THis approach is unnecessary as the definition of "variant" could be interpreted by a reasonable person already. Forcing a showdown like this will potentiallly open more cans of worms.
I think this is a pure administrative issue that can be done rather quietly under the radar, instead of a grassroot campaign of mass mail.
This is obviously a mistake in the reading and intrepertation of the regulation - it doesn't need to be escalated to freedom of access act.
Civil servants hate, absolutely hate, producing information for freedom of access request. THey much prefer to correct their mistakes quietly and I think this is the right way for this particular issue.
The problem here, as Blair pointed out, is the fact that the federal firearms bureaucracy are ALL LIEBERAL appointees. They have a stake in preserving the status quo, or even helping to put additional bans in place. They're a big reason Bill C-21 sucks so badly.
The Conservatives have shown that they're quite willing to essentially take gun owners for granted while they remain in a minority position. They "know" that gun owners will continue to vote Conservative, simply because they're the only real alternative we have. As such, the CPC has been perfecting their carrot-and-stick routine since taking power, making lots of promises, but not following through because of the political realities of the situation. Wonder why legislation to eliminate the long-gun registry wasn't included in their Omnibus Crime Bill?
The CPC isn't going to open up the whole gun control can of worms before another general election. There's some hope that if/when they win a majority, they'll remember us, but until then we're in limbo...hoping that no additional Dunblane/Port Arthur/Montreal mass shootings takes place in Canada that will force the government to act precipitously.
So, expecting the CPC to handle things quietly and to reclassify AR-15s via OIC isn't realistic. They could've done the same thing last year and made ATTs permanently part of your RPAL and they could've solved the 12(x)/SAP mess the same way, but they didn't. The CPC is simply focused on looking out for number one: the CPC and their goal of forming a majority government. Until that happens, the best we can hope for is to keep the pressure on them and to keep fresh in their minds that gun owners eventually expect them to make good on their promises, however, that support does have an expiry date.
If the CPC were really pro-firearm, they could've done something to solve some of the more aggregious facets of the gun control program like the ATT issue, just like Joe Clark did while he was in minority territory on the question of AR-15 classification. That said, I think we all must remain vigilant and to not assume that the CPC are our best buddies. They're our "friends" just as long as our money and votes are important to them. If there comes a time when our "support" becomes more politically damaging to the CPC than beneficial, they'll cut us loose without a second thought.
As for organizing a black/green/service rifle owners association, I'm all for it, as unfortunately, one of the realities of the recreational firearms community in Canada is the fact that there are so many self-interested cliques within our firearms community. i.e., hunters are only interested in protecting hunting firearms, trap shooters only interested in their sport, etc...(I'm not saying all are like that!) As such, I think that an association devoted solely to the protection and promotion of rifles like the AR-15, AR-10, PE-90, AR-180B, etc...would definitely be helpful. National organizations like the NFA & CSSA are fighting for all gun owners rights, but too often, they must pick and choose their battles strategically or simply lack the resources to fully commit to such a narrow fight as "black rifles."
Also, what has really been damaging to us has been the consistantly negative portrayal of so-called "assault weapons" in the print and tv media. Assault Weapon has become the boogeyman of the pro-gun control movement in North America, and far too often we see fellow gun-owners getting on TV and spouting off how they don't see any need for those "evil" "machine guns" that they can't hunt with anyway! Anybody remember gun-writer Jim Zumbo?
To proceed, we need to define our mission, our goals, association structure, create a constitution, elect officers and form a legal not-for-profit entity (i.e. incorporate) & start fund-raising to pay for our lobbying & education/awareness campaigns.