In addition to spending heavily on elections and lobbying Congress, the gun lobby is also quite active in the rulemaking process, federal dockets show. The National Rifle Association, other pro-gun groups and their members weighing in frequently on federal regulation covering issues ranging from wildlife to concealed weapons to air travel. Gun control groups and advocates have also participated, although it appears less frequently.
A profile of NRA activity in federal regulations, from the Sunlight Foundation's Docket Wrench tool in development, shows efforts concentrated largely on hunting and other regulations administered by the Fish and Wldlife Service (FWS). However the NRA and members also show much activity on the docket of the Occupational Safety and Health Administration (OSHA), which in 2007 was considering rules on regulation of explosives. Meanwhile, the profile of the Brady Campaign to End Gun Violence shows much less frequent involvement in the federal rulemaking process.
It's important to note that this is likely an undercount, as the data available, which comes from the government website regulations.gov, does not follow uniform standards. One of the biggest problems is that organizational names and affiliations are not standardized, so it is difficult to follow the activity of any particular group definitively.
However, a portrait of a very active gun rights membership nevertheless emerges. More than 127 letters appear to have been submitted by the NRA and people associated with the group to the Fish and Wildlife Service. Many of the letters appear to have arrived in 2008 from NRA members concerned that the FWS should permit the carrying of concealed weapons on Park Service and FWS land as consistent with state law. This followed activity in Congress: in December 2007, 47 senators from both parties wrote the agency and the Department of the Interior asking that they "remove their prohibitions on law-abiding citizens from transporting and carrying firearms on lands managed by these agencies," noting that the current regulations "infringe on the rights of law-abiding gun owners." The FWS' final rule, issued in December 2008, modified regulations to permit the carrying of concealed weapons where legal under state law.
On at least two recent occasions, the NRA has weighed in directly on hunting regulations. An August 2011 letter from the NRA's executive director, Chris W. Cox, urges the Fish and Wildlife Service (FWS) to refrain from adding greater protection under the Endangered Species Act of U.S. captive-bred addax, dama gazelle, and scimitar-horned oryx, all types of antelope. In January 2012, the FWS issued a final rule which nevertheless expanded protections for these animals.
The NRA had more luck with a 2011 letter supporting a FWS proposal to open the Crane Meadows National Wildlife Refuge in central Minnesota to deer and turkey hunting, and asks that the agency expand hunting to nine other refuges around the country. The FWS later did open the refuge to such hunting, and this year expanded hunting opportunities on 16 more refuges.
People associated with the NRA also were active in 2007 when OSHA proposed new safety regulations governing explosives. At the time, the NRA's Institute for Legislative Action criticized the agency for overreaching, saying that "the proposed rules include restrictions that very few gun stores, sporting goods stores, shippers, or ammunition dealers could comply with." A number of the letters sent to OSHA appear to be inspired by the National Shooting and Sports Foundation (NSSF) which issued an alert that contained language such as, "These proposed rules would impose severe restrictions on the transportation and storage of small arms ammunition—both complete cartridges and handloading components such as black and smokeless powder, primers, and percussion caps." In July 2007, the NRA reported that OSHA had backed down in the face of "strong opposition" from the NRA.