Here is a copy of the comment I sent last Friday. That said, I think that a much much simpler comment would work just as well without all the words I put into mine.
"April 27, 2018
The Honorable Dennis Richardson
Secretary of State
Elections Division
255 Capitol Street NE, Ste. 501
Salem, OR 97310-0722
Re: Public Comment on Initiative Petition 43 (2018)
Dear Secretary Richardson:
I write as a registered Oregon voter and am providing the following comments on the draft ballot title for Initiative Petition 2018-43 (IP-43).
The Attorney General has proposed the following summary as part of the ballot title for IP-43:
Summary:
Measure criminalizes possession or transfer of “assault weapons” (defined)/ “large capacity magazines” (defined) except for military/ law enforcement purposes, or persons authorized by State Police after criminal background check. Otherwise possession or transfer is a Class B felony. Within 120 days, persons lawfully owning such weapons or magazines must remove from Oregon, lawfully sell, surrender to law enforcement, render inoperable, or register items with State Police. Applies to inherited items. Bars moving covered items into Oregon. Assault weapons include certain semiautomatic rifles or pistols with a detachable magazine; pistol or rifles with a fixed magazine holding more than 10 rounds of ammunition; certain semiautomatic shotguns. Large capacity magazine is ammunition feeding device with capacity of more than ten rounds. Effective January 1, 2019. Other provisions.
The draft summary does not comply with ORS 250.035 (2)(d) for the reasons discussed below.
Section 3. (1)(a)(A)(iv) of IP-43 provides that:
(1)(a) “Assault weapon” means any:
(A) Semiautomatic rifle that has the capacity to accept a detachable magazine and has at least one of the following:
(iv) A shroud attached to the barrel, or that partially or completely encircles the barrel, allowing the bearer to hold the firearm with the non-trigger hand without being burned, but excluding a slide that encloses the barrel.
Virtually all rifles of any action type including semiautomatic rifles have a means that allows the “bearer to hold the firearm with the non-trigger hand without being burned.” Normally this part is referred to as part of the rifle stock. This means that all semiautomatic rifles with a detachable magazine and a rifle stock would become “assault weapons” since all rifles have a stock that would allow the “bearer to hold the firearm with the non-trigger hand without being burned.” The last phrase of Section 3. (1)(a)(A)(iv) of IP-43 “but excluding a slide that encloses the barrel” is without any clear meaning since a “slide” is a feature found on semiautomatic pistols not rifles and further that on such pistols it moves rapidly with every shot, can get hot, and thus the bearer would not be able to hold it with the non-trigger hand.
Thus the wording of IP-43 Section 3. (1)(a)(A)(iv) would designate all semiautomatic rifles with a detachable magazine as “assault weapons”. The draft Summary statement should be modified to reflect this reality.
I respectfully suggest the following:
Summary:
Measure criminalizes possession or transfer of “assault weapons” (defined)/ “large capacity magazines” (defined) except for military/ law enforcement purposes, or persons authorized by State Police after criminal background check. Otherwise possession or transfer is a Class B felony. Within 120 days, persons lawfully owning such weapons or magazines must remove from Oregon, lawfully sell, surrender to law enforcement, render inoperable, or register items with State Police. Applies to inherited items. Bars moving covered items into Oregon. Assault weapons include certain all semiautomatic rifles, many semiautomatic pistols with a detachable magazine; pistol or rifles with a fixed magazine holding more than 10 rounds of ammunition; certain semiautomatic shotguns. Large capacity magazine is ammunition feeding device with capacity of more than ten rounds. Effective January 1, 2019. Other provisions.
I have highlighted the proposed changes that change the word “certain” to “all” add a comma and the word “many” and delete the word “a” in that same sentence. The changes I propose appear to have no net change in the number of words in the Summary.
Thank you for your consideration.
Sincerely,
David Brown"
What is important is that you get the signed comment to the SoS by COB 8 May via US Mail, FAX, or by email. You will need to include contact information (your address, or FAX back number, or your email) so they can contact you to verify or other communication.
Also, I do not think it is necessary to provide a draft of what you would like the draft ballot title to say. Remember that your comment will become part of the public record.