Public Comment Period Open for Concealed Carry Rules and Regulations

[Molly B.]

The Firearm Concealed Carry Act authorizes the Illinois State Police to create and implement rules and regulations regarding implementation of the FCCA. The permanent rules (page 15859) proposed by the ISP are available to the public and are open for public comment. After the period of public comment, the rules will be submitted to the Joint Committee for Administrative Rules (JCAR) for approval. This could take place at the December 17, 2013 meeting

 

The deadline for public comment is Nov. 25th and MUST BE SUBMITTED IN WRITING to:

 

Suzanne Bond, Chief Legal Counsel, Illinois State Police, 801 South 7th St. Suite 1000-S, Springfield, IL 62703

 

Lisa Freitag, Rules Coordinator, Illinois State Police, 801 South 7th St. Suite 1000-S, Springfield, IL 62703

 

We encourage you to write your own public comments about concerns or changes you think need to be made to the proposed rules. Remember to be polite and professional in your communications with the ISP.

 

IllinoisCarry submitted comments this past week and which are attached to this post.

 

Section 1231.10 Definitions

“Substantially Similar” – the definition currently being used by the ISP excludes residents and instructors from all other states from being eligible for a carry license or to qualify to instruct Illinois concealed carry courses in their state. The requirement for states to report voluntary mental health admissions is an excessive requirement and should be omitted from the definition. Records throughout the country show that concealed carry licensees are the smallest segment of the population to have any type of prohibitive mental or criminal problems which would make them an at-risk licensee.

“Valid” – The definition of valid includes the word “expired”. Considering the delay in renewing FOID cards and the possibility of the same problem with concealed carry licenses, provision needs to be made in the definition that a carry license shall not be considered expired if a renewal application has been submitted to the Department.

Section 1285.20 Instructor Approval

a. Instructors need to be able to use local law enforcement to submit fingerprints.

Section 1231.30 Instructor Approval Revocation

a. 2) There is no requirement in the law for instructors to maintain a carry license. The requirement for instructors to maintain an IL carry license after April 16, 2014 could be problematic if applications are not processed in a timely manner. If an application has been submitted but a license has not been issued by April 16^th, is the instructor suddenly prohibited from instructing courses which were scheduled months in advance in good faith that the license would be forthcoming?

 

Many instructors are current or retired law enforcement and are already licensed under LEOSA and can carry throughout the nation with that license. The requirement for instructors to have an Illinois license is an added and unnecessary burden. Having a concealed carry license should be up to the individual instructor and their needs.

d. 1) The total number of hours required for training is 16 hrs. Only 16 and 8 hr. courses are listed as approved by the ISP. There is a need for courses to be approved for 4 hrs. and 12 hrs. because credit can be given for 4 hrs. of prior training. Course approval needs to include the words “up to” 16 hours which would grant the option for instructors to provide the number of additional hours a student may need.

h) “Upon receiving substantiated information that a curriculum, as taught, is not consistent . . .”

The unintended consequence of this wording could lead to a curriculum, widely used by many instructors, being removed from the approved list because of an error or negligence on the part of one instructor. The words “as taught” need to be omitted.

Section 1231.50 Training Certification

c) With prior credit recognized for 4 hr. and 8 hr. courses, it is necessary to provide instructors the ability to provide 4 hr. and 12 hr. courses to aid applicants in acquiring the total number of 16 hrs. This can be done by noting curriculums are approved for “up to” 8 or 16 hrs.

Not included in the proposed rules is a list of documentation the Department will accept as proof of prior training for credit toward the required 16 hours. The Department currently states it will accept only certificates of training and not licenses or permits issued as a result of that training. In the case of the Chicago Firearms Permit, which is recognized as credited prior training, the Chicago Firearms Permit office no longer exists and permit holders are being informed the documentation they submitted to that office is no longer available. In the case of the Utah concealed carry license, original applications in many instances were submitted to the Utah licensing bureau by the instructor. All the license holder has as proof of training is the license itself. The Department needs to recognize the license/permit in place of a training certificate if the certificate is not available.

The Department does not list on its website what documentation, other than a DD214, it will accept as proof of military service. There are many certificates of honorable discharge that serve as proof of service, such as the ones listed below. The ISP should research which documents are used by the branches of service and add them to the list of acceptable documents.

 

The Department does not have a list on its website listing what documentation it will accept for proof of active duty military. Active duty members will not have a DD214 and a military ID card should suffice.

Section 1231.60 Issuance of License

c & d) Applications need to be available in more than just electronic form. The law requires written applications. Applicants need the option of submitting a paper application and submitting a written signature, along with the option of paying with a check, money order, or cashier’s check.

From the FCCA: Section 30. Contents of license application.

575]

(a)

The license application shall be in writing, under penalty of perjury, on a standard form adopted by the Department and shall be accompanied by the documentation required in this Section and the applicable fee.

Furthermore, requiring the application and all documentation to be submitted electronically will disenfranchise a large portion of the elderly and the poor who do not have access to a computer or the internet. While online application and document submission may expedite the application process for the ISP and for the applicant, it cannot be the ONLY means of submitting an application.

Section 1231.70 Objections

Law enforcement officials may not submit just any objection. They must submit SPECIFIC ARTICULABLE objections.

Section 1231.90 Qualification for a License

a) FCCL applicants who are Illinois residents must have a valid FOID card at the time of the application.

The FCCA does not require applicant to have a valid FOID at the time of applying for a concealed carry license. The law allows for applicant to provide affirmation that applicant is applying for a FOID in conjunction with the license application.

(

4) an affirmation that the applicant possesses a currently valid Firearm Owner's Identification Card and card number if possessed or notice the applicant is applying for a Firearm Owner's Identification Card in conjunction with the license application;

Section 1231.100 Application

Requiring all documentation for the application to be submitted electronically is not provided for in the FCCA. (see comments for 1231.60).

Section 1231.110 Non-Resident Application

The Department’s current definition of “substantially similar” is too narrow and appears designed to prevent non-residents who travel or work in Illinois from getting a carry license. Substantially similar needs to refer to a state that requires similar training and performs a background check as part of their licensing process.

The requirement for states to report voluntary mental health admissions is an excessive requirement and should be omitted from the definition. Records throughout the country show that concealed carry licensees are the smallest segment of the population to have any type of prohibitive mental or criminal problems which would make them an at-risk licensee.

Non-resident applicants must be allowed to submit ink and roll fingerprints – IDPR does this. Live Scan prints cannot be used across state lines.

Section 1231.130 Change Requests

Need to also provide a non-electronic form of change request.

 

Section 1231.140 Fees

Other means besides online payment must be made available. Many applicants will not have ready access to E-Pay.

Section 1231.150 Prohibited Places

The Department omitted the need to list in the rules that No Carry signs need to be posted at each entrance to a prohibited area.

Additional items currently listed on the Department’s website that need clarification:

1. Exemption from training requirement – applicants who have taken the 40-hour law enforcement or armed security training, current, former, and retired corrections officers and retired or former law enforcement officers/officials.

2. Why can attorneys and LEO not teach use of force. Presently they are excluded because they are not “approved instructors” and do not have ISP issued instructor numbers.

[pgsailor]

If any of these comments are accepted as rules, how long would it take for them to go into effect? Great list BTW!

[fubarud]

Can we get some clarification as to when the 90 / 120 day clock starts for the ISP to issue a permit?

 

If I use USPS with delivery confirmation, the delivery date "should" be when their clock starts, not when they get around to opening the envelope & cashing the check.

[Klaxongreg]

Awesome list, Molly. Thank You.

[bob]

Can we get some clarification as to when the 90 / 120 day clock starts for the ISP to issue a permit?

 

If I use USPS with delivery confirmation, the delivery date "should" be when their clock starts, not when they get around to opening the envelope & cashing the check.

 

will it matter any as a practical matter?

 

I think the law says the clock starts when they receive the application.

 

But what happens if they issue it in 128 days instead of 120? Or for that matter 158 days? By the time you can get a court to look at it, you will have license in hand, or you will have to go to the review board because it has been denied.

 

Or the Chicago PD decides to object to every permit issued to Chicagoans and they get bogged down in the review process by the review board that does not exist yet. I am not saying this is likely since this would be clear abuse of the system and the courts would take a dim view of it, but there is nothing in the law that prevents them from doing so. For that matter a LE agency could potentially object to every permit application. Again, likely to be viewed very unfavorably by the courts.

 

The bottom line is there are plenty of places "they" can mess with you if they want to. So far "they" have shown a willingness to follow what the law actually says. I see that as a good sign. There are a few things around the edges that can still be tweaked at the JCAR level, but I just do not see any substantive changes to the law itself so we might as well just get used to the idea of it being what it is.

 

I think the 90 day issuance period is insane, but it is not that unusual. Even states like TX and FL get 90 days, IIRC.

 

Right now they routinely exceed the 30 day statutorily required schedule on issuance of FOID cards. It appears either nothing can be done about it or at least nothing is being done about it at least.

[hgmeyer]

I appreciate the comments but would ask that one matter be reviewed and maybe changed. Some former LEOs did not have a 40 hour course.... My PTI certification was prior to the 40hr course (yeah I knoiw that makes me older than dirt) and was for 25+ hours. (dated 10/72). Thanks for considering this matter. I know I am not alone in my "vintage", so there are many others here who do have the same issue.

[Tango7]

I appreciate the comments but would ask that one matter be reviewed and maybe changed. Some former LEOs did not have a 40 hour course.... My PTI certification was prior to the 40hr course (yeah I knoiw that makes me older than dirt) and was for 25+ hours. (dated 10/72). Thanks for considering this matter. I know I am not alone in my "vintage", so there are many others here who do have the same issue.

 

My proposal for the Legislative Route can be found in the Attn: Former LEO, retired, etc. thread

 

 

Through the JCAR? Strikethrough is to be deleted, bold and underlined is newly proposed:

 

Section 1231.10 Definitions

"Law Enforcement Officer" in Section 75 (h) of the Act shall include all the definitions of "Peace Officer" contained within 50 ILCS 705, the Illinois Police Training Act, 725 ILCS 5/107-4 (a)(2), the Code of Criminal Procedure of 1963 as well as 20 ILCS 2910, the Peace Officer Fire Investigation Act.

 

 

Then later:

 

Section 1231.40 Curriculum Approval

d) Training necessary for issuance of the FCCL shall consist of 16 hours of

classroom and firearm training. Pursuant to Section 75(g), (h) and (i) of the Act,

fewer hours of training, or no additional training, will be acceptable in certain

instances indicating prior firearms training.

1) A 16 hour training course...

2) An 8 hour training course...

3) For the topics to be included in the 16 hour and 8 hour training courses...

4) Training requirements for Section 75 (h) of the Act will be deemed to have been met upon the submission of:

 

i. A certificate attesting to the satisfactory completion of a course that meets the requirements of 50 ILCS 710, the Peace Officer Firearm Training Act (or its precursors) for employment as a Peace Officer or Corrections Officer within the state of Illinois; or

 

ii. A certificate attesting to the satisfactory completion of a course taken to obtain a firearm control card (or its precursors) by the Department of Financial and Professional Regulation; or

 

iii. A copy of the applicant's Identification Card issued by the Illinois Retired Officer Concealed Carry (IROCC) program.

[fubarud]

Can we get some clarification as to when the 90 / 120 day clock starts for the ISP to issue a permit?

 

If I use USPS with delivery confirmation, the delivery date "should" be when their clock starts, not when they get around to opening the envelope & cashing the check.

 

will it matter any as a practical matter?

 

I think the law says the clock starts when they receive the application.

 

But what happens if they issue it in 128 days instead of 120? Or for that matter 158 days? By the time you can get a court to look at it, you will have license in hand, or you will have to go to the review board because it has been denied.

 

Or the Chicago PD decides to object to every permit issued to Chicagoans and they get bogged down in the review process by the review board that does not exist yet. I am not saying this is likely since this would be clear abuse of the system and the courts would take a dim view of it, but there is nothing in the law that prevents them from doing so. For that matter a LE agency could potentially object to every permit application. Again, likely to be viewed very unfavorably by the courts.

 

The bottom line is there are plenty of places "they" can mess with you if they want to. So far "they" have shown a willingness to follow what the law actually says. I see that as a good sign. There are a few things around the edges that can still be tweaked at the JCAR level, but I just do not see any substantive changes to the law itself so we might as well just get used to the idea of it being what it is.

 

I think the 90 day issuance period is insane, but it is not that unusual. Even states like TX and FL get 90 days, IIRC.

 

Right now they routinely exceed the 30 day statutorily required schedule on issuance of FOID cards. It appears either nothing can be done about it or at least nothing is being done about it at least.

 

On a single case basis, it won't do much. You could call your represenative and put a fire under them, just like with FOID.

 

I'm not sure why nothing is being done about the FOID violations. Something needs to be done.

[bob]

I appreciate the comments but would ask that one matter be reviewed and maybe changed. Some former LEOs did not have a 40 hour course.... My PTI certification was prior to the 40hr course (yeah I knoiw that makes me older than dirt) and was for 25+ hours. (dated 10/72). Thanks for considering this matter. I know I am not alone in my "vintage", so there are many others here who do have the same issue.

 

My proposal for the Legislative Route can be found in the Attn: Former LEO, retired, etc. thread

 

 

Through the JCAR? Strikethrough is to be deleted, bold and underlined is newly proposed:

 

Section 1231.10 Definitions

"Law Enforcement Officer" in Section 75 (h) of the Act shall include all the definitions of "Peace Officer" contained within 50 ILCS 705, the Illinois Police Training Act, 725 ILCS 5/107-4 (a)(2), the Code of Criminal Procedure of 1963 as well as 20 ILCS 2910, the Peace Officer Fire Investigation Act.

 

 

Then later:

 

Section 1231.40 Curriculum Approval

d) Training necessary for issuance of the FCCL shall consist of 16 hours of

classroom and firearm training. Pursuant to Section 75(g), (h) and (i) of the Act,

fewer hours of training, or no additional training, will be acceptable in certain

instances indicating prior firearms training.

1) A 16 hour training course...

2) An 8 hour training course...

3) For the topics to be included in the 16 hour and 8 hour training courses...

4) Training requirements for Section 75 (h) of the Act will be deemed to have been met upon the submission of:

 

i. A certificate attesting to the satisfactory completion of a course that meets the requirements of 50 ILCS 710, the Peace Officer Firearm Training Act (or its precursors) for employment as a Peace Officer or Corrections Officer within the state of Illinois; or

 

ii. A certificate attesting to the satisfactory completion of a course taken to obtain a firearm control card (or its precursors) by the Department of Financial and Professional Regulation; or

 

iii. A copy of the applicant's Identification Card issued by the Illinois Retired Officer Concealed Carry (IROCC) program.

 

that is pretty bold to try and redefine LEO to include people who are not LEO. I can't imagine that would fly. but it is not like you have anything to lose by trying.

[GWBH]

I'm on it Molly - thanks!

[Tango7]

 

that is pretty bold to try and redefine LEO to include people who are not LEO. I can't imagine that would fly. but it is not like you have anything to lose by trying.

 

I'm just reinforcing the definition provided by the legislature in the three Statutes I mentioned... There are actually more references to 'peace officer' add a qualification in the ILCS than 'police officer' or 'law enforcement officer'. Both of those terms refer to the definition of peace officer.

[Molly B.]

p.s. I just noted a typo in the address for Ms. Freitag - letters for both ladies go to the same 801 S. 7th street address. I hope that did not mess anybody up . . . sorry!

[Phatty]

that is pretty bold to try and redefine LEO to include people who are not LEO. I can't imagine that would fly. but it is not like you have anything to lose by trying.

 

I'm just reinforcing the definition provided by the legislature in the three Statutes I mentioned... There are actually more references to 'peace officer' add a qualification in the ILCS than 'police officer' or 'law enforcement officer'. Both of those terms refer to the definition of peace officer.

I know you mean well, but you're doing a poor job of making your case. The way you have articulated your argument, it seems like you are simply asking that the ISP erase the phrase "law enforcement officer" in the FCCA and substitute "peace officer" instead. The ISP cannot rewrite the law. There are numerous instances in the Illinois statutes where "law enforcement officer" is defined. Each of those definitions is qualified as only applying to the use of that term in the particular act, not generally throughout the Illinois statutes. In the FCCA, the term "law enforcement officer" is not defined. That means that there is some room for interpretation by the ISP with respect to that term. The key to making your argument is to get the ISP to use one of the broad definitions of "law enforcement officer" found elsewhere in the Illinois statutes instead of one of the narrow definitions.

 

For example, a very narrow definition is contained in the Illinois Police Training Act, which states that a "law enforcement officer means (i) any police officer of a local governmental agency who is primarily responsible for prevention or detection of crime and the enforcement of the criminal code, traffic, or highway laws of this State or any political subdivision of this State or (ii) any member of a police force appointed and maintained as provided in Section 2 of the Railroad Police Act." We don't want that definition to be used, because it limits law enforcement officers to police officers only.

 

Instead, we would like the ISP to use the definition of "law enforcement officer" used in the A.I.D.S. Confidentiality Act (410 ILCS 305/7). That is the broadest definition contained in the Illinois statutes. Under that Act, a "law enforcement officer means any person employed by the State, a county or a municipality as a policeman, peace officer, auxiliary policeman, correctional officer or in some like position involving the enforcement of the law and protection of the public interest at the risk of that person's life."

 

So, if you are submitting a comment on the proposed rules to ISP, urge them to simply adopt the definition of "law enforcement officer" as used in 410 ILCS 305/7 with whatever argument you may have that makes sense. For instance, you can argue that each of the categories listed in that definition will have received much more than the 16 minimum hours of training required in the FCCA, so it is logical that each would be excused from any further training.

[Tango7]

Instead, we would like the ISP to use the definition of "law enforcement officer" used in the A.I.D.S. Confidentiality Act (410 ILCS 305/7). That is the broadest definition contained in the Illinois statutes. Under that Act, a "law enforcement officer means any person employed by the State, a county or a municipality as a policeman, peace officer, auxiliary policeman, correctional officer or in some like position involving the enforcement of the law and protection of the public interest at the risk of that person's life."

 

So, if you are submitting a comment on the proposed rules to ISP, urge them to simply adopt the definition of "law enforcement officer" as used in 410 ILCS 305/7 with whatever argument you may have that makes sense. For instance, you can argue that each of the categories listed in that definition will have received much more than the 16 minimum hours of training required in the FCCA, so it is logical that each would be excused from any further training.

 

Duly noted, and thanks!

[Pipedoc]

Is December 17th the earliest date by which the proposed rules may become permanent? If changes are made based upon public comment is that done by JCAR or are they kicked back to ISP for refining?

[Blade13]

Thanks Molly for directing me to this page and for the info at the townhall. Got a letter written. Don't know how i missed this post.

[Molly B.]

You are quite welcome! It was great getting to meet you!!

[bob]

that is pretty bold to try and redefine LEO to include people who are not LEO. I can't imagine that would fly. but it is not like you have anything to lose by trying.

 

I'm just reinforcing the definition provided by the legislature in the three Statutes I mentioned... There are actually more references to 'peace officer' add a qualification in the ILCS than 'police officer' or 'law enforcement officer'. Both of those terms refer to the definition of peace officer.

I know you mean well, but you're doing a poor job of making your case. The way you have articulated your argument, it seems like you are simply asking that the ISP erase the phrase "law enforcement officer" in the FCCA and substitute "peace officer" instead. The ISP cannot rewrite the law. There are numerous instances in the Illinois statutes where "law enforcement officer" is defined. Each of those definitions is qualified as only applying to the use of that term in the particular act, not generally throughout the Illinois statutes. In the FCCA, the term "law enforcement officer" is not defined. That means that there is some room for interpretation by the ISP with respect to that term. The key to making your argument is to get the ISP to use one of the broad definitions of "law enforcement officer" found elsewhere in the Illinois statutes instead of one of the narrow definitions.

 

For example, a very narrow definition is contained in the Illinois Police Training Act, which states that a "law enforcement officer means (i) any police officer of a local governmental agency who is primarily responsible for prevention or detection of crime and the enforcement of the criminal code, traffic, or highway laws of this State or any political subdivision of this State or (ii) any member of a police force appointed and maintained as provided in Section 2 of the Railroad Police Act." We don't want that definition to be used, because it limits law enforcement officers to police officers only.

 

Instead, we would like the ISP to use the definition of "law enforcement officer" used in the A.I.D.S. Confidentiality Act (410 ILCS 305/7). That is the broadest definition contained in the Illinois statutes. Under that Act, a "law enforcement officer means any person employed by the State, a county or a municipality as a policeman, peace officer, auxiliary policeman, correctional officer or in some like position involving the enforcement of the law and protection of the public interest at the risk of that person's life."

 

So, if you are submitting a comment on the proposed rules to ISP, urge them to simply adopt the definition of "law enforcement officer" as used in 410 ILCS 305/7 with whatever argument you may have that makes sense. For instance, you can argue that each of the categories listed in that definition will have received much more than the 16 minimum hours of training required in the FCCA, so it is logical that each would be excused from any further training.

 

This seems like a far better idea than trying to use administrative rules to redefine a term already found in the law.

[kevinmcc]

I appreciate the comments but would ask that one matter be reviewed and maybe changed. Some former LEOs did not have a 40 hour course.... My PTI certification was prior to the 40hr course (yeah I knoiw that makes me older than dirt) and was for 25+ hours. (dated 10/72). Thanks for considering this matter. I know I am not alone in my "vintage", so there are many others here who do have the same issue.

 

My proposal for the Legislative Route can be found in the Attn: Former LEO, retired, etc. thread

 

 

Through the JCAR? Strikethrough is to be deleted, bold and underlined is newly proposed:

 

Section 1231.10 Definitions

"Law Enforcement Officer" in Section 75 (h) of the Act shall include all the definitions of "Peace Officer" contained within 50 ILCS 705, the Illinois Police Training Act, 725 ILCS 5/107-4 (a)(2), the Code of Criminal Procedure of 1963 as well as 20 ILCS 2910, the Peace Officer Fire Investigation Act.

 

 

Then later:

 

Section 1231.40 Curriculum Approval

d) Training necessary for issuance of the FCCL shall consist of 16 hours of

classroom and firearm training. Pursuant to Section 75(g), (h) and (i) of the Act,

fewer hours of training, or no additional training, will be acceptable in certain

instances indicating prior firearms training.

1) A 16 hour training course...

2) An 8 hour training course...

3) For the topics to be included in the 16 hour and 8 hour training courses...

4) Training requirements for Section 75 (h) of the Act will be deemed to have been met upon the submission of:

 

i. A certificate attesting to the satisfactory completion of a course that meets the requirements of 50 ILCS 710, the Peace Officer Firearm Training Act (or its precursors) for employment as a Peace Officer or Corrections Officer within the state of Illinois; or

 

ii. A certificate attesting to the satisfactory completion of a course taken to obtain a firearm control card (or its precursors) by the Department of Financial and Professional Regulation; or

 

iii. A copy of the applicant's Identification Card issued by the Illinois Retired Officer Concealed Carry (IROCC) program.

 

What about out of state LEOs? Statute does not specific say training must be Illinois training for LEOs.

[kevinmcc]

I appreciate the comments but would ask that one matter be reviewed and maybe changed. Some former LEOs did not have a 40 hour course.... My PTI certification was prior to the 40hr course (yeah I knoiw that makes me older than dirt) and was for 25+ hours. (dated 10/72). Thanks for considering this matter. I know I am not alone in my "vintage", so there are many others here who do have the same issue.

 

My proposal for the Legislative Route can be found in the Attn: Former LEO, retired, etc. thread

 

 

Through the JCAR? Strikethrough is to be deleted, bold and underlined is newly proposed:

 

Section 1231.10 Definitions

"Law Enforcement Officer" in Section 75 (h) of the Act shall include all the definitions of "Peace Officer" contained within 50 ILCS 705, the Illinois Police Training Act, 725 ILCS 5/107-4 (a)(2), the Code of Criminal Procedure of 1963 as well as 20 ILCS 2910, the Peace Officer Fire Investigation Act.

 

 

Then later:

 

Section 1231.40 Curriculum Approval

d) Training necessary for issuance of the FCCL shall consist of 16 hours of

classroom and firearm training. Pursuant to Section 75(g), (h) and (i) of the Act,

fewer hours of training, or no additional training, will be acceptable in certain

instances indicating prior firearms training.

1) A 16 hour training course...

2) An 8 hour training course...

3) For the topics to be included in the 16 hour and 8 hour training courses...

4) Training requirements for Section 75 (h) of the Act will be deemed to have been met upon the submission of:

 

i. A certificate attesting to the satisfactory completion of a course that meets the requirements of 50 ILCS 710, the Peace Officer Firearm Training Act (or its precursors) for employment as a Peace Officer or Corrections Officer within the state of Illinois; or

 

ii. A certificate attesting to the satisfactory completion of a course taken to obtain a firearm control card (or its precursors) by the Department of Financial and Professional Regulation; or

 

iii. A copy of the applicant's Identification Card issued by the Illinois Retired Officer Concealed Carry (IROCC) program.

 

I actually commented on that aspect, but need to re-read my letter I sent. I am not sure I was aware they actually specified Illinois officers only, it's Monday morning...