The Firearms Coalition has provided an alert about the proposed BATFE Obama administration rules. The new regulations would make the application for trusts and companies to obtain federal tax stamps for gun mufflers (silencers, suppressors)short barreled rifles and shotguns, full-auto guns and a few other items, considerably more convoluted. The Firearms Coaliton supplied a sample comment in an article at Ammoland to use as reference for comments, which can be made here. I found the proposed rule change comment section with a search for NFA trust at that link, and by clicking on the Comment Now button on the right side . . .

After reviewing the Firearm Coalition comment, I decided to write my own. Feel free to use it or to take points from it as you choose.

These proposals attempt to provide solutions for problems that are non-existent.   The existing problem with the regulations is that they are non-responsive, result in unreasonable waiting times, and create barriers to good safety practice.  I have not heard of a single example of criminal misuse of these items that resulted from NFA trusts or companies.   The excessive federal regulation on gun mufflers, suppressors or silencers, has caused millions of people to have substantial hearing loss, a federally mandated health disaster.  The regulations on short barreled rifles and shotguns, given the Supreme Court decisions in Heller and McDonald, no longer make any rational sense.  To make them even more intrusive and complex is bad policy, on the edge of irrationality. 

The BATFE currently handles the annual caseload of about 30,000 transactions poorly, with delays of six to nine months.  Instead of potentially doubling this caseload for frivolous political reasons, the administration should be looking to eliminate the requirement for these intrusive and unnecessary checks on items that are treated no differently than common firearms or accessories in many European nations.  In Finland, for example, gun mufflers, suppressors or silencers are considered a constitutional right.   No crime problems have resulted from this.  Short barreled rifles and shotguns are functionally no different than handguns, possession of which has been ruled to be a constitutional right in the United States.  They should be treated the same as handguns.   If these actions were approved, the wait times for other applications could be handled in a timely manner.

The current Chief Law Enforcement Officer certification requirement should be done away with completely.  At present, local officials are able to stop individuals  from obtaining federal licenses based on nothing by individual bias,  discrimination, an unwillingness to process the forms, or simple caprice, without any appeal.   The proposed rule changes would extend this affront to the rule of law to trusts and companies as well.

The citizens that apply for these “tax stamps”, which are in fact, poorly disguised licenses, have been shown to be the most law abiding of the top 10 percent of the country.   They should not be punished for the remarkable safety record that they have established.   There is no rational basis to make these regulations more restrictive. 

After submitting the comment, you will be given a tracking number to track it through the system. My tracking number is: 1jx-88wl-w71t.

When we push to remove these frivolous infringements on the Second Amendment, we will be able to show that they were opposed by large numbers of commenters, but only if we bother to make a comment. Comments close on December 9th, so now is a good time to get yours in the system.

©2013 by Dean Weingarten: Permission to share is granted when this notice is included.
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44 Responses to Still Time to Comment on Proposed Regs on Suppressors, SBRs and NFA Trusts

  1. If this is anything like most government run ‘civilian input forums’, it will be cheerfully and courteously received and then dumped immediately into the nearest trash can.

  2. They don’t give a damn what we have to say, Obama has already told them what rules he wants and those are going to get passed.

    Our only recourse is winning in 2016 and getting sanity back in the White House.

    • “Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment.”

      Yea, I’m confident they will take my opinion into consideration…

  3. Done and done. It’s a lot easier to be marginalized if you don’t make the attempt. It’s worth the 5 minutes (or 30 seconds if you cut and paste).
    Mine’s: 1jx-88y2-h5jj

  4. Don’t forget, there is also the “no re-importation of US made weapons (i.e. WWII garands and M1a carbines) as well. Remember, these were the exact same weapons that even Sen Feinstain made exempt in her last gun-ban bill.

  5. The comments on these proposed infringements, including mine, do not a rosy picture paint. In the vast majority of counties in the U.S., they would in fact institute of a de facto ban on NFA items.

    Even given the lukewarm decisions in our favor in McDonald and Heller, I seriously doubt we would get a win over this before the SCOTUS — the same people who gave us the Three-Fifths Compromise and Citizens United, and even told us that somehow the Patriot Act and the ACA were legal (which they are quite clearly not).

    Our government ceased to care about the concerns of We, The People long ago. Long before any of us were a twinkle in our daddy’s eyes, in fact. These measures will likely be passed with all possible speed regardless of who has majority control in Congress, or who is in the White House, or who gets appointed to the SCOTUS, or any of the lower appellate federal and state courts. They’re all playing for the same team, and they sure as shit ain’t playin’ for ours — I can guaran-gotdamn-tee you that.

    • The 3-5s compromise wasn’t SCOTUS, it was written into the original Constitution as, well, a compromise, between slave owning states and non-slave states. Slave states wanted slaves to be counted in full for representative purposes so they could stack the deck in the House and as such, prevent legislation they viewed as bad to slavery while at the same time didn’t want the population counted for tax purposes. Obviously, non-slave states didn’t want them counted for representation, but wanted them counted in full for tax purposes so southern states paid more.

      The compromise was 3/5s of slave population was counted, and no anti-slavery legislation for the first 20 years.

  6. Comment left. It’s sad to see there are only 2,7xx comments thus far. There should be 200,000+. I guess most people don’t understand what’s a stake.

    • I don’t think a lot of people know they can provide input! Best to leave a few reminders and links on your local pro-gun forums.

    • I think a lot of people don’t want to sign the “Hey government, I have a gun!” list they’re inevitably compiling as a part of soliciting comments.

    • I’ve commented a few times. Also, it says 2,967 as of midnight last night. Definitely not enough. 🙁

      Honestly, I think 100,000 could comment saying their opposed rules are junk and they’d still do it. Not a good feeling to have.

      • They could get millions to comment and it wouldn’t do a damn bit of good. They don’t care about us. We’re nothing but walking ATMs as far as they care.

  7. Representative government theater continues, I see. Keep pretending like your voice matters and that your governmental overlords consider anything against their tyrannical agenda.

    Gun rights advocates as a whole are stuck in the mud right now, still clinging to the idea that “going through the system” works. It’s understandable; we’re Americans, we’re law-abiding, we like to believe that a “free country” still exists in here somewhere. The simple fact is it doesn’t, and your voice matters to the government about as much as a peasant’s life mattered to Stalin.

    But keep writing letters to your lords. See how well it works.

    • Okay, but only as long as you keep us posted on the whole “armed insurrection” thing. How we doing, by the way? Did the rebel forces retake Los Angeles yet, or is it still occupied territory?

    • And one that is well designed and effective so definitely a nice match for the similarly well designed and effective Glock. The design of the Osprey suppressor in that picture is superior when it comes to using with standard height sights and offers better suppression than a normal cylinder design option until it is too large to use with anything but raised sights or possibly at all on a Glock. This “ugly” setup is one of the sweetest configs I have ever used. Oh well looks are all that matters. Better sell it off 🙂

      • This comment approved by PhoenixNFA.

        The osprey is a good bit of kit, if only a BIT leaky around the seams. Oh well, it’s light (aluminum) and looks good.

        An osprey on an HK USP is a pretty damn good combo.

  8. In my option not that it really matters I believe that suppressors should be treated like a striped lower for an ar15. When you buy it, show your ID, fill the form for the background check and wait for the ATF to do the stander N.I.C.S. check. Once you done and come cleared of a N.I.C.S check you can pick up your new suppressor. Now of course you local and state laws will affect this depending on where you live.

  9. Pleading with this administration not to violate our rights is like asking Hannibal Lector not to eat us. They are going to do it, they can do it, and they will do it. Why? Because it is a way to get around Congress since that is a stalled front on their war on Freedoms.

    As for trusts being used in crimes; Christopher J. Dorner, the former Los Angeles police officer who embarked on a personal war against the agency used a trust to purchase asuppressor and a SBR in Nevada when we was a California resident. So yes, sadly they have been used in crimes.

    I am against trusts not because of this but because I believe Suppressors, SBSs, SBRs, and AOWs should be over the counter items. Have the dealer collect the tax, call in the background, hand the purchaser a form with an approval number and he/she can walk out the door with his/her purchase. I have a trust because where I live no CLEO will sign off. I hate it… I hate the fact that I had to resort to a trust to simply enjoy the hearing safety that a can provides or that a four inch piece of barrel is missing.

  10. Whatever happened with the comments that were solicited about loosening the AP ammo rules back in 2012? It’d be nice to get in some cheap 7.62×39 again.

  11. Done. Followed the topics of the sample comment, but composed it myself. I don’t think copy/paste comments have as much as an effect as individually-tailored comments. I can imagine people glossing over the robo-comments and disgregarding them. Or perhaps they log them under generic categories (levels of support/non-support perhaps) and use the statistics to tailor changes to the proposals, or the decision to enact/recall the proposals.

    Anyone know how it all works?

  12. You mught want to commet on the eps adding unattainable air standards to close the only lead re fining plant in the US at the end of Dec 2013. Get your lead now. You know, they are working under the radar.

    • Completely mythical. Even the ammo manufacturers have stated that the vast majority of the lead they use comes from auto battery recyclers and not virgin lead.

  13. So, the grabber argument will be: the fact that NFA items aren’t used in crime is proof the regulations work.

    Because correlation implies causation.

    The mind of a grabber is a scary place….

  14. Regulations.gov is garbage.

    When you comment – they want all your information. First and last name and home address. That is really all they need to identify everything about you (cross referrenced from the FBI records). Funny we go to regulations.gov to complain about excessive tracking and traceability of items that we otherwise have a “right” to keep and bear but also have to fill out excessive information for the use of tracking and traceablity to make the comment itself. Better be careful what you say there – or there could be agents kicking down your door at 3AM for a charge they could otherwise make up.

    • I especially enjoyed this:

      Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment.

  15. Suggestions I have seen on how to actually mess up the issuing of the regs (By Prince and Goldman) are to show that the financial calculations are WAY off on the low end and/or that there is in fact a very substantial impact to small businesses. The ATF handwaved these issues as they trigger a much more complex process if true. So if you can present a good case for either it forces a much more complex (slower) rule making process to be used.

    Look at the end of the Federal Register posting, it explains how to submit comments that don’t include all your personal data if this is an issue for you. Essentially you mail it in, with a cover sheet that has your info and then on the actual comment you can just provide whatever you want. Though your name will always be included publicly.

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