Dealer Licensing Rules Officially Posted and Open for Public Comment

[InterestedBystander]

MegaSports is the largest retail store I have been in. I can't imagine how many cameras and how much storage is needed for on site recording of store areas and parking lot much less the bandwidth for off site digital storage for 90 days (or longer if under investigation) for multiple camera video streams, plus reliable battery backup for cameras and DVRs. Suppose that also means the internet gear also needs to have battery backup to maintain off site storage.

 

This is going to raise firearm costs as these get passed along to consumer.

[Flynn]

Comcast doesn’t list upload speeds for its business service. Best info I could find quickly is maybe 10-20M for some of the fastest and most expensive packages . Upwards of $2-300 per month after introductory pricing ends. And that might still not be enough for the number of high resolution cameras required. People were complaining about local storage prices, but hard drives are fairly cheap and a fairly one time purchase. These offsite requirements are insane. I could see an easy $3-500 per month for a modest size store to meet the storage requirements. Sent from my iPhone using Tapatalk

 

https://www.business.org/services/internet/comcast-business-internet-review/

 

Note that the fastest plan at 35 Mbps IMO realistically might sustain 3-4 HD (720/1080) camera uploads at a time 'realiably' assuming it's a dedicated line for just the cameras, It will might sustain a single high compression 4K upload at that speed. And note those commericial offerings are not available everywhere, they are limited markets.

 

Some trivia, a full time 25 Mbps upload (about 4-5 HD camera uploads) will eat up about 8100 Gigs (8 TB) of bandwidth a month! So an FFL with say 5 cameras and 90 days of retention will not only need an Internet connection with that kind of bandwidth and speed but they will also need about 25TB of remote data storage, and that is just a starting point for a small shop, I can easily see the video requirements requiring more than 4-5 cameras for many.

[ilphil]

I guess it’s time to stock up on ammo before pricing goes totally crazy.

[bmyers]

I guess it’s time to stock up on ammo before pricing goes totally crazy.

 

I guess I will be driving across the river to buy ammo.

[Lou]

Per Molly’s first post on this thread :

 

Questions/requests for copies/comments through 10/7/19: Matthew R. Rentschler, DSP, 801S. Seventh St., Suite 1000-S,Springfield Il 62703, 217/782-7658

 

I think your concerns need to go to the correct place.

[mjw45]

Per Molly’s first post on this thread :

Questions/requests for copies/comments through 10/7/19: Matthew R. Rentschler, DSP, 801S. Seventh St., Suite 1000-S,Springfield Il 62703, 217/782-7658

I think your concerns need to go to the correct place.

 

I agree.

But first we need to dissect the rules so we can make a reasonable argument.

 

Just saying the video requirements are bad isn’t going to mean much.

 

Being able to say-

An average small shop needs 7-12 cameras of this minimum resolution.

This will require X amount of storage.

Costing Y dollars.

 

And Z amount of bandwidth for offsite storage costing Y amount.

 

And that bandwidth is not even available in this percentage of the state.

 

 

 

 

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[Flynn]

Per Molly’s first post on this thread :

 

Questions/requests for copies/comments through 10/7/19: Matthew R. Rentschler, DSP, 801S. Seventh St., Suite 1000-S,Springfield Il 62703, 217/782-7658

 

I think your concerns need to go to the correct place.

How is it incorrect to post them here to bring awareness and possibly invoke others to file official comments?

[Molly B.]

 

Per Molly’s first post on this thread :

Questions/requests for copies/comments through 10/7/19: Matthew R. Rentschler, DSP, 801S. Seventh St., Suite 1000-S,Springfield Il 62703, 217/782-7658

I think your concerns need to go to the correct place.

I agree.

But first we need to dissect the rules so we can make a reasonable argument.

 

Just saying the video requirements are bad isn’t going to mean much.

 

Being able to say-

An average small shop needs 7-12 cameras of this minimum resolution.

This will require X amount of storage.

Costing Y dollars.

 

And Z amount of bandwidth for offsite storage costing Y amount.

 

And that bandwidth is not even available in this percentage of the state.

 

 

 

 

Sent from my iPhone using Tapatalk

 

 

 

Yes, that is exactly the type of information we need to gather up.

[Flynn]

 

Per Molly’s first post on this thread :

Questions/requests for copies/comments through 10/7/19: Matthew R. Rentschler, DSP, 801S. Seventh St., Suite 1000-S,Springfield Il 62703, 217/782-7658

I think your concerns need to go to the correct place.

I agree.

But first we need to dissect the rules so we can make a reasonable argument.

 

Just saying the video requirements are bad isn’t going to mean much.

 

Being able to say-

An average small shop needs 7-12 cameras of this minimum resolution.

This will require X amount of storage.

Costing Y dollars.

 

And Z amount of bandwidth for offsite storage costing Y amount.

 

And that bandwidth is not even available in this percentage of the state.

 

 

 

 

I fully agree, share the knowledge here, point out issues and collaborate on the issues, so that when people head over to make official comments those comments have real substance, facts and concerns instead of vs just empty and short 'it's bad' comments that will almost certainly be summarily skipped over.

[Flynn]

I'm going to frame this part of the proposal

 

"Cameras shall be mounted so as to allow for the capture of facial recognition, clear and certain identification of any person entering or exiting the retail location, the immediate surrounding area, and license plates of vehicles in the parking lot area."

 

As all of us should be well aware of 'security cameras' are notoriously poor quality, they have low frame rates, high compression, poor (infinity) focus, poor wide angle lenses and are just overall poor video. There is no such thing as magic enhance this image software that takes images that look like Lego blocks to crystal clear portraits like seen on TV.

 

That said based on the proposal's wording of what the video quality must be, not only in the building but the surrounding area, I figured I would frame up the 'required' face size necessary to accomplish this. From what I gathered in a Google search for very basic facial ID you need 32 pixels between eye centers or 64 pixels between eye centers for better facial ID, obviously bigger is better, so I would say based on the wording of the proposal that says 'clear and certain' the videos should at minimum capture 64 pixels between eyes or face being in violation of the law. When doing this it becomes obvious that wide angle, broad capture cameras are not going to make the cut, the faces will have to be 'framed' at the size seen bellow for the specified resolutions (32 pixels and 64 pixels) this means cameras mounted high up on the walls or roof to capture the parking lot are not going to cut it, unless you have a dozens of them all zoomed into different locations, same with inside cameras, no wide angles unless it's in a closet sized room, you are going to need lots of cameras to cover bigger rooms.

 

Anyway look at the faces framed in these video resolutions and consider how that is to be accomplished not only inside the building but in the entire surrounding area and parking lots as well. You are not just going to be able to install a few over the counter wide angle security cameras, you are going to have to plan this out well, with decent quality cameras and tight focusing to bring the faces into frame big enough to fully comply with the proposed wording. Feel free to use these images in any official comment, to point out how complicated and costly this is going to be to follow the black and white text of the proposal. Note that even at 1080P a full head to shoe camera angle of people walking in the front door is borderline enough facial quality to meet the black and white requirements of the proposal, a 360 or 720 camera would have to be a tight focus on just head shots walking in the door, and that same head shot tightness has to cover the entire surrounding area.

 

 

 

[McCroskey]

"Keep ammunition stored separately from the firearms inventory and out of the reach of customers"

 

Great...get to wait until a clerk is done selling someone a firearm. No more easily inspecting new ammo or quickly picking up some .22.

 

I absolutely hate this. The guns are already locked up, what do they think someone could do with a random box of ammo and no gun? Throw the bullets at people? I did my carry renewal at 355 recently so I stopped at Bass Pro Shop after to pick up some ammo... all of the handgun ammo is in a locked case, while all the rifle ammo and shotshells are right there there to grab. No idea what the point of that is. And the gun counter was jammed with people so I just left.

[InterestedBystander]

The Flinn Report: Illinois Regulation

 

Illinois Regulation is a summary of the weekly regulatory decisions of State agencies published in the Illinois Register and action taken by the Illinois General Assembly’s Joint Committee on Administrative Rules.

 

Illinois Regulation, also titled The Flinn

Report in memory of founding JCAR member Rep. Monroe Flinn, is designed to inform and involve the public in changes taking place in agency administration

 

Summary report for Gun Dealer Licensing

http://www.ilga.gov/commission/jcar/flinn/20190823_August%2023,%202019%20-%20Issue%2034.pdf

[mjw45]

Flynn I completely agree with your assessment.

Most people do not realize what a good video security system entails.

And how many cameras it truly requires.

And these new state imposed requirements are going to require a gold plated system to implement.

I was going to stop by an LGS today just to eyeball it and take a guess at cameras needed.

It is a small to midsize store.

 

With relaxed requirements I figure 7-10 cameras minimum per store.

To meet the current requirements figure double that, mostly outside.

Even then there will probably be blind spots.

No let me rephrase that- there will definitely be blind spots, unless we go to 3 times the cameras and very creative mounting, possibly on other properties.

 

Now if I could design the physical layout of the store and parking areas I could reduce the number of cameras and resolution requirements.

 

But to cover a variety of existing stores, it will be a very large and intensive system.

 

And much of it is because of the exterior and license plate requirements.

 

And for what use?

How many criminals are robbing gun stores in their own registered vehicles?

 

Vs driving stolen cars or stolen license plates?

 

 

 

 

 

 

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[InterestedBystander]

..."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."...

 

Whats a large inventory? Isn't this a bit vague and presents the possibility of unknown costly "additional" requirements?

 

Monitoring services in place by 2020, like the video requirements, feels like it could be quite costly given requirements for notifications, cellular backups, alerts, inspections by vendor, etc.

 

I wonder how many others would not have applied for FFLs if they had seen some of these first?

[mab22]

 

I wonder if any FFLs will be streaming to Twitch or YouTube in an attempt to have an offsite video that is no cost.

Streaming is not a backup.

"The recordings shall be simultaneously backed-up offsite (e.g., cloud storage, offsite server)."

I work for a cloud services provider and I have not heard of “simultaneous backups” as of yet. There have been requests to perform snapshots at specified intervals but never “simultaneously”, it does not exist at this time, that I am aware of. This would require the Camera system to write to the systems disks AND to a separate backup “system” at the same time per the word “SIMULTANEOUSLY”, it has a specific meaning.

If you know of a vendor that does this please let me know.

 

And when you mention streaming video, that’s not the same and the

[InterestedBystander]

I think I have read of backup software for home systems that monitors file activity and automatically backs up found changes out to the cloud. Drawing a blank on the product and the ability to do so for a large volume of commercial activity, which includes video, across multiple streams is going to have extra challenges.

[Flynn]

With relaxed requirements I figure 7-10 cameras minimum per store. To meet the current requirements figure double that, mostly outside. Even then there will probably be blind spots. No let me rephrase that- there will definitely be blind spots, unless we go to 3 times the cameras and very creative mounting, possibly on other properties.

 

Yep, and to be blunt, where are they going to get the kind of bandwidth necessary to upload a dozen, two dozen or three dozen HD cameras worth of 24/7 video to an off-site location? Comcast and AT&T don't offer those speeds or bandwidth amounts. For a moderate to large store to be able to off-site backup that many cameras in real time they are going to need an OC-3 or better connection. I'm out of touch with current backbone dedicated Internet line cost, but I know it's safe to say that an OC-3 still has to cost several thousand a month, plus some un-Godly per foot cost to get the cable run and installed in the first place. For all practical purposes this kind of Internet service isn't even going to be available to rural Illinois FFLs, thus this will force all the FFLs that think they can survive the new rules to consolidate around huge metropolitan areas where they can possibly save enough money on just the Internet service to maybe stay in business.

 

That or we will see a lot of FFLs that open themselves up to all sorts of criminal and civil liability trying to pretend they are actually complying with the black and white text.

 

It's a total mess, if these proposals become the law I would expect upward of 90% or more of all FFLs in Illinois will be out of business, and/or some running illegally not in compliance, because they can't realistically comply.

 

I expect most of the big box stores that are left selling firearms to simply pull out of the market ASAP, it's simply not profitable in the least for them to even begin to install this level of video monitoring.

[Flynn]

I think I have read of backup software for home systems that monitors file activity and automatically backs up found changes out to the cloud. Drawing a blank on the product and the ability to do so for a large volume of commercial activity across multiple streams is going to have extra challenges.

 

It would still technically be delayed, those systems scan for file changes, so the backup would be delayed until the video recording software closes the video file segments and then the backup software notices the newly create file and backs it up, that delay length would be dependent on how often the video recording software closes files and starts a new one. As said "simultaneously" has a specific definition and although there might be some fudge room in how a court might interpret the word here, there is also the chance one could easily find themselves on the wrong side of the law due to lags in the backup, especially if there ever was a break-in where it is discovered that there was a lag in the off-site backup.

 

I'm sure software to accomplish this to some higher degree can be written, but I suspect it's going to be a CPU hog because you can't always get constant write speeds over network connections, so there is always going to be some lag and buffer between what is written locally and what is written at the remote location, and when you are talking dozens of cameras this becomes a nightmare, it's going to basically require as said above "a gold plated system to implement" and realistically probably a custom solution that could end up cost $10s or even $100s of thousands of dollars to have implimented.

[mab22]

I think I have read of backup software for home systems that monitors file activity and automatically backs up found changes out to the cloud. Drawing a blank on the product and the ability to do so for a large volume of commercial activity, which includes video, across multiple streams is going to have extra challenges.

That’s what incremental backups are and they can be scheduled to run every hour, day, week, when ever, etc.

Does that meet the definition of “simultaneously”?

 

https://www.merriam-webster.com/dictionary/simultaneous

 

simultaneous adjective

si·​mul·​ta·​neous | \ ˌsī-məl-ˈtā-nē-əs , -nyəs also ˌsi-\

Definition of simultaneous

1 : existing or occurring at the same time : exactly coincident

2 : satisfied by the same values of the variables

simultaneous equations

[ChicagoRonin70]

Once again, there needs to be a court case filed that definitively highlights that these requirements are so egregiously onerous and obviously intended to prevent the citizens of Illinois from being able to access firearm stores, the way that strict abortion laws are being challenged on the grounds that they are intended to make abortion clinics unavailable to citizens in an unconstitutional way.

[Patriots & Tyrants]

 

I guess it’s time to stock up on ammo before pricing goes totally crazy.

 

I guess I will be driving across the river to buy ammo.

 

 

 

Heh my feeling as well; what I can I will order online and ship to my fathers place in Wisconsin or Indiana. What I cannot I will buy when visiting WI or IN. Its sad but this is going to kill off shooting sports in Illinois if the courts do not offer relief.

[InterestedBystander]

Its sad but this is going to kill off shooting sports in Illinois if the courts do not offer relief.

The Atty General petition to dismiss the ISRA suit is scheduled for 9/5

[Patriots & Tyrants]

 

Its sad but this is going to kill off shooting sports in Illinois if the courts do not offer relief.

The Atty General petition to dismiss the ISRA suit is scheduled for 9/5

 

 

 

The ISP should have waited until after 9/5 to post this if that is the case, does our "side" have the ability to amended their lawsuit based on this new information?

[Bitter Clinger]

After reading some of that law, I've come to the conclusion that it's not possible to implement, even for big box stores.

 

For example, my local Bass Pro is in a big shopping mall with an absolutely enormous shared parking lot that wraps around the entire complex. There is no way in heck they could put cameras there to capture all license plates of the tens of thousands of cars which pass through there every day.

 

Also, Bass Pro is HUGE. Do they propose putting cameras everywhere in the store to capture EVERY angle. Not possible.

 

The law was clearly created to eliminate all gun shops because there is no way to practically comply with it.

[InterestedBystander]

I wonder if this is based upon, or even a copy of legislation approved in any other states. Flavors of GDL are in other states but I could not find same video requirements. I might guess the ISP did not come up with all of this on their own but more consulting with gun control groups. How did this work out elsewhere?

[Jamie]

Just a modest proposal, but I'd suggest ensuring that you include what the typical profits are for small, medium, and large guns shops. Just as the public thinks that AR-15s spew thousands of rounds of bullets per second, they also likely think that gun stores are raking in massive profits every month.

 

If that's the case, the numbers about what the video will cost is just going to sound like whining about losing money rather than what it is -- a very real possibility of putting tons of small businesses, veteran-owned businesses, minority-owned businesses, women-owned businesses, etc. out of business entirely and permanently.

[Black Flag]

It's a total mess, if these proposals become the law I would expect upward of 90% or more of all FFLs in Illinois will be out of business, and/or some running illegally not in compliance, because they can't realistically comply.

 

I expect most of the big box stores that are left selling firearms to simply pull out of the market ASAP, it's simply not profitable in the least for them to even begin to install this level of video monitoring.

 

Once again, there needs to be a court case filed that definitively highlights that these requirements are so egregiously onerous and obviously intended to prevent the citizens of Illinois from being able to access firearm stores, the way that strict abortion laws are being challenged on the grounds that they are intended to make abortion clinics unavailable to citizens in an unconstitutional way.

 

After reading some of that law, I've come to the conclusion that it's not possible to implement, even for big box stores.

 

For example, my local Bass Pro is in a big shopping mall with an absolutely enormous shared parking lot that wraps around the entire complex. There is no way in heck they could put cameras there to capture all license plates of the tens of thousands of cars which pass through there every day.

 

Also, Bass Pro is HUGE. Do they propose putting cameras everywhere in the store to capture EVERY angle. Not possible.

 

The law was clearly created to eliminate all gun shops because there is no way to practically comply with it.

 

The resultant of all the above is ripe for a new Federal suit, or "Ezell III".

[mikew]

Just look at the video requirements alone...

 

Does any other regulated controversial-along-partisan-lines business type have requirements like this?

Weed Dispensary? Weed grower? Abortion Clinic?

 

How about regulated but not controversial?

Retail Pharmacy? Pharmaceutical Wholesaler?

Supplier of Agricultural Chemicals? (Ammonium Nitrate - explosive precursor, anhydrous ammonia - precursor)

Individual Farms? (both Ammonium Nitrate and Anhydrous Ammonia)

[mikew]

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

[mjw45]

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

 

 

 

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