Dear Director Pannella-

Please accept the following comments on the Commission’s proposed mixed martial arts (MMA) rules that were published at 36:3 Md. Reg. 219 (January 30, 2009).

Let me begin by complimenting the Commission on its formulation of professional and amateur regulations for mixed martial arts competitions. It is clear that the Commission has kept the safety of the competitors at the fore when drafting these regulations and I applaud its efforts. I do have some comments on the proposed rules as follows:

9.14.16 Mixed Martial Arts—Professional

9.14.16.09(F) describes the judging of matches, including “(1) A takedown from the standing position to a mount position;(2) Passing the guard to a mount position; and (3) A bottom position mixed martial arts contestant using an active, threatening guard.”

Those terms are confusing in that a takedown from standing rarely results in a mount position- a competitor would normally have to work to achieve a mount position. It is suggested that “a takedown from the standing position” would be more appropriate. To the extent that the defending competitor gains the guard during the takedown, that could be considered in awarding under defense, but the takedown should still be awarded even if it does not result in a mount. Similarly, in (2), the mount is a specific position and even though there are variations, it may be simpler to judge based on the generic “(2) Passing the guard and obtaining a better position.”

9.14.16.04. There is little regarding a competitor’s appearance; the Commission may want to give thought to requiring closely cropped or tied back head and/or facial hair and the elimination of jewelry and piercings.

The Commission may also want to consider whether to include the heel hook on the list of foul techniques due to the potential for knee injury before a competitor recognizes the danger and has an opportunity to tap. The technique is banned in some sport grappling competitions although permitted in many professional MMA competitions (this Commission included it on the list of impermissible techniques for amateurs) .

9.14.17 Mixed Martial Arts—Amateur

9.14.17.11(A)(2)
It appears that kicking to the head would not be a permissible technique, although it is not specifically impermissible per .12(A). I understand the heightened safeguards for amateur competitors, and eliminating punching to the head while the competitors are on the ground may very well be appropriate, but eliminating kicks to the head while standing seems unnecessary and excessive.

Amateur competitors are required to wear shin and instep padding, similar to amateur kickboxers in many jurisdictions. I would urge the Commission to reconsider allowing kicks to the head while standing in amateur matches. That allows for the occasional exciting attempt at a head kick and safely begins preparing amateurs for professional fights, which allow kicks to the head with no shin or instep padding.

9.14.17.11(B)(2)(a)-(c) limits ground submissions to chokes, “arm bars,” and straight leg locks. It may help to clarify or define what is meant by “arm bar” as that term would be commonly understood to mean only straight arm bars which work by hyperextending the elbow joint. Assuming the intention was not to limit the technique in that manner (some of the most common submissions in MMA are bent arm locks which attack the elbow and shoulder), perhaps the generic term “arm lock” would be clearer. Otherwise, if only the straight arm bar is the only arm lock being permitted for some reaon, it should be so stated to avoid confusion.

9.14.17.06(A) and (C) Because .06(A) has a super-heavyweight class of anything over 210 pounds, which is not really all that heavy, the Commission should consider either adding a heavier weight class or increasing the allowable weight differences (cannot exceed seven pounds difference per .06C). An eight pound weight difference may be an issue at 114 pounds, but is negligible at 280 pounds. One approach may be to add a larger weight difference for super-heavyweights or make it a percentage difference (say 3%-5%) rather than an absolute weight.

9.14.17.12(A)(14) “Holding onto the ropes; and” should be “Holding onto the ropes [or enclosure]; and”

9.14.17.12(B)(13)-(14) seem irrelevant because the match is already on the ground by definition:
(13) Slamming an opponent to the ground;
(14) Throwing an opponent out of the competition area;

Slamming an opponent to the ground is ambiguous considering that throws and take downs are permitted- the goal of many throws and takedowns are to slam the opponent to the ground. If something specific is meant it should be defined.

Thank you for considering my comments. I look forward to seeing safe and exciting MMA thrive in Maryland.

Sincerely,

Jason Couch