To: NY DEC, Joe Racette. email@example.com
Thank you for the opportunity to comment on the proposed rulemaking for Big Bore Air Rifles (Part 1, Section 180.3).
Only a lawyer could love the ambiguous language of the proposed rules. They would allow that a big bore air rifle "...may be used to take big game or wildlife that may legally be taken with a rimfire rifle." This statement is impossible to decipher, either due to poor grammar or poor logic. If it's the grammar at fault (specifically, the use of the word "or" followed by a complex statement), then it conceals an alarming, new allowance--that should not be made--for hunting big game with a big bore air rifle. On the other hand, if it's the logic at fault, then it contradicts itself.
The NY DEC summary of big-game hunting regulations (i.e. "deer and bear hunting regulations," http://www.dec.ny.gov/outdoor/8305.html), says that "It is unlawful to hunt big game with a firearm using rimfire ammunition." Working from this point, using plain logic, (with or without a knowledge of rifle ballistics) the natural conclusion would be that it should therefore be unlawful to hunt big game with a big bore air rifle.
Let me guess: of the following three alternatives, which one was the intended meaning of the proposed rulemaking?
Whichever meaning was intended, (or if some other meaning were intended), the proposed rulemaking should specify the minimum weight of an allowable bullet at 650 fps. It would be negligent and inhumane without that restriction.