TO:  Senator R. Fields, Senator C. Hansen,

Representative A. Boesenecker, and Representative J. Joseph

FROM:  Rionda Osman, League of Women Voters of Colorado

The Legislative Action Committee of the League of Woman Voters of Colorado supports SB23-279 Unserialized Firearms And Firearm Components.  We have adopted this stance because the League of Women Voters supports policies to protect the health and safety of citizens through limiting the accessibility and regulating the ownership of handguns and semi-automatic weapons and to support regulation of firearms for consumer safety.

We believe that this bill supports that position.

As this bill moves through the Senate Committee of the Whole and into the House, we ask you, as a sponsor, to consider the following discussion points:

-- One member makes the following detailed suggestions: 

• p 4 lines 6-12 on 3D printers:Delete everything after "additive manufacturing process" -- The definition thus becomes a little more flexible and broader. For example, in addition to resin, there are 3D printers that can print metal.
• p 8 line 13 retaining serial number records:There's nothing about how long the records of newly created serial numbers need to be kept. I'd advise they be kept as long as federally licensed firearms manufacturers need to keep records of serial numbers on firearms they make. One source referred to27 CFR 478.123but I couldn't find the retention schedule there.

Note:  According to APRIL 11, 2022 FACT SHEET: The Biden Administration Cracks Down on Ghost Guns, Ensures That ATF Has the Leadership it Needs to Enforce Our Gun Laws [ https://www.whitehouse.gov/briefing-room/statements-releases/2022/04/11/fact-sheet-the-biden-administration-cracks-down-on-ghost-guns-ensures-that-atf-has-the-leadership-it-needs-to-enforce-our-gun-laws/ ]

…the final rule requires federally licensed firearms dealers to retain key records until they shut down their business or licensed activity. At that time, these dealers must transfer the records to ATF, just as they are currently required to do at the end of licensed activity. Previously, these dealers were permitted to destroy most records after 20 years, making it harder for law enforcement to trace firearms found at crime scenes.  According to ATF’s National Tracing Center, on average more than 1,300 firearms a year are untraceable because the federally licensed firearms dealer destroyed the relevant records that were more than 20 years old.

• p 8 lines 2-4 how to format the serial number:  It may be that ATF requires privately manufactured firearms to be imprinted with the full license number as a prefix to the serial number, rather than the abbreviated license number required in the bill. Recommend this bill be consistent with ATF's requirement27 CFR478.125(i)

-- Another member seeks an amendment that would require all firearms to be serialized – not simply those after 1968.

-- Another member suggests that we need an amendment to pay for the cost of serializing currently unserialized firearms. 

I would be happy to discuss any of these proposed changes to the bill, as well as any assistance the League or I can offer. 

Thank you for your service.