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ATF Report on Importability of Certain Semiautomatic Rifles (1989), as mirrored on 3/4/2010

REPORT AND

RECOMMENDATION

OF THE

ATF WORKING GROUP

ON THE

IMPORTABILITY OF

CERTAIN

SEMIAUTOMATIC RIFLES

[newpage]


                   DEPARTMENT OF THE TREASURY
             BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
                     WASHINGTON, D.C. 20226
                           JUL 06 1989

MEMORANDUM TO:      Director

FROM:               Associate Director (Compliance Operations)

SUBJECT:            Report and Recommendation on the Importability
                    of Certain Semiautomatic Rifles

The working group has completed its evaluation of the semiautomatic
rifles whose importation was suspended pending a determination as
to whether these weapons are, as required by 18 U.S.C. section
925(d)(3), of a type "generally recognized as particularly suitable
for or readily adaptable to sporting purposes."

Attached for your review and approval is the report and
recommendation on the importability of these rifles.


                            [signed]
                         Daniel R. Black


Attachment


Approve: [signed] Stephen E. Higgins 7/6/89

Disapprove:

[newpage]

       REPORT AND RECOMMENDATION OF THE ATF WORKING GROUP
                 ON THE IMPORTABILITY OF CERTAIN
                      SEMIAUTOMATIC RIFLES



          SUSPENSION OF ASSAULT-TYPE RIFLE IMPORTATIONS

On March 14, 1989, ATF announced that it was suspending, effective
immediately, the importation of several makes of assault-type
rifles, pending a decision as to whether these weapons meet the
statutory test that they are of a type generally recognized as
particularly suitable for or readily adaptable to sporting
purposes.  The announcement stated that ATF would not approve,
until further notice, the importation of AKS-type weapons, Uzi
carbines, FM/FAL-type weapons, FN/FNC-type weapons and Steyr Aug
semiautomatic weapons.  On April 5, 1989, the suspension was
expanded to include all similar assault-type rifles.

For purposes of this suspension, assault-type rifles were rifles
which generally met the following criteria:

          a.    military appearance

          b.    large magazine capacity

          c.    semiautomatic version of a machinegun

Based on these criteria, ATF suspended action on pending
applications and suspended outstanding permits covering certain
firearms listed in Attachment 1. These included both centerfire and
.22 rimfire caliber firearms.  At that time, ATF indicated that the
reexamination of these weapons would take approximately 90 days.

This ATF working group was established to conduct the reevaluation
of the importability of these semiautomatic rifles.  This report
represents the findings and recommendations of the working group.

[newpage]

                              - 2 -


                           BACKGROUND

Section 925(d)(3) of Title 18, United States Code, as amended,
provides in pertinent part that:

     The Secretary shall authorize a firearm. . . to be imported or
     brought into the United States . . .    if the firearm . . .

     (3) is of a type that does not fall within the definition of
     a firearm as defined in section 5845(a) of the Internal
     Revenue Code of 1954 and is generally-recognized as
     particularly suitable for or readily adaptable to sporting
     purposes, excluding surplus military firearms . . .

This provision was originally enacted by Title IV of the Omnibus
Crime Control and Safe Streets Act of 1968, and was also contained
in Title I of the Gun Control Act of 1968, which amended Title IV
later that year.  According to the Senate Report on Title IV, this
provision was intended to "curb the flow of surplus military
weapons and other firearms being brought into the United States
which are not particularly suitable for target shooting or
hunting."  S. Rep. No. 1097, 90th Cong. 2d Sess. 80, 1968 U.S. Code
Cong. and Admin. News 2112, 2167.

Moreover, there is legislative history which indicates that
Congress intended the standard to allow the importation of
traditional sporting rifles, while excluding military-type rifles.
The Senate Report on the Gun Control Act observed that the
importation standards ". . . are designed and intended to provide
for the importation of quality made, sporting firearms, including
. . . rifles such as those manufactured and imported by Browning
and other such manufacturers and importers of firearms."  S. Rep.
No. 1501, 90th Cong. 2d Sess. 38 (1968).  Significantly, the rifles
being imported by Browning at that time were semiautomatic and
manually operated traditional sporting rifles of high quality.
[footnote 1]

An explanation of the effect of this section by one of the sponsors
of the bill specifically stated that military firearms would not
meet the "sporting purposes" test for importation.  The mere fact
that a military firearm may be used in a sporting event does not
make it importable as a sporting firearm. [footnote 2]

There is a reference in the Senate Report on Title IV which notes
that the importation prohibition ". . . would not interfere with
the bringing in of currently produced

                              - 3 -

firearms, such as rifles . . . of recognized quality which are used
for hunting and for recreational purposes, or for personal
protection."  S. Rep. No. 1097, 90th Cong. 2d Sess. 80, 1968 U.S.
Code Cong. and Admin.  News 2112, 2167.  However, this language is
not inconsistent with the expressed purpose of restricting
importation to firearms particularly suitable for target shooting
or hunting since firearms particularly suitable for those purposes
can obviously be used for other purposes such as recreational
shooting and personal protection.

The determination of a weapon's suitability for sporting purposes
"rest[s] directly with the Secretary of the Treasury." 114 Cong.
Rec. 27465 (1968) (Statement of Sen. Murphy).  While the
legislative history suggests that the term "sporting purposes"
refers to the traditional sports of target shooting, trap and skeet
shooting, and hunting, the statute itself provides no criteria
beyond the "generally recognized" language of section 925(d)(3).
S. Rep. No. 1097, 90th Cong. 2d Sess. 80, 1968 U.S. Code Cong. and
Admin.  News 2167.  The Senate Report on the Gun Control Act
stated:

     The difficulty of defining weapons characteristics to meet
     this target [of eliminating importation of weapons used in
     crime] without discriminating against sporting quality
     firearms, was a major reason why the Secretary of the Treasury
     has been given fairly broad discretion in defining and
     administering the import prohibition.

S. Rep. No. 1501, 90th Cong. 2d Sess. 38 (1968).

Following enactment of the Gun Control Act in 1968, the Secretary
established a Firearms Evaluation Panel to provide guidelines for
implementation of the "sporting purposes" test of section
925(d)(3).  This panel was composed of representatives from the
military, law enforcement, and the firearms industry.  The panel
focused its attention on handguns and recommended the adoption of
factoring criteria to evaluate the various types of handguns.
These factoring criteria are based upon such considerations as
overall length of the firearm, caliber, safety features, and frame
construction.  An evaluation sheet (ATF Form 4590) was developed
thereafter by ATF and put into use for evaluating handguns pursuant
to section 925(d)(3).  Attachment 2.

The 1968 Firearms Evaluation Panel did not propose criteria for
evaluating rifles and shotguns under section 925(d)(3).  Other than
surplus military firearms which

                              - 4 -

Congress addressed separately, long guns being imported prior to
1968 were generally conventional rifles and shotguns specifically
intended for sporting purposes.  Thus, in 1968, there was no cause
to develop criteria for evaluating the sporting purposes of rifles
and shotguns.  Until recently, all rifles and shotguns were
approved for importation so long as they were not otherwise
excluded by section 925(d)(3).  Only rifles and shotguns covered by
the National Firearms Act (NFA), 26 U.S.C. section 5845(a) (for
example, machineguns and short-barreled rifles and short-barreled
shotguns), and surplus military rifles and shotguns had been denied
importation.

The Firearms Evaluation Panel did briefly comment on whether a
model BM59 Beretta, 7.62mm NATO Caliber Sporter Version Rifle was
suitable for sporting purposes.  Minutes of the Firearms Advisory
Panel, December 10, 1968.  Attachment 3. It was the consensus of
the Panel that this rifle did have a particular use in target
shooting and hunting.  Accordingly, it was recommended that
importation of the Beretta BM59, together with the SIG-AMT 7.62mm
NATO Caliber Sporting Rifle and the Cetme 7.62mm NATO Caliber
Sporting Rifle, be authorized for importation. (The Beretta RM59
and the Cetme, the predecessor to the HK91, are two of the rifles
whose importation has been suspended.  The SIG-AMT is no longer
being produced.) However, the Panel recommended that importation of
these weapons should include the restriction that they not possess
combination flash suppressors/grenade launchers.

The working group found the Panel's consideration of these rifles
to be superficial and unpersuasive.  The vast majority of the work
of the 1968 Panel was devoted to handguns and the establishment of
the factoring criteria for the importation of handguns.  Indeed, we
found compelling evidence that these rifles are not generally
recognized as particularly suitable for sporting purposes.

The first time that ATF looked beyond the restrictions on NFA and
surplus military rifles and shotguns and undertook a meaningful
analysis under the "sporting purposes" test was in 1984.  At that
time, ATF was faced with a new breed of imported shotgun.  It was
clear that the historical assumption that all shotguns were
sporting was no longer viable.  Specifically, ATF was asked to
determine whether the Striker-12 shotgun was suitable for sporting
purposes.  This shotgun is a military/law enforcement weapon
initially designed and manufactured in South Africa for riot
control.  When the importer was asked to provide evidence of
sporting purposes for the weapon, ATF was provided information that
the weapon was suitable for police/combat style competitions.  ATF
determined that this type of competition did not constitute
"sporting purposes" under

                              - 5 -

the statute, and that this shotgun was not suitable for traditional
sporting purposes, such as hunting, and trap and skeet shooting.
Accordingly, importation was denied.  Attachment 4.

Thereafter, in 1986, the Gilbert Equipment Company requested that
the USAS-12 shotgun be classified as a sporting firearm under
section 925(d)(3).  After examination and testing of the weapon,
ATF found that it was a semiautomatic version of a selective fire
military-type assault shotgun.  In this case, ATF determined that,
due to its weight, size, bulk, designed magazine capacity,
configuration, and other factors, the USAS-12 was not particularly
suitable for or readily adaptable to sporting purposes.  Again, ATF
refused to recognize police/combat competitions as a sporting
purpose under section 925(d)(3).  The shotgun was reviewed on the
basis of its suitability for traditional shotgun sports of hunting,
and trap and skeet shooting and its importation was denied.
Attachment 5. This decision was upheld by the United States
District Court in Gilbert Equipment Company, Inc. v. Higgins, 709
F. Supp. 1071 (S.D. Ala. 1989).  The case is currently on appeal to
the Eleventh Circuit.

These two cases involving shotguns represent ATF's first thorough
examination of the suitability of certain combat-type weapons for
sporting purposes.  In these cases ATF adopted an interpretation of
sporting as being limited to certain traditional sports and not
simply any lawful activity in which the weapons might be employed.

                            ANALYSIS

A. Defining the type of weapon under review.

As noted above, section 925(d)(3) expressly provides that the
Secretary shall authorize the importation of a firearm that is of
a type that is generally recognized as particularly suitable for
sporting purposes.  The legislative history also makes it clear
that the Secretary shall scrutinize types of firearms in exercising
his authority under section 925(d).  Specifically, in its
explanation of section 925(d)(3), the Senate Report on the Gun
Control Act stated:

     This subsection gives the Secretary authority to permit the
     importation of ammunition and certain types of firearms--(1)
     those imported for scientific or research purposes or for use
     in competition or training under chapter 401 of title 10 of
     the United States Code; (2) an unserviceable firearm other
     than a machinegun; (3) those firearms not coming within the
     purview of the National Firearms Act (26 U.S.C. 5801, et

                              - 6 -

     seq.) and suitable for sporting purposes (in the case of
     surplus military weapons this type is limited to shotguns and
     rifles) and those taken out of the United States. (Emphasis
     added.)

S. Rep. No. 1501, 90th Cong. 2d Sess. 38 (1968).

In light of the statutory mandate that types of firearms be
scrutinized, the working group first attempted to determine whether
the semiautomatic rifles suspended from importation fall within a
type of firearm.

The working group determined that the semiautomatic rifles in
question are generally semiautomatic versions of true selective
fire military assault rifles. [footnote 3] As a class or type of
firearm they are often referred to as "assault rifles," "assault-
type rifles," "military style rifles," or "paramilitary rifles."
[footnote 4] Since we are only concerned with semiautomatic rifles,
it is somewhat of a misnomer to refer to these weapons as 'assault
rifles." True assault rifles are selective fire weapons that will
fire in a fully automatic mode. [footnote 5] For the purposes of
this paper, it was necessary to settle on one term that best
describes the weapons under consideration, and we will refer to
these weapons as "semiautomatic assault rifles."  They represent a
distinctive type of rifle distinguished by certain general
characteristics which are common to the modern military assault
rifle, The modern military assault rifle, such as the U.S. M16,
German G3, Belgian FN/FAL, and Soviet AK47, is a weapon designed
for killing or disabling the enemy and, as described below, has
characteristics designed to accomplish this purpose.

We found that the modern military assault rifle contains a variety
of physical features and characteristics designed for military
applications which distinguishes it from traditional sporting
rifles. [footnote 6] These military features and characteristics
(other than selective fire) are carried over to the semiautomatic
versions of the original military rifle.  These features and
characteristics are as follows:

     1.   Military Configuration.

a.   Ability to accept a detachable magazine. virtually all modern
military firearms are designed to accept large, detachable
magazines. [footnote 7] This provides the soldier with a fairly
large ammunition supply and the ability to rapidly reload.  Thus,
large capacity magazines are indicative of military firearms.
While detachable magazines are not limited to military firearms,
most traditional semiautomatic sporting firearms, designed to
accommodate a detachable magazine, have a relatively small magazine
capacity.  In addition, some States have a limit an the magazine

                              - 7 -

capacity allowed for hunting, usually 8 rounds or less. [footnote
8] That a firearm is designed and sold with a large capacity
magazine, e.g., 20-30 rounds, is a factor to be considered in
determining whether a firearm is a semiautomatic assault rifle.

b. Folding/telescoping stocks.  Many military firearms incorporate
folding or telescoping stocks. [footnote 9] The main advantage of
this item is portability, especially for airborne troops.  These
stocks allow the firearm to be fired from the folded position, yet
it cannot be fired nearly as accurately as with an open stock.
With respect to possible sporting uses of this feature, the folding
stock makes it easier to carry the firearm when hiking or
backpacking.  However, its predominant advantage is for military
purposes, and it is normally not found on the traditional sporting
rifle.

c. Pistol grips.  The vast majority of military firearms employ a
well-defined pistol grip that protrudes conspicuously beneath the
action of the weapon. [footnote 10] In most cases, the "straight
line design" of the military weapon dictates a grip of this type so
that the shooter can hold and fire the weapon.  Further, a pistol
grip can be an aid in one-handed firing of the weapon in a combat
situation.  Further, such grips were designed to assist in
controlling machineguns during automatic fire.  On the other hand,
the vast majority of sporting firearms employ a more traditional
pistol grip built into the wrist of the stock of the-firearm since
one-handed shooting is not usually employed in hunting or
competitive target competitions.

d. Ability to accept a bayonet.  A bayonet has distinct military
purposes. [footnote 11] First, it has a psychological affect on the
enemy.  Second, it enables soldiers to fight in close quarters with
a knife attached to their rifles.  We know of no traditional
sporting application for a bayonet.

e. Flash suppressor.  A flash suppressor generally serves one or
two functions.  First, in military firearms it disperses the muzzle
flash when the firearm is fired to help conceal the shooter's
position, especially at night.  A second purpose of 'some flash
suppressors is to assist in controlling the "muzzle climb" of the
rifle, particularly when fired fully automatic. [footnote 12] From
the standpoint of a traditional sporting firearm, there is no
particular benefit in suppressing muzzle flash.  Those flash
suppressors which also serve to dampen "muzzle climb" have a
limited benefit in sporting uses by allowing the shooter to
reacquire the target for a second shot.

                              - 8 -

However, the barrel of a sporting rifle can be modified by "magna-
porting" to achieve the same result.  There are also muzzle
attachments for sporting firearms to assist in the reduction of
muzzle climb.  In the case of military-style weapons that have
flash suppressors incorporated in their design, the mere removal of
the flash suppressor may have an adverse impact on the accuracy of
the firearm.

f. Bipods. The majority of military firearms have bipods as an
integral part of the firearm or contain specific mounting points to
which bipods may be attached. [footnote 13] The military utility of
the bipod is primarily to provide stability and support for the
weapon when fired from the prone position, especially when fired
fully automatic.  Bipods are available accessory items for sporting
rifles and are used primarily in long-range shooting to enhance
stability.  However, traditional sporting rifles do not come
equipped with bipods, nor are they specifically designed to
accommodate them.  Instead, bipods for sporting firearms are
generally designed to attach to a detachable 'sling swivel mount"
or simply clamp onto the firearm.

g. Grenade launcher.  Grenade launchers are incorporated in the
majority of military firearms as a device to facilitate the
launching of explosive grenades. [footnote 14] Such launchers are
generally of two types.  The first type is a flash suppressor
designed to function as a grenade launcher.  The second type
attaches to the barrel of the rifle either by screws or clamps. we
are not aware of any particular sporting use for grenade launchers.

h. Night Sights.  Many military firearms are equipped with luminous
sights to facilitate sight alignment and target acquisition in poor
light or darkness. [footnote 15] Their uses are generally for
military and law enforcement purposes and are not usually found on
sporting firearms since it is generally illegal to hunt at night.

     2. Whether the weapon is a semiautomatic version of a
machinegun.

The vast majority of modern military firearms are selective fire,
i.e., they can shoot either fully automatic or semiautomatic.
Since machineguns are prohibited from importation (except for law
enforcement use) the manufacturers of such weapons have developed
semiautomatic versions of these firearms. [footnote 16]

                              - 9 -

     3. Whether the rifle is chambered to accept a centerfire
cartridge case having a length of 2.25 inches or less.

Modern military assault rifles and submachineguns are generally
chambered to accept a centerfire cartridge case of 2.25 inches or
less. [footnote 17] On the other hand, while many traditional
sporting rifles will fire a cartridge of 2.25 inches or less, such
firearms usually do not have the other military features outlined
in Items 1a-h.

These features and characteristics are not usually found on
traditional sporting firearms. [footnote 18] This is not to say
that a particular rifle having one or more of the listed features
should necessarily be classified as a semiautomatic assault rifle.
Indeed, many traditional sporting firearms are semiautomatic or
have detachable magazines.  Thus, the criteria must be viewed in
total to determine whether the overall configuration places the
rifle fairly within the semiautomatic assault rifle category.

Using these criteria, we determined that, on balance, all of the
firearms on the original suspension list are properly included in
the semiautomatic assault rifle category, with the exception of the
.22 rimfire caliber rifles and the Valmet Hunter.  While the .22
rimfire caliber rifles bear a striking resemblance to the true
assault rifle, these rifles employ, by and large, conventional .22
rimfire caliber semiautomatic mechanisms. [footnote 19] Moreover,
they are not semiautomatic versions of a machinegun and contain
only a few of the other relevant characteristics.  Further, the
working group determined that, in general, .22 caliber rifles are
generally recognized as suitable for small game hunting.  The
Valmet Hunter, while based on the operating mechanism of the AK47
assault rifle, has been substantially changed so that it is now
akin to a traditional sporting rifle and does not properly fall
within the semiautomatic assault rifle category.  More
specifically, its receiver has been modified and its pistol grips,
bayonet, and flash suppressor have been removed.  The trigger
mechanism has been moved to the rear of the modified receiver to
facilitate its use with a traditional sporting stock.  Also, its
military-style sights have been replaced with traditional sporting-
style sights.  See Attachment 6.

B. Scope of "Sporting Purposes."

The second step of our process was to determine the scope of
"sporting purposes" as used in the statute.  This is a critical
aspect of the process.  The broadest interpretation could take in
virtually any lawful activity or

                             - 10 -

competition which any person or groups of persons might undertake.
Under this interpretation, any rifle could meet the "sporting
purposes test.  A narrower interpretation which focuses on the
traditional sports of hunting and organized marksmanship
competition would result in a more selective importation process.
[footnote 20]

To determine the proper interpretation, we consulted the statute
itself, its legislative history, applicable case law, the work of
the original Firearms Evaluation Panel, and prior interpretations
by ATF.  In terms of the statute itself, the structure of the
importation provisions would suggest a somewhat narrow
interpretation.  In this regard, firearms are prohibited from
importation (section 922(j)) with certain specific exceptions
(section 925(d)(3)).  A broad interpretation which permits
virtually any firearm to be imported because someone may wish to
use it in some lawful shooting activity would render the statute
meaningless.

As discussed earlier, the legislative history suggests a narrow
meaning and indicates that the term "sporting purposes" refers to
the traditional sports of target shooting, skeet and trap shooting,
and hunting.  Moreover, the history discussed earlier strongly
suggests that Congress intended the provision to allow the
importation of traditional sporting type rifles while excluding
military type rifles.  There is nothing in its history to indicate
that it was intended to recognize every conceivable type of
activity or competition which might employ a firearm.  To the
contrary, the history indicates that mere use in some competition
would not make the rifle a sporting rifle.

Finally, the 1968 Firearms Evaluation Panel specifically addressed
at least one informal shooting activity and determined that it was
not a legitimate sporting purpose under the statute.  The panel
addressed what is commonly referred to as "plinking" (shooting at
randomly selected targets such as bottles and cans).  It was the
Panel's view that "while many persons participated in this type of
activity and much ammunition was expended in such endeavors, it was
primarily a pastime and could not be considered a sport for the
purposes of importation. . . "  See Attachment 3.

Based on the above, the working group determined that the term
"sporting purpose" should properly be given a narrow reading.  It
was determined that while hunting has been a recognized rifle sport
for centuries, and competitive target shooting is a recognized
rifle sport, the so-called activity of plinking is not a recognized
sport.  Moreover, we believe that reference to sporting purposes
was intended also to stand in contrast to military and law
enforcement applications.  Consequently, the working group does not

                             - 11 -

believe that police/combat-type competitions should be treated as
sporting activities.  This position is supported by the court's
decision in Gilbert Equipment Company, Inc., v. Higgins, 709 F.
Supp. 1071 (S.D. Ala. 1989) and is consistent with prior
interpretations of ATF as noted on pages 4 and 5 in discussing the
Striker-12 shotgun and USAS-12 shotgun.

C. Suitability.

The final step in our review involved an evaluation of whether
semiautomatic assault rifles are a type of rifle generally
recognized as particularly suitable for or readily adaptable to the
traditional sporting applications discussed above.

The criminal misuse of semiautomatic assault rifles is a matter of
significant public concern and was an important factor in the
decision to suspend their importation.  Nevertheless, the working
group did not consider criminal misuse as a factor in its analysis
of the importability of this type of rifle.  Instead, the working
group confined its analysis to the question of whether this type of
rifle meets the test provided in section 925(d)(3).

Rather than criminal misuse, our comprehensive examination of this
issue focused on the legal analysis and technical assessment of
these firearms discussed earlier.  In addition, the working group
used the information gathered under Items 1-7 outlined in the next
section in determining whether this type of firearm is generally
recognized as particularly suitable for sporting purposes.  These
items take into account technical and marketing data, expert
opinions, the recommended uses of the firearms, and data on the
actual uses for which the weapons are employed in this country.

In evaluating these firearms, we believe that all rifles which are
fairly typed as semiautomatic assault rifles should be treated the
same.  Therefore, the fact that there may be some evidence that a
particular rifle of this type is used or recommended for sporting
purposes should not control its importability. [footnote 21]
Rather, all findings as to suitability of these rifles as a whole
should govern each rifle within this type.

This is consistent with the approach taken with respect to handguns
since 1968.  Although certain handguns may be used or recommended
for sporting purposes, they may fall within the type of easily
concealable handguns barred from importation by the administrative
factoring criteria used

                             - 12 -

by ATF to determine the importability of handguns.  Furthermore, a
pistol specifically designed for target shooting, but lacking a
safety as required by the factoring criteria, would be a type of
handgun prohibited from importation as not particularly suitable
for sporting purposes for this reason.  Finally, just as ATF allows
handguns to be modified so as to meet the factoring criteria, a
semiautomatic assault rifle could be modified into a sporting
configuration and be importable, as was done in the case of the
Valmet Hunter referred to earlier.

D. Evaluation of Information from Outside Sources

As part of our comprehensive analysis as to whether semiautomatic
assault rifles meet the statutory criteria for importation, the
following sources of information were also considered:

     1.   How has the weapon been advertised, marketed and
     categorized by the manufacturer and/or importer?

     2.   How has the use of the rifle been described by firearms
     technical writers?

     3.   What is the rifle's reported use by importers?

     4.   Do hunting guides recommend the rifle?

     5.   Do editors of hunting magazines recommend the rifle?

     6.   Is the rifle used in target shooting competitions?

     7.   Do State game commissions allow the use of the rifle to
     hunt?

Items 1-6 focus upon how the rifles are marketed, advertised, and
recommended for use.  Item 7 addresses the legal restrictions
pertaining to the use of the weapons for sporting purposes.

The working group reviewed the advertising and marketing literature
concerning each of the weapons (Item 1) and reviewed evaluations of
the firearms by technical writers (Item 2).  In addition, the
working group solicited information from the importers of the
weapons and other knowledgeable sources (Items 3-6).

Questionnaires were drafted and sent out to licensed hunting
guides, State game and fish commissions, local hunting
associations, competitive shooting groups, and hunting/shooting
magazine editors to determine the extent to which the weapons are
used for sporting purposes or recommended for such use.  The
working group believed that the actual uses of the weapons for
sporting purposes

                             - 13 -

would be a factor to be considered in determining whether this type
of rifle meets the sporting purposes test.

The review of advertising and marketing literature indicates that
these rifles are not generally marketed for hunting or competitive
shooting.  The review of the technical evaluations revealed that
these rifles are not regarded as suitable for these sporting
activities. [footnote 22]

To the extent that the technical evaluations made recommendations
with respect to the use of the rifles suspended from importation,
the majority recommended them for law enforcement or military use
or for activities such as collecting, plinking, home and self-
defense, and combat target shooting.  Only 5 of over 50 evaluations
reviewed contained recommendations for the use of these firearms
for hunting purposes.

The importers were asked to submit information concerning the
sporting uses of the semiautomatic rifles they import.  Thirty-nine
importers were asked to submit this information and 19 responded.
In general, their comments were conclusory and stated that their
weapons could be used for sporting purposes.  A small number of
importers, e.g., Gun South, Inc., and Heckler & Koch, Inc.,
provided more specific data showing the sporting uses made of their
firearms by their customers.

Of 3 hunting associations to whom questionnaires were sent, 2
responded.  They stated that they place no restrictions on the use
of semiautomatic rifles by their members, on the minimum caliber of
ammunition used to hunt large game, or on the number of rounds
allowed in semiautomatic rifle magazines.  However, over 1,800
hunting guides were sent questionnaires and, of these, 706
responded.  Over 73 percent of those responding indicated that
their patrons used either bolt or lever action rifles for hunting.
Only 10 of the 706 guides indicated that their patrons had used any
of the rifles whose importation had been temporarily suspended.

Of the 20 hunting/shooting editors to whom questionnaires were
sent, 14 responded.   Nine of the fourteen editors recommended
semiautomatic rifles for use in hunting large game, including 5 who
recommended use of any of the rifles subject to the temporary
suspension.  Eleven of the fourteen editors recommended
semiautomatic rifles for target competitions, including 7 who
recommended semiautomatic assault rifles for such use.

The recommendations of editors were contradictory.  One editor
pointed out that what made the assault rifle successful as a
military weapon made the semiautomatic

                             - 14 -

version totally unfit for any other use.  On the other hand,
another editor stated that semiautomatic rifles had certain
advantages over conventional sporting rifles especially for the
physically disabled and left-handed shooters.  While this may be
true, there appears to be no advantage to using a semiautomatic
assault rifle as opposed to a semiautomatic sporting rifle.

A total of 54 competitive shooting groups were sent a questionnaire
and 53 groups responded (some of the responses were from
unsolicited groups).  Fifty of these groups indicated that they
sponsor high power rifle competition events.  While none of the
groups prohibited the use of the semiautomatic assault rifles in
their competitions, none stated that any of the rifles covered by
the temporary suspension were used in a specific event.

Finally, the information gathered under Item 7 reveals that most of
these weapons could legally be used in most States for most hunting
purposes.

The working group reviewed all of the information gathered under
Items 1-6 and determined that while these weapons may legally be
used for sporting purposes in most States, the evidence was
compelling that, as a type of firearm, the semiautomatic assault
rifle is not generally recognized as particularly suitable for
sporting purposes.  The working group found persuasive the
technical and expert evaluations of these firearms which generally
did not recommend them as particularly suitable for sporting
purposes.  The group was also impressed by the comments of the
hunting guides which showed that these rifles were not widely used
for hunting purposes.  The comments of the hunting guides are
consistent with the opinion of the technical experts who generally
do not recommend the rifles for hunting purposes.

The opinions of the editors were fairly divided with respect to the
sporting uses of these rifles.  The importers generally recommended
their own weapons for such uses.  The competitive shooting groups
indicated that the rifles could be used in certain shooting events.
Thus while there was some evidence that these rifles could be used
for hunting and target shooting, there was no evidence of any
widespread use for such purposes.  The mere fact that they are not
generally prohibited from use for sporting purposes does not mean
that the rifles meet the test for importation.

                             - 15 -

                           CONCLUSION

The working group has dealt with a complex issue, the resolution of
which has required the group to take into account interpretations
of law, technical assessments of firearms and their physical
characteristics, marketing data, the assessment of data compiled
from responses to questionnaires and, finally, Bureau expertise
with respect to firearms. we fully recognize that particular
findings as well as the results will be controversial.

From the cross section of representation within ATF, we have
brought to bear our technical, legal, and administrative expertise
to resolve the issues in what we believe to be a fair manner,
taking into consideration all points of view.  While some of the
issues were difficult to resolve, in the end we believe that the
ultimate conclusion is clear and compelling.  These semiautomatic
assault rifles were designed and intended to be particularly
suitable for combat rather than sporting applications.  While these
weapons can be used, and indeed may be used by some, for hunting
and target shooting, we believe it is clear that they are not
generally recognized as particularly suitable for these purposes.

The purpose of section 925(d)(3) was to make a limited exception to
the general prohibition on the importation of firearms, to preserve
the sportsman's right to sporting firearms.  This decision will in
no way preclude the importation of true sporting firearms. It will
only prevent the importation of military-style firearms which,
although popular among some gun owners for collection, self-
defense, combat competitions, or plinking, simply cannot be fairly
characterized as sporting rifles.

Therefore, it is the finding of the working group that the
semiautomatic assault rifle is not a type of firearm generally
recognized as particularly suitable for or readily adaptable to
sporting purposes and that importation of these rifles should not
be authorized under 18 U.S.C. section 925(d)(3).

Based on our evaluation, we recommend that the firearms listed on
Attachment 7 not be authorized for importation.  For the reasons
discussed in this report, we recommend that the firearms listed on
Attachment 8 be authorized for importation.  These are the .22
rimfire caliber rifles and the Valmet Hunter which we do not
believe are properly included in the category of semiautomatic
assault rifles.  Attachment 9 is a compilation of the responses
from the questionnaires.  Attachment 10 combines the criteria for

                             - 16 -

identifying semiautomatic assault rifles and the items considered
in assessing suitability.  Attachments 11 and 12 contain the data
compiled for each of the criteria listed in Attachment 10.
Finally, Attachment 13 contains the source materials used in
locating persons and organizations who were sent questionnaires.

[newpage]
                              NOTES

1. Paul Wahl, ed., Gun Trader's Guide, 13th Edition, (South
Hackensack, NJ. 1987), 155-162.

2. Although a firearm might be recognized as "suitable" for use in
traditional sports, it would not meet the statutory criteria unless
it were recognized as particularly suitable for such use.  Indeed,
Senator Dodd made clear that the intent of the legislation was to
"[regulate] the importation of firearms by excluding surplus
military handguns; and rifles and shotguns that are not truly
suitable for sporting purposes." 114 Cong. Rec. 13325 (1968)
(Statement of Sen. Dodd) [emphasis added].

Similarly, it is apparent that the drafters of the legislation did
not intend for "sports" to include every conceivable type of
activity or competition which might employ a firearm; otherwise a
"sporting purpose" could be advanced for every firearm sought to be
imported.  For example, in response to Sen. Hansen's question
concerning the meaning of "sporting purposes" in the bill which
became section 925(d), Senators Dodd and Hansen engaged in the
following colloquy:

     Mr. HANSEN.  Would the Olympic shooting competition be a
     "sporting purpose?"

     Mr. DODD.  I would think so.

     Mr. HANSEN.  What about trap and skeet shooting?

     Mr. DODD.  I would think so.  I would think trap and skeet
     shooting would certainly be a sporting activity.

     Mr. HANSEN.  Would the Camp Perry national matches be
     considered a "sporting purpose?"

     Mr. DODD.  Yes; that would not [sic] fall in that arena.  It
     should be described as a sporting purpose.

     Mr. HANSEN.  I understand the only difference is in the type
     of firearms used at Camp Perry which includes a wide variety
     of military types as well as commercial.  Would all of these
     firearms be classified as weapons constituting a "sporting
     purpose?"

                               -2-

     Mr. DODD.  No. I would not say so.  I think when we get into
     that, we definitely get into military type of weapon for use
     in matches like these at Camp Perry; but I do not think it is
     generally described as a sporting weapon.  It is a military
     weapon.  I assume they have certain types of competition in
     which they use these military weapons as they would in an
     otherwise completely sporting event.  I do not think that fact
     would change the nature of the weapon from a military to a
     sporting one.

     Mr. HANSEN.  Is it not true that military weapons are used in
     Olympic competition also?

     Mr. DODD.  I do not know.  Perhaps the Senator can tell me.
     I am not well informed on that.

     Mr. HANSEN.  It is my understanding that they are.  Would the
     Senator be inclined to modify his response if I say that is
     true? (27461)

     Mr. DODD.  It is not that I doubt the Senator's word.  Here
     again I would have to say that if a military weapon is used in
     a special sporting event, it does not become a sporting
     weapon.  It is a military weapon used in a special sporting
     event.  I think the Senator would agree with that.  I do not
     know how else we could describe it. . . .

     Mr. HANSEN.  If I understand the Senator correctly, he said
     that despite the fact that a military weapon may be used in a
     sporting event, it did not, by that action become a sporting
     rifle. is that correct?

     Mr. DODD.  That would seem right to me . . . As I said
     previously the language says no firearms will be admitted into
     this country unless they are genuine sporting weapons . . . I
     think the Senator and I know what a genuine sporting gun is.

114 Cong. Rec. 27461-62 (1968).  (Emphasis  added.)

                              - 3 -

3. Ken Warner, ed., Gun Digest 1989, (Northbrook, Il. 1988), pp.
293-300; William S. Jarrett, ed., Shooter's Bible, (Hackensack, NJ.
1988), pp. 345-363; Edward Clinton Ezell, Small Arms of the World,
(Harrisburg, Pa. 1983), p. 844; Pete Dickey, "The Military Look-
Alikes," American Rifleman, (April 1980), p. 31.  Also, see
generally, Ian V. Hogg, ed., Jane's Infantry Weapons, 1987-88, (New
York 1987); Jack Lewis, ed., The-Gun Digest Book of Assault
Weapons, (Northbrook, Il. 1986).

4. Art Blatt, "Tomorrow's State-of-the-Art Sporting Rifle," Guns &
Ammo, (July 1981), P. 48; Jarrett, pp. 345-363; Warner, pp. 293-
300.

5. Daniel D. Musgrave and Thomas B. Nelson, The World's Assault
Rifles, (Virginia, 1967), P. 1.

6. See generally, Angus Laidlaw, ed., Paul Wahl's Big Gun
Catalog/1, (Bogota, NJ. 1988); Musgrave and Nelson; Hogg; Jarrett;
and Warner.

7. Ibid.

8. Arizona, 5 rounds; Colorado, 6 rounds; Michigan 6 rounds; New
Hampshire, 5 rounds; New York, 6 rounds; North Carolina, 6 rounds;
North Dakota, 8 rounds; Oregon, 5 rounds; Pennsylvania,
semiautomatic rifles prohibited; Vermont, 6 rounds.

9. See generally, Hogg; Musgave and Nelson; Ezell; Warner; Jarrett;
Laidlaw; and Lewis.

10. Ibid.

11. Ibid.

12. Ibid.

13. Ibid.

14. Ibid.

15. Ibid.

16. Ezell, P. 844; Dickey, p. 31.

17. Musgrave and Nelson, pp. 11-29; and, see generally, Hogg; and
Ezell.

                              - 4 -

18.  Ezell, pp.844-866; and, see generally, Warner; Jarrett;
and-Laidlaw.

19. See, for example, Walter Rickell, "The Plinker's AK," Guns
Magazine, (July 1986) p. 21; John Lachuk, "Bantam Battle Rifles,"
Guns & Ammo, (January 1987), p. 37; John Lachuk, ".22 Erma
Carbine," Guns & Ammo, (May 1968), p. 58; Jack Lewis, "Something
New: The AX in Twenty-Two," Gun World, (July 1985), p. 32; Roger
Combs, "A Most Unique Carbine," Gun World, (December 1985), p. 28;
Garry James, "Mitchell Arms AK-22," Guns & Ammo, (November 1985),
p. 72.

20. See note 2, colloquy between Senators Dodd and Hansen.

21. Ibid.

22. See generally, bibliography.

[newpage]

                          BIBLIOGRAPHY


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65-66.

     Beretta AR. 70 Rifle," American Rifleman, (March 1988), 64-66.

     Blatt, Art. "Beretta M-70/Sport Rifle," Guns (December 1983),
64-65.

     Blatt, Art.  "Tomorrow's Sporting Rifles," Guns & Ammo, (July
1981), 48-57, 78, 79.

     Bruce, Robert. "The AUG Assault System," Guns Magazine,
(September 1986), 37-39, 42,43, 57-61.

     Clapp, Wiley. "Great To-Do With the Daewoo," The Gun Digest
Book of Assault Weapons, (1986), 82-87.

     Combs, Roger. "A Most Unique Carbine," Gun World, (December
1985), 28-31, 47.

     Combs, Roger. "Galil 7.62mm Nato Rifle", Gun World, (October
1985), 32-36.

     Combs, Roger. "The Avtomat Kalashnikov Goes .22," The Gun
Digest Book of Assault Weapons, (1986), 182-195.

     Combs, Roger. "The Uniquely Unique F-11," The Gun Digest Book
of Assault Weapons, (1988), 188-195.

     Cooking and Heckling with H & K 's HK94A3," Gun World, (August
1984), 18-20.

     Davis, Russ. "Have Your AK and Shoot it, Too," Guns Magazine,
(February 1987), 39, 62-64.

     Dickey, Pete. "The Military Look-Alikes",  American Rifleman,
(April 1980), 30-31, 76.

     Egolf, Dick.  "Heckler & Koch's Super Semi-Auto," American
Rifleman, (June 1985), 29-32, 65-67.

     Ezell, Edward Clinton.  Small Arms of the World.  Harrisburg:
Stackpole Books, 1983.

     "FN FNC Rifle," American Rifleman, (January 1988), 58-60.

                              - 2 -

     Ferguson, Tom.  "A Hard Look at The AR-180," The Gun Digest
Book of Assault weapons, (1986), 121-127.

     French, Howard.  "H & K's 9mm Paracarbine," Guns & Ammo,
(November 1983), 42-44.

     Grennell, Dean A. "The Mitchell AK-47," Gun World, (September
1986), 40-41.

     "Heckler & Koch 91," American Rifleman, (October 1981), 56-58.

     "Heckler & Koch Model 94 Carbine," American Rifleman,
(February 1988), 46-48.

     Hogg, Ian V., ed.  Janes' Infantry Weapons, 1987-1988.  New
York: Jane's Publishing Company, 1987.

     Hunnicutt, Robert W. "The Bullpups Have Arrived," American
Rifleman, (March 1987), 30-35, 70-71.

     James, Frank W. "The Springfield Armory SAR-3," Special
Weapons and Tactics, (July 1989), 42-46.

     James, Garry. "Australian L1A1A Rifle," Guns & Ammo, (December
1987).

     James, Garry. "Chinese AX-47 .223," Guns & Ammo, (August
1986), 84-86.

     James, Garry.  "Mitchell Arms AK-22," Guns & Ammo, (November
1985), 72-73, 97.

     James, Garry.  "Mitchell Heavy Barrel AK-47," Guns & Ammo,
(November 1986), 83-84.

     James, Garry.  "PTK Chinese M-14S Rifle," American Rifleman,
(July 1988), 81-82.

     James, Garry.  "The SAR-48 Rifle, Springfield Armory
Reproduces a Classic," Guns & Ammo, (August 1985), 64-66.

     Jarrett, William S., ed.  Shooter's Bible, No. 80.
Hackensack: Stoeger Publishing Company, 1988.

    Kapelsohn, Emanuel.  "Steyr's Space-Age AUG," The Gun Digest
Book of Assault Weapons, (1986), 45-49.

                              - 3 -

     Karwan, Chuck.  "The Fetching-Famas," Gun World, (October
1988), 18-21, 78.

     Karwan, Chuck.  "The Rugged Rifles of Springfield Armory," Gun
World, (March 1989), 72-76.

     Karwan, Chuck.  "Valmet's Assault Family," The Gun Digest Book
of Assault Weapons, (1986), 70-75.

     Lachuk, John.  ".22 Erma Carbine," Guns & Ammo, (May 1968),
58-60.

     Lachuk, John. "Bantam Battle Rifles," (January 1987), 36-39,
75-76.

    Laidlaw, Angus, ed.  Paul Wahl's Big Gun Catalog/1. Bogata:
Paul Wahl Corporation, 1988.

     Lewis, Jack, ed.  The Gun Digest Book of Assault Weapons.
Northbrook: DBI Books, Inc., 1986.

     Lewis, Jack.  "A Family Affair," The Gun Digest Book of
Assault Weapons, (1986), 76-81.

     Lewis, Jack.  "EMP's Look-Alike AP-74," The Gun Digest Book of
Assault Weapons, (1986), 166-171.

     Lewis, Jack.  "Something New: The AK in Twenty-Two," Gun
World, (July 1985), 32-35.

     Lewis, Jack. "Springfield's S.A.R. 48," The Gun Digest Book Of
Assault Weapons, (1968), 88-93.

    Lewis, Jack.  "The Why and How of Rimfires," Digest Book of
Assault Weapons, (1986), 160-171.

     Mason, James D. "The Maadi in America," Guns Magazine,
(January 1983), 33-35, 78.

     Musgrave, Daniel O. and Nelson, Thomas B. The World's Assault
Rifles.  Washington, DC: Goetz Company, 1967.

     O'Mbara, Robert.  "The Guns of Israel," Guns Magazine,
(January 1989), 33-35, 51.

     Paige, Alan.  "The AK-47 As A Bullpup" Firepower, (January
1989), 48-53.

                              - 4 -


     Rees, Clair.  "Valmet M71-S," Guns & Ammo, (October
1976), 86, 137.

     Rickell, Walter.  "The Plinker's AK," Guns Magazine, (July
1986), 21.

     Roberts, J.B. "Bernosky Wins His Fourth," American Rifleman,
(Oct. 1980), 49-51.

     Sanow, Ed.  "National Match AK-47/S," Firepower, (January
1989), 66-71.

     Shults, Jim.  "The Mean Machine," Gun World, (April 1982), 26-
28.

     "Springfield Armory S.A.R. 48," American Rifleman, (March
1986), 57-58.

     Steele, Kevin E. "Beretta BM-59," Guns Magazine, (January
1983), 14.

     Steele, Kevin E. "Sporting Firearms Update," Guns Magazine,
(February 1980), 52-55, 79, 84-85.

     "Steyr-AUG: The Terrible Toy," Gun World, (December 1984), 32-
35.

     Swenson, Thomas J. "The Incredible Uzi," Guns & Ammo, (January
1982), 32-16, 76.

     Tappan, Mel.  "Survive! Survival Rifles-Part 2," Guns & Ammo,
(August 1978), 68, 96-97.

     Traister, John.  "AK Rifle: Chinese AKS or Type 56S," American
Rifleman, (May 1988), 50-51.

     "UZI Semi-Automatic .45 Carbine," American Rifleman, (January
1986), 59.

     "Uzi Semi-Automatic Carbine," American Rifleman, (August
1981), 55-57.

     "Valmet M78 Rifle," American Rifleman, (April 1988), 64-66.

    Wahl, Paul, ed.  Gun Trader's Guide, 13th Edition, South
Hackensack:  Stoeger Publishing Company, 1987.

                              - 5 -


     Warner, Ken, ed.  Gun Digest 1989.  Northbrook:  DBI
Books, Inc., 1988.

     Wood, J.B. "Beretta's AR70 Sporter," Guns Magazine, (March
1986), 38-39, 65-66.

     Woods, Jim.  "Firepower From the Far East-Daewoo," Guns
Magazine, (February 1986), 28-29, 60-61.

     Zwirz, Bob.  "Valmet's Military Look," Gun World, (September
1988), 28-30.

ATTACHMENT 1

ATF NEWS

April 5, 1989

Temporary suspension of the following semiautomatic firearms
announced March 14, 1989:

AKS Variants
AK47 type
AK47S type
AK74 type
AKS type
AKM type
AKMS type
ARM type
84S type
84S1 type
84S3 type
86S type
86S7 type
87S type
Galil type
Type 56 type
Type 56S type
Valmet M76 type
Valmet M78 type
M76 counter sniper type

FAL Variants 
FAL type 
L1A1A type 
SAR 48 type

Other
AUG type
FNC type
Uzi carbine


Suspension of additional semiautomatic firearms announced
April 5, 1989:

Algimec AGM1 type
AR180 type
Australian Automatic Arms SAR type 
Beretta AR70 type
Beretta BM59 type
CIS SR88 type
HK91 type
HK93 type
HK94 type
G3SA type
K1 type
K2 type
AR100 type
M14S type
MAS223 type
SIG 550SP type
SIG 551SP type
SKS type with detachable magazine 
AK22 type
AP74 type
Galil/22 type
M16/22 type
Unique F11 type
Erma EM1.22 type

ATTACHMENT 2

[Attachment 2 is ATF Form 4590 "Factoring Criteria for Weapons",
which is the form for determining, by score, the importability of
handguns.]

ATTACHMENT 3

                     FIREARMS ADVISORY PANEL

      The initial meeting of the Firearms Advisory Panel was held
in Room 3313, Internal Revenue Building, on December 10, 1968 with
all panel members present, Internal Revenue Service personnel in
attendance at the meeting were the Director, Alcohol and Tobacco
Tax Division, Harold Soarr; Chief, Enforcement Branch, Thomas
Casey; Chief Operations Coordination Section, Cecil M. Wolfe; and
Firearms Enforcement Officer, Paul Westenberger.  Deputy
Commissioner Compliance, Leon Green, visited the meeting several 
times during the day.

     The Director convened the meeting at 10:00 a.m. by welcoming
the members and outlining the need for such an advisory body.  He
then introduced the Commissioner of Internal Revenue, Mr. Sheldon
Cohen to each panel member.

     Mr. Cohen spoke to the panel for approximately fifteen
minutes.  He thanked the members for their willingness to serve on
the panel, explained the role of the panel and some of the
background which led to the enactment of the Gum Control Act of
1968.  Commissioner Cohen explained to the panel members the
conflict of interest provisions of regulations pertaining to
persons employed by the Federal Government and requested that if
any member had any personal interest in any matter that came under
discussion or consideration, he should make such interest known and
request to be excused during consideration of the matter.

                              - 2 -

     Mr. Serr then explained to the panel the areas in which the
Division would seek the advice of the panel and emphasized that the
role of the panel would be advisory only, and that it was the 
responsibility of the Service to make final decisions.  He then
turned the meeting over to the moderator, Mr. Wolfe.

     Mr. Wolfe explained the responsibility of the Service under
the import provisions of the Gum Control Act and under the Mutual
Security Act.  The import provisions were read and discussed.

     The panel was asked to assist in defining "sporting purposes"
as used in the act.  it was generally agreed that firearms designed
and intended for bunting and all types of organized competitive
target shooting would fall within the sporting purpose category. 
A discussion was held concerning the so  called  sport of
"plinking".  It was the consensus that, while many persons
participated in the type of activity and much ammunition was ex-
pended in such endeavors, it was primarily a pastime and could not
be considered a sport for the purposes of importation since any
firearm that could expel a projectile could be used for this
purpose without having any characteristics generally associated
with target guns.

     The point system that had been developed by the Division and
another point system formula suggested and furnished by the
Southern Gun Distributors through Attorney Michael Desalle, was
explained and demonstrated by Paul Westenberger.  Each panel member
was given copies of the formulas and requested 

                              - 3 -

to study them and endeavor to develop a formula he believed would
be equitable and could be applied to all firearms sought to be
imported.

     A model BM59 Beretta, 7.62mm, NATO Caliber Sporter Version
Rifle was presented to the panel and their advice sought as to
their suitability for sporting purposes.  It was the consensus that
these rifles do have a particular use in target shooting and
hunting.  Accordingly, it was recommended that importation of this
rifle together with the SIG-AMT 7.62mm NATO Caliber Sporting Rifle
and the Cetme 7.62mm NATO Caliber Sporting Rifle be authorized for
importation.  Importation, however, should include the restriction
that these weapons must not possess combination flash
suppressor/grenade adapters with outside diameters greater than
20mm (.22mm is the universal grenade adapter size).

     The subject of ammunition was next discussed.  Panel members
agreed that incendiary and tracer small arms ammunition have no use
for sporting purpose.  Accordingly, the Internal Revenue Service
will not authorize these types of small arms ammunition
importation.  All other conventional small arms ammunition for
pistols, revolvers, rifles and shotguns will be authorized. 

     The meeting was adjourned at 4:00 p.m.



                           C.M. Wolfe


ATTACHMENT 4



                           JUN 30 1986

                                                  C:F:F:DEC      
                                                  178.111



Mr.  Grant W. Stapleton 
Box 649
Middleton, Pennsylvania  17057

Dear Mr. Stapleton:

This is in response to your request for a determination whether the
Striker-12 shotgun recently submitted to the Bureau of Alcohol,
Tobacco and Firearms for examination is a weapon that may be
imported into the United States.

Section 925(d)(3) of 18 U.S.C. Chapter 44 provides that a firearm
may be imported or brought into the United States if the person
importing or bringing in the firearm establishes to the
satisfaction of the Director that the firearm is of a type that
does not fall within the definition of a firearm as defined in
Section 5845 (a) of the Internal Revenue Code of 1954 and is
generally recognized as particularly suitable for or readily
adaptable to sporting purposes, excluding surplus military
firearms.

The Bureau has considered the information provided about the
Striker-12 gauge shotgun and examined the weapon submitted.  We
have determined that the Striker-12 shotgun is not particularly
suitable for sporting purposes.  We believe the weapon to have been
specifically designed for military and law enforcement uses.

Therefore, we will not authorize the importation of the Striker-12
shotgun under the provisions of 925(d)(3). if we can be of any
further assistance, please do not hesitate to contact us.

                        Sincerely yours,

                         Wayne P. Moran
          Acting Chief, Firearms and Explosives Division




ATTACHMENT 5

                           DEC 11 1986

                                                  LE:F:TE:FMO
                                                  7540

Mr. Wayne K. Naihe
Gilbert Equipment Company, Inc. 
3300 Buckeye Road, N.W.
Atlanta, Georgia  30341

Dear Mr. Naihe:

This refers to the USAS-12 semiautomatic shotgun bearing serial
number  which was submitted for classification as to its
importability as a sporting purpose firearm.

The firearm has been compared with the full automatic version of
the USAS-12 which your firm provided and it has been determined
that the weapon in question to designed to permit only
semiautomatic fire.  Therefore the USAS-12 shotgun bearing serial
number JHH0000002SA is classified as being a firearm as that term
is defined in Section 921(a)(3) Chapter 44, Title 18, United States
Code (U.S.C.), The Gun Control Act of 1960 (GCA).

Additionally, the Bureau of Alcohol, Tobacco and Firearms has
carefully reviewed the USAS-12 semiautomatic shotgun and determined
that the weapon is a semiautomatic version of a selective fire
military type assault shotgun.  It is our opinion that due to the
weight, size, bulk, designed magazine capacity, configuration and
other factors, the USAS-12 semiautomatic shotgun is not
particularly suitable for or readily adaptable to sporting
purposes.  Therefore, the USAS-12 semiautomatic shotgun may not be
imported into the United States for unrestricted commercial sale
under the provisions of Section 925(d)(3), Chapter 44, Title 18,
U.S.C.  The weapon may however, be imported for Federal or State
Government entities as provided by 18 U.S.C., Section 925.

                              - 2 -

Mr. Wayne K. Naihe

The submitted sample, which was released to your firm on a
conditional basis for test and design study, should to exported or
destroyed upon completion of your testing.

We regret that our reply cannot be more positive.  If we can be of
any further assistance, please contact us.

                        Sincerely yours,

                    (signed) William T. Drake

                        William T. Drake
                         Deputy Director

ATTACHMENT 6

[Attachment 6 is a copy of a page from some firearms catalog,
describing the Valmet Hunter, and Valmet M76 rifles, both with
folding tube stock and with fixed stock, with photos of each
variant.]

ATTACHMENT 7

RIFLES RECOMMENDED TO BE DENIED IMPORTATION

AKS Variants
AK 47 type
AK47S type
AK74 type
AKS type
AKM type
AKMS type
ARM type
84S type
84S1 type
84S3 type

86S type
867S type
867S type
Galil type
Type 56 type
Type 56S type
Valmet M76 type
Valmet M78 type
M76 counter sniper type

FAL Variants 
FAL type 
L1A1A type
SAR 48 type

Other
AUG type
FNC type
Uzi carbine


Algimec AGM1 type
AR180 type
Australian Automatic Arms SAR type* 
Beretta AR70 type
Beretta BM59 type
CIS SR88 type
HK91 type
HK93 type
HK94 type
G3SA type
K1 type
K2 type
AR100 type
M14S type
MAS223 type
SIG 550SP type
SIG 551SP type
SKS with detachable magazine

* The Australian Automatic Arms Model SP-20 will be conditionally
imported to determine if it is of a type generally recognized as
particularly suitable for sporting purposes.


ATTACHMENT 8


RIFLES RECOMMENDED TO BE APPROVED FOR IMPORTATION

Valmet Hunter 
AK22 type 
AP74 type 
Galil/22 type 
M16/22 type 
Unique F11 type
Erma EM1.22 type


ATTACHMENT 9


                                             June 7, 1989

                     LICENSED HUNTING GUIDES
                         SURVEY RESULTS


A total of 706 respondents have been entered into the
database.


     1.    What type of guided hunt do you ordinarily conduct?

          a.   Large-Game                           89.742% 
          b.   Small Game                           28.571%

     2.   What type of rifle is most often used by your clients?

          a.   Bolt or lever action                 73.542%
          b.   Semi-automatic                       28.158% ***
          C.   Other                                11.178%



     For clients who use semi-automatic rifles, which makes or
     brands and models are used?


          a.   520 of the 706 respondents indicated that their
               clients had used semi-automatic firearms.

               403 of the 520 stated their clients had used
               Remington firearms.

               357 of the 520 stated their clients had used
               Browning firearms.

               176 of the 520 stated their clients had used
               Winchester firearms.

               128 of the 520 stated their clients had used Ruger
               firearms.

          b.   186 of the 706 respondents stated that they either
               did not allow/recommend use of semi-automatic
               rifles or that none of their clients had ever used
               semi-automatic rifles for hunting.

                              - 2 -

 Hunting Guide Survey

          c.   10 of the 706 respondents indicated that their
               clients had used weapons which were covered by the
               temporary import ban.

               7 of the 10 listed the H&K model 91

               3 of the 10 listed the AK 47

               3 of the 10 listed the H&K model 93

               1 of the 10 listed the Poly Tech AKS

               1 of the 10 listed the Chinese SKS 7.62 X 39


     4.   Do you supply rental semi-automatic rifles for your
          clients?

          28 of the 706 respondents indicated that they supply
          semi-automatic firearms for their clients.

          2 of the 28 indicated that they supplied a weapon covered
          by the temporary import ban.  The two respondents
          indicated they supplied the Uzi and H&K 91 to their clients.


     5.   What percentage of your clients use semi-automatic rifles
          for:

          Large game hunting                          28.472%
          Small game hunting                          51.284% ***


*** This figure is substantially inflated by respondents
erroneously including the use of semi-auto shotguns in this figure.

[newpage]
                                                  June 7, 1989

                   COMPETITION SHOOTING GROUPS
                         SURVEY RESULTS

A total of 53 respondents have been entered into the
database.


     1.   Does your group/association sponsor high power rifle
          competion events?

          50 of the 53 responded  yes. 

     2.    Do you have published guidelines?

          a.    52 of the 53 responded yes.

          b.   39 of the 52 observe NRA and/or Department of
               Civilian Marksmanship (DCM) rules.

          c.   4 of the 52 observe United States Practical
               Shooting Association (USPSA) rules.

          d.   2 of the 52 have their own published club rules.

     3.   Do you have competitive events using high power semi-
          automatic rifles?

          51 of the 53 responded yes.

     4.   If so do these events cover:

          a.   Sporting competition

          51 of the 53 responded yes.

          b.   Military or police combat competition?

          30 of the 53 responded yes.

          c.   Other?

          6 of the 53 indicated they conduct silhouette, benchrest
          or other type of matches.

                              - 2 -

 Competition Shooting Groups

     5.   For 4a through 4c, as applicable, do you restrict the
          semi-automatic rifle, which may be used, either in terms
          of type, caliber, magazine capacity, or other aspects?

          a.   34 of the 53 responded yes.

          b.   19 of the 34 respondents observe match restrictions
               as dictated by NRA, USPSA or DCM rules.

[newpage]

                                             June 7, 1989

                      HUNTING ASSOCIATIONS
                         SURVEY RESULTS

A total of 2 respondents have been entered into the
database.

Both respondents answered NO to every question.

[newpage]

                                             June 7, 1989

                     HUNTING/SHOOTING EDITOR
                         SURVEY RESULTS

A total of 14 respondents have been entered into the
database.

     1.   Do you recommend specific types of semi-automatic
     rifles for use in hunting large game?

          a.   9 of the 14 responded yes.

          b.   3 of the 9 recommended the H&K 91.

          c.   1 of the 9 recommended the FAL type.

     2.   Do  you recommend specific types of semi-automatic rifles 
          for high power rifle competion?

          a.   11 of the 14 responded yes.

          b.   2 of the 11 recommended the H&K 91.

          c.   2 of the 11 recommended the H&I 93.

          d.   1 of the 11 recommended the SAR 48.

          e.   1 of the 11 recommended the Galil.

          f.   1 of the 11 recommended the Steyr AUG.


     3.   Have you written any articles concerning the use of semi-
          automatic rifles as to their suitability for use in
          hunting large game?  If so, please furnish us with a
          copy.

          9 of the 14 respondents submitted articles for review.

[newpage]

                                             June 7  1989

                   GAME AND FISH COMMISSIONER
                         SURVEY RESULTS

A total of 43 respondents have been entered into the database.

Do the hunting laws of your State place any prohibitions or
restrictions on:

     1.   The use of high power rifles for hunting large or small
          game?

          26 of the 43 responded yes

     2.   The use of semi-automatic high power rifles in general
          for hunting large game or small game?

          a.   22 indicated prohibitions or restrictions on the
               use of semi-automatic rifles for hunting large
               game.

          b.   21 indicated.prohibitions or restrictions on the
               use of semi-automatic rifles for hunting small
               game.

     3.   If any, what are these restrictions

          a.   6 States have a 6 round restriction, including
               magazine and chamber.

          b.   5 States have a 5 round magazine restriction.

          c.   2 States have an 8 round magazine restriction.

          d.   1 State has a 10 round magazine restriction.

          e.   1 State has an 11 round magazine restriction.

     4.   What if any, is the minimum caliber or bullet dimensions
          which may be used for taking large game?

          22 of the 43 respondents indicated that their State has
          ammunition restrictions for large game hunting.

ATTACHMENT 10

               CRITERIA FOR EVALUATION OF SPECIFIC
                    RIFLES ON SUSPENSION LIST

     1.   Does the rifle have a military configuration?

          a.   ability to accept a detachable magazine
          b.   folding/telescoping stock
          c.   pistol grip
          d.   ability to accept a bayonet
          e.   flash suppressor
          f.   bipod
          g.   grenade launcher
          h.   night sights

     2.   Is the weapon a semiautomatic version of a machinegun?

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? (military assault rifles
          and submachineguns use intermediate rifle cartridges and
          pistol cartridges)

     4.   How has the rifle been advertised/marketed and
          categorized by the manufacturer/importer?

          a.   Number of advertisements used __.
          b.   Number of advertisements which deal with
               hunting/competition use __.
          c.   Number of advertisements which deal with assault,
               paramilitary or combat type use __.

     5.   How has the use of the rifle been described by technical
          writers?

          a.   Number of technical articles used __.
          b.   Number of technical articles which deal with
               hunting/competition use __.
          c.   Number of articles which deal with assault,
               paramilitary or combat type use __.

     6.   What is the rifles reported use by importers?

          a.   Number of affected importers responding __.
          b.   Number who recommended for hunting use __.
          c.   Number who recommended for competitive shooting __.

[newpage]

     7.   Do State Game Commissioners allow the use of the rifle to
          hunt?

          a.   Number of State Game Commissions responding __.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles __. *
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles __.

     8. Do hunting guides recommend the rifle?

          a.   Number of hunting guides who responded __.
          b.   Number of hunting guides who listed the rifle as
               being used by their clients __.
          c.   Number of hunting guides who listed the rifle as
               one they supply to their clients for hunting use
               __. 

     9. Do hunting/shooting editors recommend the rifle?

          a.   Number of hunting/shooting editors who responded
               __.
          b.   Number of hunting/shooting editors who recommended
               this type of rifle for hunting __.
          c.   Number of hunting/shooting editors who recommend
               this type of rifle for competitive shooting __.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               __.
          b.   Number of hi power rifle associations who listed
               the rifle as used in competition __.
          c.   Number of hi power rifle associations who indicated
               the rifle was suitable for use in competition __.
               **

*Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

**Permitted for use in the "Any Rifle" category.

ATTACHMENT 11

                  EVALUATION OF SPECIFIC RIFLES
                       ON SUSPENSION LIST

RIFLE: AKS (includes all variants imported)
MANUFACTURER: State factories in China and Yugoslavia, Also
              MAADI Company Egypt & Valmet in Finland
IMPORTER: Various, Major include: China Sports Santa Fe
          Springs, CA.; KFS Atlanta, GA; Mitchell Arms Costa Mesa,
          CA; Sile New York.

DESCRIPTION: 7.62x39mm caliber semiautomatic rifle.  Gas operated,
detachable magazine, weight 8.4 pounds (weight varies depending on
configuration.  Overall length approximately 34 5/8 inches
depending on stock configuration.  Barrel lengths 16.25 inch
standard, longer lengths available depending on configuration of
rifle.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes,
          identical in appearance to AK47 and AKM military assault
          rifles. imported examples also available in configuration
          of RPK light machinegun.

     a.   ability to accept a detachable magazine.  Yes, 30 round
          standard. 75 round drum available as option. 5 round also
          available (5.56mm caliber)

     b.   folding/telescoping stock.  Yes, available with several
          variations of folding stock or fixed stock.

     c.   pistol grip.  Yes, design of receiver and configuration
          of stock dictate use of separate pistol grip.

     d.   ability to accept bayonet.  Yes, depending on marketing
          bayonet is supplied with rifle or sold as an accessory.

     e.   flash suppressor.  Yes, depending on configuration, some
          versions have flash suppressor, others have only muzzle
          brake, some variations have no muzzle attachment.

     f.   bipod. Yes, versions supplied in configuration of RPK
          light machinegun supplied with bipod.

     g.   grenade launcher.  No. Those versions with threaded
          muzzles for flash suppressors or muzzle brakes could be
          fitted with screw on grenade launcher.

     h.   night sights, Yes, certain versions supplied with
          luminous sights.

[newpage]

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of AK47/AKM military rifle,
          other configurations available which are semiautomatic
          versions of RPK light machinegun.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes (7.62x39mm)
          Cartridge case length-is approximately 1.5 inches. 
          Versions in caliber 5.56mm/.223 Remington have cartridge
          case length of 1.76 inches.  Versions in 7.62mm NATO/.308
          Winchester have cartridge case length of 2.015 inches. 
          NOTE: M76 Counter Sniper Version is chambered for 7.9 x
          57mm cartridge which has a cartridge case length in
          excess of 2.25 inches.

     4.   How has the rifle been advertised/marketed?

          5 advertisements used; Navy Arms; China North Industries,
          Stoeger, Poly Technologies and Mitchell Arms.  The
          advertising material does not indicate a specific use for
          the rifles.  Advertising stresses that the rifles are:

          a.   military rifles (Stoeger advertisement for Valmet
               M76)
          b.   semiautomatic version of the Chinese AKM (Type 56)
               assault rifle (Poly Technologies advertisement for
               AKS)
          c.   Semiautomatic version of the-Chinese RPK Squad
               Automatic Weapon (Navy Arms advertisement for RPKS-
               74)
          d.   Quality that exceeds military specifications
               (Mitchell Arms advertisement for AK-47).
          e.   Semi-auto sporting rifle (China North Industries
               advertisement for Type 56S).

     5.   Technical Writers Descriptions:
     13 technical articles used.
     Guns & Ammo Magazine, October 1976, page 86 
     Guns Magazine, January 1983, page 33
     Gun World Magazine, October 1985, page 32
     Guns a Ammo Magazine, August 1986, page 84
     Gun World Magazine, September 1986, page 40 
     Guns & Ammo Magazine, November 1986, page 83 
     Guns Magazine, February 1987, page 39
     Gun World Magazine, September 1988, page 28 
     American Rifleman Magazine, April 1988, page 64 
     American Rifleman Magazine, May 1988, page 50 
     Firepower Magazine, January 1989, Pages 48 & 66 
     The Gun Digest Book of Assault Weapons, Page 70

The majority of the articles contain discussions of the development
and military use of the AK47 as a military rifle.  As in technical
articles on firearms much time is devoted to a discussion of the
design, function, disassembly, and quality of the weapon.  All
articles cover the ruggedness and reliability of the rifles.

[newpage]

Those articles which discuss the accuracy of the rifle, with the
exception of the January 1989 Fire Power Magazine article on the
National match AK47, indicate that the rifles have acceptable
accuracy for an assault rifle.  The October 1976 Guns & Ammo
Magazine article states "I obtained 5 round groups measuring from
5 to 6 inches across.  While thats not tack driving accuracy by
hunting rifle standards, its plenty good enough to keep a General
happy and his troops smiling."

None of the articles specifically recommend the rifle for hunting. 
The October 1976 Guns a Ammo Magazine article states "and while I
do not think a paramilitary arm like this has any place in the
woods (the Russian round would be legal for hunting deer in some
states, as long as expanding bullets were used).  I thought I might
have some fun at least scaring a few of the coyotes and other
varmint type creatures inhabiting Utah's desert."

The articles list the following uses for the various
versions of the AKS type rifles.

     a.   Guns & Ammo Magazine, October 1976; plinking or home
          defense.
     b.   Guns Magazine, January 1983; highly desirable to military
          collectors and combat shooting groups.
     c.   American Rifleman Magazine, April 1988; allows the
          civilian to own an attractive and reliable equivalent to
          the Soviet RPK.
     d.   Gun Digest Book of Assault Rifles; Valmet M82 Bull Pup
          particularly suited for law enforcement purposes,
          excellent choice as survival or self defense weapon. 
          Characterizes the Valmet M78 as an assault rifle.

None of the articles recommend the basic variants of the AKS for
traditional competitive target shooting.

The Fire Power Magazine, January 1989, article discusses the
National Match AK47 as having features such as a longer barrel,
longer stock and machined receiver with scope mount as making the
rifle the most accurate Kalishnikov in the world.

[newpage]

                         EVALUATION OF SPECIFIC RIFLES
                              ON SUSPENSION LIST

RIFLE: FN FAL and variants
MANUFACTURER: FN Belgium, FMAP Argentina, Brazil,
              Australia, Israel

IMPORTER: Various, Major include, Gun South, Trussville, AL;
          Springfield Armory, Geneseo IL; Armscorp, Baltimore MD;

DESCRIPTION: 7.62 NATO caliber semiautomatic rifle.  Gas operated
detachable magazine, weight 9.4 - 12.2 pounds depending on
configuration.  Overall length 39 - 45 inches depending on
configuration.  Barrel lengths 18 or 21 inch.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? yes,
          identical in appearance to FN FAL selective fire military
          rifle.

          a.   ability to accept a detachable magazine.  Yes 20
               round standard. 10 round available as option

          b.   folding/telescoping stock.  Yes, standard on "Para"
               (paratroop) version.

          c.   pistol grip.  Yes, design of receiver and
               configuration of stock dictate use of separate
               pistol grip.

          d.   ability to accept a bayonet.  Yes, available as
               accessory.

          e.   Flash suppressor.  Yes, depending on configuration
               clamps or screws to barrel.

          f.   bipod.  Yes, standard on heavy barrel model

          g.   grenade launcher.  No, certain style flash
               suppressors serve as grenade launcher on military
               version.  Friction ring for retaining grenade in
               position is removed from flash suppressors on
               semiautomatic versions.  Short style flash
               suppressors could serve as grenade launchers if
               friction ring were replaced.

          h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of FN PAL selective fire
          military rifle.

[newpage]

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or loss? Yes, (7.62mm NATO/.308
          Winchester) Cartridge case length is 2.015 inches.

     4.   How has the rifle been advertised/marketed?

     3 advertisements used: Armscorp, Gun South, Springfield
     Armory.  Armscorp advertising describes high quality and does
     not mention specific uses.  Gun South advertising states that
     rifle is supplied as a semiautomatic version for sporting use
     of the FN FAL military rifle.  Springfield Armory advertising
     describes the rifle as developed from FN military rifle and
     lists uses in combat rifle matches or NRA matches.

     5.   Technical writers descriptions:

     5 technical articles used.
     Guns & Ammo Magazine, August 1985, page 64 
     American Rifleman Magazine, March 1986, page 57 
     Guns & Ammo Magazine, December 1987, page 96 
     Gun World Magazine, March, 1989, page 72
     Gun Digest Book of Assault Weapons, page 88

All of the articles discuss the history of the military FN FAL
rifle and comment on the quality of the rifles being tested. 
Technical discussions of function, accuracy and disassembly are
contained in each article.  The excellent accuracy of the rifles is
mentioned in each article.  The American Rifleman, March 1986
article makes the following comment concerning the use of the
rifle; "as all "paramilitary" arms do, the S.A.R.-48 raises the
question "what's it for?" The simple fact is that many gun
enthusiasts neither hunt nor compete in traditional tournament
shooting.  For these shooters the S.A.R.-48's accuracy and pleasant
shooting qualities (thanks to its heft) make it an ideal high-power
plinker.

The March 1989 Gun World Magazine article states that the rifle has
match grade accuracy and is extremely versatile.  The article also
indicates that though a bit on the heavy side and unconventional in
looks it makes a superbly accurate hunting rifle.  This article
also recommends the rifle for home defense.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: Steyr AUG SA
MANUFACTURER: Steyr Mannlicher, Austria 
IMPORTER: Gun South, Inc.  Trussville, Alabama

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 7.2 pounds, overall
length 31 inches with standard barrel, Quick change barrel, lengths
available, 16 inch, 20 inch (standard), 24.5 inch.  Built in
telescopic sight with fixed auxiliary open sights

CRITERIA ELEMENTS 1 - 5

     1.   Does the Weapon have a military configuration? Yes,
          identical in appearance to Steyr AUG selective fire
          military rifle.

     a.   ability to accept a detachable magazine.  Yes, 30 round
          standard, 42 round available as option.

     b.   folding/telescoping stock.  No

     c.   pistol grip.  Yes.  Straight line configuration dictates
          pistol grip placement well below action.

     d.   Ability to accept bayonet.  Yes, bayonet and bayonet
          latch ring available as accessories from importer.

     e.   flash-suppressor.  Yes mounted on barrel.  Flash
          suppressor is internally threaded for blank firing

     f.   bipod. yes, bipod is attached to 24 inch barrel option.
          (24 inch barrel is same as used on light machinegun
          version of military AUG)

     g.   grenade launcher.  No. Flash suppressor serves as grenade
          launcher on military version.  Friction ring for
          retaining grenade in position is removed from flash
          suppressor of AUG SA prior to importation.  AUG SA flash
          suppressor could function as grenade launcher if friction
          ring were replaced

     h.   Night sights.  No

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of Steyr AUG military rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes (5.56mm/.223
          Remington) Cartridge case length is 1.76 inches

[newpage]

     4.   How has rifle been advertised/marketed?

     1 advertisement from Gun South was used.  The advertising
     material does not indicate a specific use for the rifle.  The
     literature stresses the advanced technology of the system,
     simplicity of design, unparalleled accuracy and adaptability.

     5.   Technical Writers Descriptions:

     4 technical articles used.
     Gun World Magazine, December 1984, Page 32
     Guns Magazine, September 1986, Page 37
     American Rifleman magazine, March 1987, Page 30 
     Gun Digest Book of Assault Weapons, page 44

     All of the articles contain in depth discussions of the
     advanced design and configuration of the rifle.  The
     ruggedness, reliability and accuracy are also stressed.  All
     of the articles describe the selective fire version of the
     rifle and its military use.
     None of the articles stress a particular use for the weapon. 
     The Gun World Article states at its conclusion "Aside from
     meeting the needs of police SWAT teams and other special
     groups, the Steyr AUG, with its high resolution scope, should
     be a crackerjack at reducing the nearby varmit population. 
     Good shot placement should leave enough meat for eating on
     rabbits and other small game, too."

     The Gun Digest Book of Assault Rifles article deals primarily
     with the selective fire version of the rifle and its combat
     type applications.  The article mentions the availability of
     the semiautomatic version and concludes by stating "Because of
     its superior design, the AUG is not only an assault rifle for
     close-range combat, but will-allow the average shooter to
     achieve hits at distant targets in less time than would be
     possible with a conventional rifle."

[newpage]

                         EVALUATION OF SPECIFIC  RIFLES
                              ON SUSPENSION LIST

RIFLE: FN FNC
MANUFACTURER: FN, Belgium (no longer produced)
IMPORTER: Gun South, Trussville, AL

DESCRIPTION: 5.56mm semiautomatic rifle, Gas operated, detachable
magazine, weight 8.4 pounds, overall length 40 inches, barrel
length 18 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes,
          identical in appearance to FNC selective fire military
          rifle.

          a.   ability to accept a detachable magazine.  Yes 30
               round standard, 20 round available (uses same
               magazines as AR15).

          b.   folding/telescoping stock.  Yes, available with
               fixed or folding stock.

          c.   pistol gripe Yes, design of receiver and
               configuration of stock dictate use of separate
               pistol grip.

          d.   ability to accept bayonet.  Yes, bayonet available
               as accessory.

          e.   flash suppressor.  Yes, screws to barrel.

          f.   bipod, Yes, available as accessory.

          g.   grenade launcher.  No, flash suppressor serves as
               grenade launcher on military version.  Friction
               ring for retaining grenade in position is removed
               from semiautomatic version prior to importation. 
               Flash suppressor could serve as grenade launcher is
               friction ring were replaced.

          h.   Night sights.  No

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of FNC selective fire rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes (5.56mm/.223
          Remington) Cartridge case length is 1.76 inches.

[newpage]

     4.   How has rifle been advertised/marketed?

     1 advertisement from Gun South used.  The advertising lists
     the rifle as a sporter rifle and states that it is suitable
     for open field, jungle, bush as well as forests.

     5.   Technical writers Descriptions:

     1 technical article used.
     American Rifleman Magazine, January 1988, page 58

     Technical article discusses the development of the weapon,
     function, accuracy and disassembly.  Article makes no mention
     of hunting or target shooting use.  Mentions military use.

[newpage]

                         EVALUATION OF SPECIFIC RIFLES
                              ON SUSPENSION LIST

RIFLE: Uzi Carbine
MANUFACTURER: Israel Military Industries, Israel 
IMPORTER: Action Arms, Philadelphia, PA

DESCRIPTION: 9mm Parabellum .45ACP, .41 Action Express
semiautomatic rifle (.22lr conversion available).  Blowback
operated, detachable magazine, weight 8.50 pounds, overall length
31 1/2 inches, barrel length 16.25 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration.  Yes,
          semiautomatic copy of Uzi submachinegun.

     a.   ability to accept a detachable magazine.  Yes, 10 to 32
          round magazines depending on caliber.

     b.   folding/telescoping stock.  Yes, folding stock standard. 
          Fixed wood stock available as option.

     c.   pistol grip.  Yes, design of receiver, magazine location
          and stock configuration dictate use of separate pistol
          grip.

     d.   ability to accept bayonet.  Yes, bayonet lug part of
          receiver.

     e.   flash suppressor.  No

     f.   bipod.  No

     g.   grenade launcher.  No

     h.   night sights.  No

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of Uzi submachinegun.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes, (9mm Parabellum)
          cartridge case length of approximately .75 inches.
          (.45ACP) Cartridge case length approximately 7/8 inch.

     4.   How has the rifle been advertised/marketed?

     1 advertisement from Action Arms used.  Advertising makes no
     comment concerning use.  Advertising mentions unfailing
     reliability and superior accuracy.

[newpage]

     5.   Technical Writers Descriptions:
     4 technical articles used.
     American Rifleman Magazine, August 1981, page 55 
     Guns & Ammo Magazine, January 1982, page 32 
     American Rifleman Magazine, January 1986, page 59 
     Guns Magazine, January 1989, page 33

None of the technical articles mention hunting or competitive
shooting use of the Uzi Carbine.  All of the articles discuss the
history of the Uzi submachinegun and development of the
semiautomatic carbine.  August 1981 American Rifleman magazine
article states that "as a "plinker", collector piece, home or boat
defense gun or for security guard user we judged the UZI more than
acceptable.  The January 1982 Guns a Ammo magazine article stated
that the rifle is a legal version of a classic submachinegun any
military buff can own.  This article also indicated uses for
plinking and home defense.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: Algimec AGM1
MANUFACTURER: AL. GI. NEC, Italy 
IMPORTER: Global Sales, Minden Utah

DESCRIPTION: 9mm parabellum caliber semiautomatic rifle.  Delayed
blowback operation. detachable magazine, weight 6.6 pounds, overall
length 26.4 inches, barrel length 16.2 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes, has
          bullpup configuration similar to French FMAS. and other
          modern military rifles,

          a.   ability to accept a detachable magazine.  Yes, 13
               or 20 round available.

          b.   folding/telescopic stock.  No.

          c.   pistol grip.  Yes, receiver design and stock
               configuration dictate use of separate pistol grip.

          d.   ability to accept bayonet.  No.

          e.   flash suppressor.  No.

          f.   bipod.  No.

          g.   grenade launcher.  No.

          h.   night sights.  Yes. available as option.

     2.   Is the weapon a semiautomatic version of a machinegun?. 
          No.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes (9mm Parabellum
          Cartridge case length approximately .75 inches.

     4.   How has the rifle been advertised/marketed.

     1 AL. GI. MEC advertisement used.  No use listed.

     5.   Technical writers Descriptions:

     No technical articles available.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: AR180
MANUFACTURER: Sterling, England (no longer produced)
IMPORTER: none current

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 7.2 pounds, overall
length 38 inches, barrel length 18.25 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the rifle have a military configuration? Yes, Same
          general configuration as other modern military selective
          fire rifles in the same caliber.

          a.   ability to accept a detachable magazine.  Yes, 5
               round standard, 20, 30 or 40 round available.

          b.   folding/telescoping stock.  Yes, folding stock
               standard.

          c.   pistol grip.  Yes, design of receiver and
               configuration of stock dictate use of separate
               pistol grip.

          d.   ability to accept bayonet.  Yes.

          e.   flash suppressor.  Yes.

          f.   bipod.  No.

          g.   grenade launcher.  Yes. flash hider serves as
               grenade launcher.

          h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of AR18 selective fire rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes (5.56mm/.223
          Remington) Cartridge case length is 1.76 inches.

     4.   How has the rifle been advertised/marketed.

     1 Advertisement available from Armalite, Costa Mesa, CA dated
     1981. (Armalite out of business).  Describes the rifle as the
     commercial version of the AR18 combat rifle.

[newpage]

     5.   Technical Writers Descriptions:
     2 technical articles used.
     American Rifleman Magazine, February 1981, page 65 
     The Gun Digest Book of Assault Weapons, page 121

Both technical articles give considerable discussion to the
development, design, function, reliability and accuracy of the
rifle.  Neither article comments on specific sporting uses.  The
American Rifleman article makes the following statement; "The
military rationale for the folding stock was to ease handling of
the rifle by paratroops, tank or aircraft crews.  The distributor
of the AR180 feels this feature would also be well liked by persons
who might wish to store a compact, high power rifle aboard a boat,
airplane or other vehicle for protection or survival.  For sporting
purposes the folding stock is comparable to the takedown center-
fire rifles so popular in the past."

The Book of Assault Rifles article discusses only the weapons
possible advantages over the M16 as a combat rifle.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: Australian Automatic Arms SAR
MANUFACTURER: Australian Automatic Arms, Australia
IMPORTER: Not currently imported.

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 7.5 pounds, overall
length 35.875 inches, barrel length 16.25 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes. 
          Identical in appearance to Australian Automatic Arms
          military rifle.

          a.   ability to accept a detachable magazine.  Yes. 20
               or 30 round (uses M16 magazines)

          b.   folding/telescoping stock, No.

          c.   Pistol grip.  Yes.  Receiver design and stock
               configuration dictate separate pistol grip.

          d.   ability to accept bayonet. Yes.

          e.   flash suppressor.  Yes

          g.   grenade launcher.  Yes, flash suppressor serves as
               grenade launcher.

          h.   night sights.  No

     2.   Is the weapon a semiautomatic version of a machinegun. 
          Yes, semiautomatic version of Australian Automatic Arms
          AR selective fire rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes. (5.56mm/.223
          Remington) Cartridge case length 1.76 inches.

     4.   How has rifle been advertised/marketed.

          1.   Australian.  Automatic Arms advertisement used.
               Advertised as sporting rifles and military weapons. 
               No specific sporting use listed.  Company also
               produces conventional appearing sporting rifle
               using same basic action with redesigned stock and
               forearm.  Known as SP and SP20 rifles.

     5.   Technical writers Descriptions:

     No technical articles available.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: Beretta AR70
MANUFACTURER: Beretta, Italy
IMPORTER: Beretta U.S.A., Accokeek, MD

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 8.3 pounds, overall
length 38 inches, barrel length 17.72 inches.

CRITERIA ELEMENTS 1 - 5

          1.   Does the rifle have a military appearance? Yes,
               identical in appearance to Beretta Model 70
               military rifle.

          a.   ability to accept a detachable magazine.  Yes, 30
               round standard. 5 and 8 round available as options

          b.   folding/telescoping stock.  No.

          c.   pistol grip.  Yes, receiver design and stock
               configuration dictate separate pistol grip.

          d.   ability to accept bayonet.  Yes.

          e.   flash suppressor, Yes built into muzzle shroud.

          f.   bipod, Yes, available as accessory

          g.   grenade launcher.  No. friction ring to hold
               grenade in place removed from barrel shroud.  If
               friction ring replaced, grenade launcher would be
               functional.

          h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of Beretta AR70 rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes, (5.56mm/.223
          Remington) Cartridge case length 1.76 inches.

     4.   How has the rifle been advertised/marketed?

     1 Beretta U.S.A. advertisement used.  Advertisement lists
     rifle as AR70 Sport.  Does not mention specific use but states
     that it is the ultimate rifle for shooters who demand optimum
     firepower.

[newpage]

     5.   Technical Writers Descriptions:

     3 technical articles used.
     Guns & Ammo Magazine, December 1983, page 64 
     Guns Magazine, March 1986, page 36 
     American Rifleman Magazine, March 1988, page 64

All of the articles dwell on the history, design, function,
accuracy, disassembly and ruggedness of the rifle.  The December
19983 Guns & Ammo magazine article states that "basic ruggedness,
essential in a military arm, that has made assault rifles so
attractive to shooters and hunters who pursue their sports in rough
terrain." The article refers to the weapon as a solid, smooth
functioning, accurate assault rifle sporter.

The March 1986 Guns magazine article comments that accuracy
performance is good for a no frills out-of-the-box assault rifle. 
This article states that for sport shooting or serious law
enforcement work it would be an ideal choice.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: Beretta BM59
MANUFACTURER: Beretta, Italy (copies also made by
              Springfield Armory from a combination of
              foreign and domestic parts)
IMPORTER: Springfield Armory, Geneseo, IL

DESCRIPTION: 7.62 NATO caliber semiautomatic rifle
Gas operated, detachable magazine, weight 9.5 pounds without
accessories, length 43.11 inches, barrel length 19.32 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the rifle have a military configuration? Yes,
          Identical in appearance to Beretta BM59 military rifle.

     a.   ability to accept a detachable magazine.  Yes, 20 round
          standard.

     b.   folding/telescoping stock.  Yes, standard on certain
          versions.

     c.   pistol grip.  Yes, separate pistol grip standard on
          Alpine paratrooper model and Nigerian model, conventional
          pistol grip on standard Italian model.

     d.   ability to.accept bayonet.  Yes.

     e.   flash suppressor.  Yes.

     f.   bipod.  Yes.

     g.   grenade launcher.  Yes.

     h.   night sights, No.

     2.   Is the rifle a semiautomatic version of a machinegun?
          Yes, semiautomatic version of Beretta BM59 selective fire
          rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes (7.62 NATO/.308
          Winchester) Cartridge case-length 2.015 inches.

     4.   How has the rifle-been advertised/marketed?
     1 Springfield Armory Advertisement used.  Does not list uses
     for rifle.  Describes it as premium quality Italian military
     rifle.

[newpage]

     5.   Technical Writers Descriptions:
     2 Technical articles used.
     Gun World Magazine, April 1982, page 26
     Guns Magazine, January 1983, page 14

Articles discuss history, development, function, ruggedness and
accuracy of the rifle.  The Gun World article suggests the rise in
popularity of military for defensive purposes.  The article further
states "I am not a gun collector. and I don't own rifles just to
look at them.  However, I couldn't resist the BM-59.(I have no real
need, since it is not legal for U.S. match shooting and I have a
nice hunting rifle.) I quickly rationalized my purchase of a BM for
the new sport of combat rifle shooting, which is similar to combat
pistol or practical pistol matches."

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: SR88
MANUFACTURER: Chartered Industries of Singapore IMPORTER: None

DESCRIPTION: 5.56mm caliber rifle.  Semiautomatic version has not
yet been approved by ATF as a firearm as defined in Chapter 44,
Title 18.  Weapon has yet to be commercially imported.  Rifle is to
be a copy of SAR 80 selective fire military rifle.  No further
evaluation possible due to lack of sample.  No advertising no
technical articles.

[newpage]

                         EVALUATION OF SPECIFIC RIFLES
                              ON SUSPENSION LIST

RIFLE: HK 91 & 93 (and copies)
MANUFACTURER: Heckler a Koch, West Germany (copies made in
Greece & Portugal)
IMPORTER: HK Inc., Sterling, VA. (copies imported by
          Springfield Armory, Geneseo, IL., Pars Int'l. 
          Louisville, KY)

DESCRIPTION: 7.62 NATO (HK91) or 5.56mm (HK93) semiautomatic rifle. 
Delayed roller lock operation, detachable magazine, weight 9.7 -
10.5 pounds (HK91), 7.94 - 8.6 pounds (HK93), overall length 40.38
inches (HK91) 37 inches (HK93).

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes,
          identical in appearance to HK G3 and HK33 selective fire
          military rifles.

          a.   ability to accept detachable magazine.  Yes, 20
               round (HK91), 25 round (HK93), 5 round available
               for both

          b.   folding/telescoping stock.  Yes, a version of both
               rifles supplied with telescoping stock, Telescoping
               stock also available as accessory.

          c.   pistol grip.  Yes, design of receiver and
               configuration of stock dictate use of separate
               pistol grip.

          d.   ability to accept bayonet.  Yes, bayonet and
               adapter available from importer.

          e.   flash suppressor.  Yes, screws to barrel.

          f.   bipod.  Yes.  Both rifles have built in bipod
               mount.  Bipod available as accessory from
               manufacturer.

          g.   grenade launcher.  No, Flash suppressor serves as
               grenade launcher on military versions.  Friction
               ring and friction ring groove for retaining grenade
               in position removed from barrel on HK91 a 93.

          h.   Night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of HK G3 and HK33 selective
          fire rifles.

[newpage]

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes, (7.62 NATO/.308
          Winchester) Cartridge case length 2.015 inches,
          (5.56mm/.223 Remington) cartridge case length 1.76
          inches.

     4.   How has the rifle been advertised/marketed?

     2 advertisements used, HK, Inc. and Springfield Armory.  HK
     Inc. advertises the HK90 series rifles as semiautomatic
     sporting rifles.  No specific use is mentioned.  Advertising
     stresses technology and superior craftsmanship that has made
     HK a leader in military firearms for a quarter of a century. 
     Springfield Armory advertising makes no mention of specific
     use for the firearm.  Advertising states that the SAR-3 has
     the design, quality and performance comparable to the HK91 but
     at a much lower price.

     5.   Technical Writers Descriptions:
     6 Technical Articles used.
     Guns & Ammo Magazine, August 1978, page 68 
     Guns Magazine, February 1980, page 52
     American Rifleman Magazine, October 1981, page 56 
     American Rifleman Magazine, June 1985, page 29 
     Special Weapons & Tactics Magazine, July 1989, page 42 
     Gun Digest Book of Assault Rifles, page 76

The majority of the technical articles go into great detail on the
historical development of the rifles, their function, accuracy,
quality and disassembly.  The August 1978, Guns & Ammo Magazine
article titled Survival Rifles - Part 2 considers the HK91 a battle
rifle which is a best buy for long term survival use.  This article
also states that that the HK91 is one rifle that the entire family
can utilize effectively for defense or hunting purposes.  The
February 1980 Guns Magazine article states that the HK91 and 93 are
available for the riflemen who fancy military assault rifles for
competition, varminting or plinking.  This article also states that
both rifles offer excellent potential for "chucking" (taken to mean
shooting woodchucks/ground hogs).

The October 1981 American Rifleman Article discusses the history,
accuracy, reliability and reloading of ammunition for the rifle. 
The article does not specifically recommend the rifle for hunting
or competition but makes the following statement, "Although the
HK91 is not recognized as a  "commercial equivalent" of the M14 or
M16 rifles, and therefore isn't suitable for use in service rifle
competition, it is a well made, reliable and accurate rifle which
is of considerable interest to collectors and others who enjoy
informal shooting of military type rifles."

[newpage]

The July 1989 Special Weapons and Tactics magazine describes the
rifle as  "For those who are interested in an excellent
paramilitary rifle, the advantages of this new Springfield Armory
SAR-3 are too good to ignore."  The article further states that the
HK91 became an extremely popular rifle among survivalists,
collectors, combat shooters and even law enforcement officers.  The
article calls the firearm a battle rifle.

[newpage]

                         EVALUATION OF SPECIFIC RIFLES
                              ON SUSPENSION LIST

RIFLE: Hk94
MANUFACTURER:Heckler a Koch, West Germany IMPORTER: HK, Inc.,
Sterling, VA

DESCRIPTION: 9mm Parabellum caliber semiautomatic rifle.  Delayed
roller lock operation, detachable magazine, weight 6.43 -.7.18
pounds depending on stock configuration.  Barrel length 16.54
inches.

CRITERIA ELEMENTS 1 -  5

     1.   Does the weapon have a military configuration? Yes,
          semiautomatic version of MP5 military submachinegun.

     a.   ability to accept a detachable magazine.  Yes, 15 round
          standard, 30 round available.

     b.   folding/telescoping stock. Yes, HK94A3 supplied with
          telescoping stock.  Telescoping stock also available
          as accessory.

     c.   pistol grip.  Yes, design;of receiver and configuration
          of stock dictate use of separate pistol grip.

     d.   ability to accept bayonet. No.

     e.   flash suppressor.  No.

     f.   bipod.  No.

     g.   grenade launcher.  No.

     h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of MP5 submachinegun.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes, (9mm Parabellum)
          Cartridge case length approximately .75 inches.

     4.   How has the Rifle been advertised/marketed?

     1 HK Inc. advertisement used.  Advertisement lists rifle as
     semiautomatic sporting rifle.  Advertisement states that the
     HK90's series of semiautomatic sporting rifles combine the
     advanced technology and superior craftsmanship that has made
     HK a leader in military firearms for a quarter of a century.

[newpage]

 5..Technical Writers Descriptions:
     4 technical articles used.
     Guns & Ammo Magazine, November 1983, page 42 
     Gun World Magazine, August 1984, page 18 
     American Rifleman Magazine, February 1988, page 46 
     Gun Digest Book of Assault Rifles, page 76

The technical articles spend much time discussing the history of
the weapon, function, accuracy, reliability, and disassembly.  The
November 1983 Guns & Ammo article calls the weapon a home defense
gun that is fun to shoot.  The article also states "You certainly
aren't going to enter any serious, formal matches with it; you're
just going to have something that is a ball to shoot.  And isn't
that what shooting is all about?"

The August-1984 Gun World Article states "it is a carbine made in
the popular semi-military, survival look...". The article makes the
following statement concerning use; "A gun of this type, used for
small gamer plinking, home defense or in a survival role, is
virtually useless unless it is reliable.  The HK94A3 is as reliable
as anyone might desire."

The February 1988 American Rifleman article makes the following
statement concerning the uses of the HK94; "While the HK94 would
make a fun plinking gun and possibly a home defense arm, one
suspects that those customers will seek out lower-priced
alternatives like the Marlin Camp carbine.  The HK94 with a price
tag approaching $1000.00, will appeal more to the well funded law
enforcement and private security agencies as well as dyed in the
wool HK fans."

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: K1, K2, and AR100
MANUFACTURER: Daewoo, South Korea
IMPORTER: Stoeger, New Jersey (K1 & K2), Pacific
          International, California (AR100)

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 6.5 pounds overall length
38.4 inches, barrel length 17 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes, 
          semiautomatic version of K1 & K2 selective fire military
          rifles.

          a.   ability to accept a detachable magazine.  Yes, 30
               round standard. 20 round available (uses M16
               magazines)

          b.   folding/telescoping stock.  Yes, K1 telescoping
               stock, K2 folding stock.

          c.   pistol grip.  Yes, design of receiver and stock
               configuration dictate separate pistol grip.

          d.   ability to accept bayonet. yes.

          e.   flash suppressor.  Yes.

          f.   bipod.  Uncertain, K1 appears to have bipod
               mounting point on barrel.

          g.   grenade launcher.  Unknown, flash suppressor may
               serve as grenade launcher.

          h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of K1 & K2 selective fire
          military rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes (5.56mm/.223
          Remington) Cartridge case length 1.76 inches.

     4.   Bow has rifle been advertised/marketed.

     No specific advertising literature available.  Rifle listed in
     centerfire rifles military style autoloaders section of 1989
     Gun Digest.

[newpage]


     5.   Technical Writers Descriptions:
     2 technical articles used.
     Guns Magazine, February 1986, page 28
     The Gun Digest Book of Assault Rifles, page 82

Both articles discuss the design, function, disassembly,
reliability, and accuracy of the weapons.  Neither article makes
any mention of sporting uses of the weapons.  The Gun Digest Book
of Assault Rifles article concentrates almost exclusively on the
full automatic versions of the weapons.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: M14S
MANUFACTURER: Poly Technologies, China
IMPORTER: KFS, Atlanta, GA.

DESCRIPTION: 7.62mm NATO caliber semiautomatic rifle.  Gas
operated, detachable magazine, weight 9.2 pounds, overall length 43
3/10 inches, barrel length 22 inch.

CRITERIA ELEMENTS-1 - 5

     1.   Does the weapon have a military configuration? Yes,
          Identical in appearance to U.S. M14 service rifle.

          a.   ability to accept a detachable magazine.  Yes, 20
          round standard.

          b.   folding/telescoping stock.  No.

          c.   pistol grip.  No. has conventional stock.

          d.   ability to accept bayonet.  Yes.

          e.   flash suppressor, Yes, held to barrel by nut.

          f.   bipod.  No.

          g.   grenade launcher.  No. None built in but will
               accept standard U.S. attachable grenade launcher.

          h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of M14 selective fire rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less.  Yes (7.62mm NATO/.308
          Winchester) Cartridge case length 2.015 inches.

     4.   How has rifle been advertised/marketed?

     1 KFS advertisement used.  Advertisement does not list
     specific sporting use but makes the following statement "The
     U.S. M14 is widely recognized as one of the most accurate
     service rifles produced.  Chambered for the versatile 7.62
     NATO(308 Win.) cartridge.  The M14 is particularly well suited
     for sporting purposes.

     The Poly Tech M14/S is a semi-auto only version of the M-14
     featuring a true forged receiver.  Obviously, our cold hammer
     forged receiver is more time consuming and costly to
     manufacture.  The result is a precision crafted component

[newpage]

     that actually meets military specifications."

     5.   Technical Writers Descriptions
     1 Technical article used.
     Guns a Ammo Magazine, July 1988, page 80.

     The technical article discusses the design, function, quality
     and accuracy of the rifle.  The article makes no mention of
     specific sporting uses.

[newpage]

                         EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: MAS223
MANUFACTURER:  Manufacture Nationale d'Armes de Saint Etienne, 
               France
IMPORTER: Century Arms, St. Albans, VT.

DESCRIPTION:5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 8.67 pounds, overall
length 29.8 inches, barrel length 19.1 inches.

CRITERIA 1 - 5

     1.   Does the rifle have a military configuration? Yes,
          identical in appearance to French FA MAS military rifle

     a.   ability to accept a detachable magazine.  Yes, 25
          round standard.

     b.   folding/telescoping stock.  No.

     c.   pistol grip.  Yes, weapon configuration dictates separate
          pistol grip.

     d.   ability to accept bayonet, Yes. bayonet supplied with
          rifle.

     e.   flash suppressor.  Yes

     f.   bipod.  Yes, standard.

     g.   grenade launcher.  No. flash suppressor diameter changed
     to prevent use as grenade launcher.

     h.   night sights, Yes

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of French FA MAS selective
          fire rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of less than 2.25 inches? Yes (5.56mm/.223
          Remington) Cartridge case length 1.76 inches.

     4.   How has the rifle been advertised/marketed?

          2 Century Arms advertisements used.  Advertisements make
          no mention of use.  Advertisements state that the rifle
          is limited quantity civil version of the famed and
          fearsome FMAS 5.56 high-tech assault weapon.
          Advertisements list the rifle as for the sportsman and
          collector.

[newpage]

     5.   Technical Writers Descriptions:
     1 Technical Article used
     Gun World magazine, October 1988, page 18

Technical rifle goes into considerable detail on the function,
disassembly, accuracy and reliability of the rifle.  Article calls
the weapon a bullpup assault rifle and recommends it for combat and
use by police SWAT teams.  Article does not mention other uses for
rifle.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: SIG 550SP and 551SP
MANUFACTURER: SIG, Switzerland
IMPORTER: Sigarms, Inc., Herndon, VA.

DESCRIPTION: 5.56mm caliber semiautomatic rifle.
Gas operated, detachable magazine, weight 9 pounds (550SP), 7.7  
pounds (551SP), Overall length 39.3 inches (550SP), 32.5 inches
(551SP), barrel length 20.8 inches (550SP), 16 inches (551SP).

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes,
          identical in appearance to SIG 90 military rifles.

     a.   ability to accept a detachable magazine.  Yes, 20 round
          standard.

     b.   folding/telescoping stock.  Yes, folding stock standard

     c.   pistol grip.  Yes, receiver design and stock
          configuration dictate the use of a separate pistol grip.

     d.   ability to accept bayonet.  Yes, available as accessory.

     e.   flash suppressor.  Yes, integral with barrel.

     f.   bipod.  Yes, standard

     g.   grenade launcher.  Yes

     h.   night sights.  Yes

     2.   Is the weapon a semiautomatic version of a machinegun?
          Yes, semiautomatic version of STG 90 selective fire
          rifle.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less? Yes (5.56mm/.223
          Remington) Cartridge case length 1.76 inches.

     4.   How has the rifle been advertised/marketed?

     1 Sigarms advertisement used.  Only advertisement available is
     for selective fire military version.

     5.   Technical Writers Descriptions: No technical articles
          available.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: SKS with detachable magazine
MANUFACTURER: China, various factories
IMPORTER: Various

DESCRIPTION: 7.62x39mm caliber semiautomatic rifle,
Gas operated, detachable AK47 type magazine, weight 8.8 pounds,
overall length 20.16 inches, barrel length 20.47 inches.

CRITERIA ELEMENTS 1 - 5

     1.   Does the weapon have a military configuration? Yes,
          identical to outdated Soviet & Chinese military rifle
          (SKS & Type 56)

     a.   ability to accept detachable magazine.  Yes. standard 10
          round fixed magazine removed and AK 47 type magazine and
          release fitted.

     b.   folding/telescoping stock.  No.

     c.   pistol grip.  No. Has one piece wood stock with
          conventional pistol grip located in wrist of stock.

     d.   ability to accept bayonet.  Yes. folding bayonet.

     e.   flash suppressor.  No.

     f.   bipod.  No.

     g.   grenade launcher.  No.

     h.   night sights.  No.

     2.   Is the weapon a semiautomatic version of a machinegun?'
          No.

     3.   Is the rifle chambered to accept a cartridge case having
          a length of 2.25 inches or less.  Yes (7.62x39mm)
          Cartridge case length approximately 1.5 inches.

     4.   How has rifle been advertised/marketed.

     No specific advertising available.  Rifle generally advertised
     as SKS with detachable magazine.

     5.   Technical writers Descriptions:

     No technical articles available.

[newpage]

                    EVALUATION OF SPECIFIC RIFLES
                         ON SUSPENSION LIST

RIFLE: AK22, AP74, Galil/22, M16/22, Unique F11, Erma 22
MANUFACTURER: Various German, Italian & Philippine
IMPORTER: Various

DESCRIPTION: All of the listed .22 rimfire caliber rifles are
conventional blowback operated rimfire rifles.  The mechanism
designs are virtually no different than conventional sporting type
.22 rifles.  The Unique F11 is actually a standard French Unique
sporting rifle which has been encased in a housing to resemble the
French FMAS service rifle.  The rifles all accept detachable box
magazines.

CRITERIA ELEMENTS 1 - 5

     1.   Do the weapons have a military configuration Yes.  All
          are assembled to resemble various military rifles such as
          the AK47, M16, Galil, FMAS and Ml Carbine

     a.   ability to accept detachable magazines? Yes, depending on
          rifle magazine capacity varies from 10 to 29 rounds.

     b.   folding/telescopic stock. one version of M16 look a like
          has folding stock, others have fixed stocks.

     c.   pistol grip.  Yes since rifles are assembled to closely
          resemble modern military rifles most have pistol grip
          like military counterpart.

     d.   ability to accept bayonet?  One version of M16 look a
          like will accept bayonet.  Others generally do not accept
          bayonets.

     e.   flash suppressors: No. Non functional flash suppressors
          which resemble military flash suppressor generally
          installed.

     f.   bipod.  Yes, Unique F11 fitted with bipod, bipods
          available as accessories for most others.

     g.   grenade launcher.  No.

     h.   night sights.  No.

     2.   Are the weapons semiautomatic versions of a machinegun?
          No.  All are conventional .22 rimfire actions assembled
          to resemble various modern military rifles.

     3.   Are the rifles chambered to accept a cartridge case
          having a length of less than 2.25 inches? Yes (.22 long
          rifle rimfire) Cartridge case length approximately 18/32
          of an inch in length.

[newpage]

     4.   How has the rifle been advertised/marketed. 1 Mitchell
          Arms Co. advertisement used.

     Advertising does not recommend specific sporting use. 
     Advertisements state rifles are military style look a likes of
     other famous weapons.

     5.   Technical Writers Descriptions:
     9 technical articles used.
     Guns & Ammo magazine, May 1968, page 58
     Gun World Magazine, July 1985, page 32
     Guns & Ammo Magazine, November 1985, page 72
     Gun World magazine, December 1985, page 28
     Guns Magazine, July 1986, page 21
     Guns & Ammo Magazine, January 1987, page 36
     Gun Digest Book of Assault Rifles, pages 160, 182 & 188

All of the technical articles discuss the military appearance,
construction, design, function, accuracy and disassembly of the
rifles.  The vast majority of the articles state that the rifles
are good for training use and are a lot of fun to shoot.

The May 1968 Guns Magazine article states "the Erma M122 should
make an excellent varmint a small game rifle."

The December 1985 Gun World Magazine article states that the French
F11 rifle is being offered more as a collector curiosity than a
trainer.

The January 1987 Guns & Ammo article states " Their lack of
refinement is forgiven by shooters who have discovered what
fabulous fun they offer plinkers, and their obvious aptitude in the
field as small game getters."

The Gun Digest Book of Assault Rifles Articles indicates camping
and survival use of the weapons.

ATTACHMENT 12

                          AKS VARIANTS

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 1 .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                              AK 47

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 6.
          b.   Number who recommend for hunting use 6.
          c.   Number who recommend for competitive shooting 4.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  3.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                            TYPE 56S

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.


                       VALMET M76 (HUNTER)

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 3.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                           VALMET M78

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                              GALIL

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 1.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                               FAL

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                            FAL L1A1A

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                            STEYR AUG

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0 .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 1.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                             FN FNC

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                             SAR 48

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0 .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 1.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                               UZI

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 1.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.

          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                          ALGIMEC AGM1

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                              AR180

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

               AUSTRALIAN AUTOMAITC ARMS SAR TYPE

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                          BERETTA AR 70

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               706.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                       BERETTA BM 59 TYPE

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                             H&K 91

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  7.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 4.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 1.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                             H&K 93

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 3.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 1.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.


                             H&K 94

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                           G3SA SAR-3

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                            DAEWOO K1

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                            DAEWOO K2

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                           AR 100 TYPE

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                              M14S

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0 .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                             MAS 223

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 1.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                         SIG 550 SP TYPE

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0 .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                         SIG 551 SP TYPE

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients  0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 0.

          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                               SKS

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 0.
          b.   Number who recommend for hunting use 0.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding 42.
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles 42.
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles 0.

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded 706.
          b.   Number of hunting guides who listed rifle as being
               used by their clients 0.
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use 0.

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded
               14.
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting 1.
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting 0.

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               53.  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition 0.
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition 53. **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                  AK 22 (IMPORTER SURVEY ONLY)

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding .
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles .
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles .

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded .
          b.   Number of hunting guides who listed rifle as being
               used by their clients .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use .

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded .
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting .
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting .

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               .  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition .
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition . **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

                 M 16/22 (IMPORTER SURVEY ONLY)

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding .
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles .
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles .

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded .
          b.   Number of hunting guides who listed rifle as being
               used by their clients .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use .

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded .
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting .
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting .

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               .  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition .
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition . **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

               ERMA EM1 22 (IMPORTER SURVEY ONLY)

     6.   What is the rifles reported use by importers?
          a.   Number of affected importers responding 1.
          b.   Number who recommend for hunting use 1.
          c.   Number who recommend for competitive shooting 0.

     7.   Do State game commissioners allow the use of the rifle to
     hunt?
          a.   Number of State Game Commissions responding .
          b.   Number of State Game Commissions who permit use of
               high power semi-automatic rifles .
          c.   Number of State Game Commissions who do not permit
               use of high power semi-automatic rifles .

     8.   Do hunting guides recommend the rifle?
          a.   Number of hunting guides who responded .
          b.   Number of hunting guides who listed rifle as being
               used by their clients .
          c.   Number of hunting guides who listed rifle as one
               they supply to their clients for hunting use .

     9.   Do hunting/shooting editors recommend the rifle?
          a.   Number of hunting/shooting editors who responded .
          b.   Number of hunting/shooting editors who recommend
               this type of rifle for hunting .
          c.   Number of hunting shooting editors who recommend
               this type of rifle for competitive shooting .

     10.  Is the weapon used in competitive target competition?

          a.   Number of hi power rifle associations who responded
               .  
          b.   Number of hi power rifle associations who listed
               rifle as used in competition .
          c.   Number of hi power rifle associations who indicated
               rifle was suitable for use in competition . **

* Use of rifle is permitted provided magazine capacity
restrictions, where applicable, are complied with.

** Permitted for use in the "Any Rifle" category.

ATTACHMENT 13

               Sources of Questionnaire Addressees

1. Editors of Sporting/Shooting Magazines -

     Gale Directory of Publications - 1989 (121st Edition)

2. High Power Shooting Associations -

     NRA List of Addresses from March 1989 issue of American
     Rifleman

3. Licensed Hunting Guides

     Lists furnished by State agencies and by professional Guide
     Associations

4. Hunting Associations -

     1989 Conservation Directory of National wildlife Federation
     (34th Edition)

5. Fish and Game Commissioners/Directors

     (Same as 4)

6. Importers -

     Those affected by the ban on importations

-- SeanNewton - 04 Mar 2010

Topic revision: r1 - 04 Mar 2010 - SeanNewton
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