FCAB April 2025 Meeting Notes
Long gun testing and roster:
The EOPSS attorney for the FCAB let us know that Secretary Reidy had approved the Board’s recommendation to exclude long guns from the testing requirements previously designed for handguns. The way this was accomplished was by utilizing the opening sentence in the Massachusetts gun law definition section. (Chapter 140, Section 121)
“Section 121. As used in sections 122 to 131Y, inclusive, the following words shall, unless the context clearly requires otherwise, have the following meaning”
The determination was that since the testing requirements in the handgun roster section of law would never work, and was not practical for long guns that the context did not apply. In short – there will be no testing requirements or roster for long guns.
Banned Assault Style Firearms Roster:
This continues to be a point of contention between GOAL and the rest of the FCAB members. GOAL reiterated at the April meeting that the draft did not meet the law nor does anything in the draft represent the current law. All we got was: “Noted” The consensus of the rest of the Board members is that you have to know what is no longer in the law in order to understand what is in the law.
The Board is working on a standardized form, potentially an online fill in type, that all the testing labs can use. Currently the labs create their own using the standards they must meet.
There was also a lot of discussion about potentially updating the “functional design equivalent” regulations. This is a path handgun manufacturer can use for models already approved that simply have a different color, grip, etc. While these guns don’t have to go through the rigorous testing, they still have to pay a lab to declare something a functional design equivalent.
There was also discussion surrounding the new Biofire gun that was approved at the March meeting. GOAL had brought several concerns about the testing requirements. Are the current methods of testing suitable for a handgun that has to be powered and will only function on biometrics?
The other glaring issue for the Biofire gun is that each gun is made to order. Unlike traditional handgun models that are, for the most part, manufactured the same in large numbers. So how does the state approve individual models?
Training Mandate:
The Board was informed that the new training requirements should be ready soon. The focus is going to be using the training programs that are already out there (NRA, USCCA, etc.) and just have them add the new requirements. We were told that they would all have to resubmit their course curriculums for approval.
There was also discussion concerning folks who had taken a course after August 1, 2024 but before the new courses were available. Initially the Board was told that before their next license renewal they would have to take some sort of supplemental course to fulfill the new mandates. GOAL suggested that those folks could be grandfathered by guidance or regulation. I was told that the law was very clear. GOAL pointed out that the state either ignores laws or interprets them as it fits their needs every day.
Non-resident Issues:
GOAL asked if the State Police has made any progress in creating a list of states that have “substantially similar” licensing requirements. The absence of this list drastically effects non-residents under Chapter 140, Section 129C (i) & (j).
(i) A nonresident who is at least 18 years of age may possess rifles and shotguns that are not large capacity or semi-automatic and ammunition therefor if the nonresident has a permit, card or license issued from their state of residence which has substantially similar requirements to those of the commonwealth for a firearm identification card as determined by the colonel of the state police pursuant to subsection (l)
(j) A nonresident who is at least 18 years of age may possess rifles and shotguns that are not large capacity or semi-automatic and ammunition therefor: (i) to hunt during hunting season with a nonresident hunting license or a hunting license or permit lawfully issued from their state of residence, which has substantially similar requirements to those in section 11 of chapter 131, as determined by the colonel of the state police pursuant to…
The hunting piece of this section is problematic as well. The drafters of Chapter 135 were ignorant of the difference between Massachusetts hunting licenses and the rest of the country. They were basing the language on the standardized Hunter Education nationwide. The problem is that Massachusetts requires anyone over 15 years old that hunts with a firearm to have an FID or LTC.
Handgun Frames:
GOAL inquired about handgun frames. According to the new law, frames (even unfinished) are now a firearm. However, like the long gun context, handgun frames will not be subject to the handgun roster testing requirements. We asked, if that is the case, then can retailers sell any handgun frames they want providing they are not assault style? The answer was yes but it probably doesn’t warrant mention in the guidance letters.
Meeting Venues:
GOAL has asked that future meetings be outside of the Boston area. We suggested using MassWildlife HQ in Westborough as an idea.
New Handguns:
Retay .22 Model: RXP22-BLK-10
Smith & Wesson .380 Model: Bodyguard 2.0
Keltec 9mm Model: P15
Heckler & Koch 9mm Model: VP9F
Long gun testing and roster:
The EOPSS attorney for the FCAB let us know that Secretary Reidy had approved the Board’s recommendation to exclude long guns from the testing requirements previously designed for handguns. The way this was accomplished was by utilizing the opening sentence in the Massachusetts gun law definition section. (Chapter 140, Section 121)
“Section 121. As used in sections 122 to 131Y, inclusive, the following words shall, unless the context clearly requires otherwise, have the following meaning”
The determination was that since the testing requirements in the handgun roster section of law would never work, and was not practical for long guns that the context did not apply. In short – there will be no testing requirements or roster for long guns.
Banned Assault Style Firearms Roster:
This continues to be a point of contention between GOAL and the rest of the FCAB members. GOAL reiterated at the April meeting that the draft did not meet the law nor does anything in the draft represent the current law. All we got was: “Noted” The consensus of the rest of the Board members is that you have to know what is no longer in the law in order to understand what is in the law.
- There are NO banned ASFs in Massachusetts. There are many that have restrictions on them, but none of them are outright banned. Publishing any such roster would not be keeping with the law that calls for a “banned” roster.
- The draft prelude to the roster now refers to it as “Prohibited” rather than banned.
- The draft continually refers to the 1994 date which no longer appears in Massachusetts law as it used to pertain to firearms. (The date still exists for magazines.)
- The draft treats the 2016 date as if it matters. They believe Chapter 135 “codified” the 2016 Attorney General’s guidance.
The Board is working on a standardized form, potentially an online fill in type, that all the testing labs can use. Currently the labs create their own using the standards they must meet.
There was also a lot of discussion about potentially updating the “functional design equivalent” regulations. This is a path handgun manufacturer can use for models already approved that simply have a different color, grip, etc. While these guns don’t have to go through the rigorous testing, they still have to pay a lab to declare something a functional design equivalent.
There was also discussion surrounding the new Biofire gun that was approved at the March meeting. GOAL had brought several concerns about the testing requirements. Are the current methods of testing suitable for a handgun that has to be powered and will only function on biometrics?
The other glaring issue for the Biofire gun is that each gun is made to order. Unlike traditional handgun models that are, for the most part, manufactured the same in large numbers. So how does the state approve individual models?
Training Mandate:
The Board was informed that the new training requirements should be ready soon. The focus is going to be using the training programs that are already out there (NRA, USCCA, etc.) and just have them add the new requirements. We were told that they would all have to resubmit their course curriculums for approval.
There was also discussion concerning folks who had taken a course after August 1, 2024 but before the new courses were available. Initially the Board was told that before their next license renewal they would have to take some sort of supplemental course to fulfill the new mandates. GOAL suggested that those folks could be grandfathered by guidance or regulation. I was told that the law was very clear. GOAL pointed out that the state either ignores laws or interprets them as it fits their needs every day.
Non-resident Issues:
GOAL asked if the State Police has made any progress in creating a list of states that have “substantially similar” licensing requirements. The absence of this list drastically effects non-residents under Chapter 140, Section 129C (i) & (j).
(i) A nonresident who is at least 18 years of age may possess rifles and shotguns that are not large capacity or semi-automatic and ammunition therefor if the nonresident has a permit, card or license issued from their state of residence which has substantially similar requirements to those of the commonwealth for a firearm identification card as determined by the colonel of the state police pursuant to subsection (l)
(j) A nonresident who is at least 18 years of age may possess rifles and shotguns that are not large capacity or semi-automatic and ammunition therefor: (i) to hunt during hunting season with a nonresident hunting license or a hunting license or permit lawfully issued from their state of residence, which has substantially similar requirements to those in section 11 of chapter 131, as determined by the colonel of the state police pursuant to…
The hunting piece of this section is problematic as well. The drafters of Chapter 135 were ignorant of the difference between Massachusetts hunting licenses and the rest of the country. They were basing the language on the standardized Hunter Education nationwide. The problem is that Massachusetts requires anyone over 15 years old that hunts with a firearm to have an FID or LTC.
Handgun Frames:
GOAL inquired about handgun frames. According to the new law, frames (even unfinished) are now a firearm. However, like the long gun context, handgun frames will not be subject to the handgun roster testing requirements. We asked, if that is the case, then can retailers sell any handgun frames they want providing they are not assault style? The answer was yes but it probably doesn’t warrant mention in the guidance letters.
Meeting Venues:
GOAL has asked that future meetings be outside of the Boston area. We suggested using MassWildlife HQ in Westborough as an idea.
New Handguns:
Retay .22 Model: RXP22-BLK-10
Smith & Wesson .380 Model: Bodyguard 2.0
Keltec 9mm Model: P15
Heckler & Koch 9mm Model: VP9F
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