough costs assuming the above would be:

 

  1. 1200 to 1500 local storage (includes ability to get to public cloud storage)
  2. 3400 for camera system
  3. Cloud storage about 800 a month
  4. Internet connection 500 for uncapped business connection
  5. PS setup 24 hours 200 per hour average

grand total 1st year about 25000

each year after 15600

 

This would be a put together system not a professional security system I have no idea how much that would cost. I am sure it would be more. I would also be dependent on a 1Gbit internet connection being available and no data cap. May need more work to get the upload speed to be reasonable as that is much less typically then the download. You also might be able to stream the backup better at a colo site and dedicated pipe with local backup rather then the other way around.

 

Costs should be fairly accurate if you take into account motion activation and 12 hour video window overall.

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...You would need about 1Gbit connection to send that to the cloud....

 

....Internet connection 500 for uncapped business connection...

 

And that brings me back to my point, that type of connection isn't readily available outside of large metropolitan areas and even then sometimes it will incur astronomical installation and much higher monthly fees. For much of rural Illinois, to be blunt "forget about it" it's just not going to happen for your average firearms dealer.

 

 

 

Costs should be fairly accurate if you take into account motion activation and 12 hour video window overall.

 

As I was corrected earlier, the law says 24/7 video recording, 12 hours isn't going to cut it.

 

And this section negates the use of any motion detection, on any of the cameras "Twenty-four hour recordings from all video cameras shall be available for immediate viewing by the Department upon request."

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...You would need about 1Gbit connection to send that to the cloud....

 

....Internet connection 500 for uncapped business connection...

 

And that brings me back to my point, that type of connection isn't readily available outside of large metropolitan areas and even then sometimes it will incur astronomical installation and much higher monthly fees. For much of rural Illinois, to be blunt "forget about it" it's just not going to happen for your average firearms dealer.

 

 

 

Costs should be fairly accurate if you take into account motion activation and 12 hour video window overall.

 

As I was corrected earlier, the law says 24/7 video recording, 12 hours isn't going to cut it.

 

And this section negates the use of any motion detection, on any of the cameras "Twenty-four hour recordings from all video cameras shall be available for immediate viewing by the Department upon request."

 

 

No reason to record nothing it would be 24/7 just not turn on when nothing to record. I have done cloud security storage transactions and they all work that way. Really would not make a lot of difference as the camera system includes about 6T of overflow space anyways. This is rough estimate just to give a ball park for someone who is fairly technical but cant do it on their own. As to the bandwidth you can get it just effects the cost.

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No reason to record nothing it would be 24/7 just not turn on when nothing to record.

 

 

Every reason as that is literally what the proposed rules/law says must be done, I quote "Fixed cameras shall be installed to provide a consistently recorded image of these areas." & "Twenty-four hour recordings from all video cameras shall be available for immediate viewing by the Department upon request."

 

It states that all cameras have to recorded 24/7 with simultaneous off site backup, and you have to have 24 hours of each camera ready for immediate review at any given time. It makes no mention of no pan/tilt, no motion sensing, only fixed cameras covering all areas recording 24/7 with backing up in real time, good enough quality for facial recongnition and license plate capture of vehicles in parking lot.

 

If there ever was a problem and the police requested the last days worth of of camera footage and you produced 2 hours saying "The cameras didn't detect anything worth recording for the other 22 hours" do you really think that is going to fly based on the black and white text of the proposed rules/law? I don't and I would not even pretend to believe that was acceptable, under the proposed wording.

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It looks like they are only taking feedback via mail, so here is the start of my letter to Mr Rentschler. Feel free to echo. What else short we add?

 

August 31, 2019

Matthew R. Rentschler DSP

801S. Seventh St.

Suite 1000-SSpringfield, IL 62703

 

Dear Mr. Rentscher,

 

I wanted to share my concerns about the recently published proposed rules for the Firearm Dealer License Certification Act. The cost of implanting the requirements of the rules will negatively impact firearm dealers ability to do continue do business.

 

Your rules require:

 

90 days worth of 24/7 HD facial recognition video surveillance of the entire retail space along with camera to capture the license plate of all cars in. The video surveillance must be stored onsite storage with simultaneous offsite back up.

 

In order to comply with this rule, according to security experts, a small firearms dealer would have to pay in excess of $25,000 for the initial set-up with an addition cost of $16,000 in annual operational costs. It will be impossible for some dealers to comply with the rules as the 1+ Gbps high-speed internet service required for offsite storage is not available in their area.

 

The end result of your onerous rules will result in the majority of Illinoisâ firearms dealers closing their doors, the impact of which will severely limit the right of law abiding citizens in Illinois to keep and bear arms.

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From page 126:

 

Time, Place, and Manner in which interested persons may comment on this proposed rulemaking: Within 45 days after the publication of this Notice, any interested person may submit comments, data, views or argument regarding the proposed rules. The submissions must be in writing and directed to: Mr. Matthew R. Rentschler Chief Legal Counsel Illinois State Police 801 South 7th Street, Suite 1000-S Springfield IL 62703 217/782-7658
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re Alarm monitorimg w/ cellular service?

 

-Ive been a few places in the state where I can not receive cellular service for miles and miles. Dont know how common that is but is the cellular backup an issue in rural IL to comply?

 

-I assume they are common, but are all police locations equipped and able to receive those direct alarms from the licensee place of business? Thinking again of the more rural parts of the state that may have small force and low budget.

 

-I assume the yearly cost to have all devices being tested by a qualified alarm vendor is not prohibitive.

 

-If a retail location presents special security issues, such as an extremely large inventory, exposed handling, or unusual vulnerability to diversion, theft or loss, the Department may require additional safeguards.

 

Additional safeguards mean what?

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As mentioned about the largest in the area

This stuff is already being done, before the law

 

I can’t say exactly how, but only cameras for door and a few others would need to be monitored

During operating times, those are recorded in house and everyone know about yard drive size

 

It’s going to punch many, but the better organized places have been doing this for years, some to the anger of posters here!

 

lol. :-)

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As mentioned about the largest in the area

This stuff is already being done, before the law

 

I can’t say exactly how, but only cameras for door and a few others would need to be monitored

During operating times, those are recorded in house and everyone know about yard drive size

 

It’s going to punch many, but the better organized places have been doing this for years, some to the anger of posters here!

 

lol. :-)

 

Not exaclty sure what your point it, the proposed rules are drastically different than what you claim is already being done... I would bet that no FFL in Illinois is anywhere near doing what is in the proposed rules in regards to video cameras, not even places like Walmart. Local storage of a few cameras during open hours with maybe some motion detection after hours that I suspect some gun shops are doing is exponentially easier to accomplish then what is proposed. The simultaneous off-site real time video backup is a monumental task to accomplish for the number of cameras and retention requirements to meet the letter of the law, I highly doubt anyone is doing this anywhere near the capacity mandated in the rules.

 

With the rules in place, for many rural gun shops, it will literally be cheaper to rent a second building next to the gun shop and run network cables and/or setup a private directional wifi network to another builidng in local proximity to accomplish the 'off-site' back vs what it will cost to to bring in sufficient 'Internet' service speeds and bandwidth to do it. Assuming that passes the sniff test of off-site if say the buildings are physically connected.

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A public hearing has been requested by Federal Firearms Licensees of Illinois

 

...Illinois law says that state agencies proposing new rules must hold a public hearing if requested. FFL-IL has requested a public hearing on the proposed rules for the gun dealer certification.

 

Filed with the State Police and JCAR we await the announcement and will share that with you so our supporters may participate. Below is our letter to the State Police

 

8/30/19

 

Mr. Matthew R. Rentschler

Chief Legal Counsel

Illinois State Police

801 South 7th Street

Suite 1000-S

Springfield IL 62703

 

Dear Mr. Rentschler:

 

In accordance with 5 ILCS 1--/5-40, The Federal Firearms Licensees of Illinois (FFL-IL) request that the Illinois State Police hold public hearings on the proposed gun dealer certification rules which were published in the Illinois Register on 8/23.

 

FFL-IL understands the undertaking this presents to the Department and has no objection if it takes longer than the 20 days to facilitate such meeting. Furthermore, do to the size of the regulation, the expansiveness of it and the impact it will have on the remaining 1200 plus FFLs in Illinois, we believe that multiple meetings would be necessary across the state to accommodate the large number of business’ and persons impacted, both FFLs and customers due to the geography and diversity of the state.

 

FFL-IL certifies that we represent “100 interested persons” as required by the statute.

 

You may contact me via email tvandermyd@aol.com or by cell phone 708-218-2180 if you wish to discuss the matter further or the details of this request.

 

Sincerely,

 

Todd Vandermyde

Executive Director

FFL-IL

 

(5 ILCS 100/5-40) (from Ch. 127, par. 1005-40)

Sec. 5-40. General rulemaking.

“The agency shall hold a public hearing on the proposed rulemaking during the first notice period if (i) during the first notice period, the agency finds that a public hearing would facilitate the submission of views and comments that might not otherwise be submitted or (ii) the agency receives a request for a public hearing, within the first 14 days after publication of the notice of proposed rulemaking in the Illinois Register, from 25 interested persons, an association representing at least 100 interested persons, the Governor, the Joint Committee on Administrative Rules, or a unit of local government that may be affected. At the public hearing, the agency shall allow interested persons to present views and comments on the proposed rulemaking. A public hearing in response to a request for a hearing may not be held less than 20 days after the publication of the notice of proposed rulemaking in the Illinois Register unless notice of the public hearing is included in the notice of proposed rulemaking. A public hearing on proposed rulemaking may not be held less than 5 days before submission of the notice required under subsection © of this Section to the Joint Committee on Administrative Rules. Each agency may prescribe reasonable rules for the conduct of public hearings on proposed rulemaking to prevent undue repetition at the hearings. The hearings must be open to the public and recorded by stenographic or mechanical means. At least one agency representative shall be present during the hearing who is qualified to respond to general questions from the public regarding the agency's proposal and the rulemaking process.”

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