ATF bump stock ban comment period
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UPDATE: The comment period for letting the ATF know your feelings about regulating bump fire stocks (and probably binary triggers, too) like machine guns closes at midnight tomorrow. A little over 82,000 comments have been entered so far. You can read the ATF’s proposed rule and let your opinion be known here or click the image below.

Here’s the original post we ran on this including the VCDL’s email call to arms . . .

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In response to pressure from President Trump, Attorney General Jeff Sessions announced a proposed a new rule which would regulate bump fire stocks like machine guns. That new rule is now open for public comment.

The Virginia Citizens Defense League sent out an email blast letting gun owners and anyone who cares about arbitrary regulation by government fiat know how to let their voices be heard. Here’s the text of their email:

The bump stock rule is now written and comments from citizens can be submitted. If implemented, this is a true ban, which classifies bump stocks as machine guns! No grandfathering of existing items. They must be destroyed or turned over to the police, with no compensation for the taking of your property that was lawful when you purchased it. The penalty is up to $10,000 and/or up to 10 years in jail.

Regardless of whether you own a bump stock or not, or whether you love them, hate them, or are indifferent toward them, we need to oppose this rule.

The government is not providing a valid reason to suddenly consider bump stocks as machine guns. Their reasoning is clearly political and nothing more, totally failing the smell test.

In the proposed rule, BATFE brushes off the idea that firing a semi-automatic rifle with a bump stock is no different than bump firing that same rifle using only one’s bare hands. (Video of me doing just that can be seen here:

Here’s what the BATFE writes about the supposed “differences” between firing with a bump stock vs bump firing with your bare hands:

“The relevant statutory question is whether a particular device causes a firearm to ‘shoot … automatically more than one shot, without manual reloading, by a single function of the trigger.’ 26 U.S.C. 5845(b).”

“Bump firing and other techniques for increasing the rate of fire do not satisfy this definition because they do not produce an automatic firing sequence with a single pull of the trigger. Instead, bump firing without an assistive device requires the shooter to exert pressure with the trigger finger to re-engage the trigger for each round fired. [PVC: “Pay no attention to the man behind the curtain!” That’s exactly what a bump stock does. Pressure from the trigger finger engages the trigger after each shot to fire the next one. With either method my finger stays stationary, while the gun bumps the trigger into my trigger finger and fires again. Nice try, though, BATFE!]

“…the bump-stock-type devices at issue cause the trigger to “bump” into the finger, so that the shooter need not pull the trigger repeatedly to expel ammunition.” [PVC: Again, that is exactly how bump firing a gun with one’s bare hands works.]

“…Because these bump-stock-type devices allow multiple rounds to be fired when the shooter maintains pressure on the extension ledge of the device, ATF has determined that bump-stock-type devices are machinegun conversion devices, and therefore qualify as machineguns under the GCA and the NFA.” [PVC: It is still the trigger finger that activates the trigger, not any part of the bump stock. All that the extension ledge does is to hold your finger in a fixed position, same as if you hold it stiffly yourself when bump firing with your bare hands. BATFE hopes we are stupid enough not to see there is no difference in how bump firing works, with or without a bump fire stock.]


Click this link to get to the proposed bump stock ban rule:

You can read all the text of the proposed rule at this point, if you wish.

To enter a comment against the proposed rule, click on the blue “Comments Now!” button in the upper right corner of the page.

Suggested comments:

“I fully oppose this ruling. The shooter’s trigger finger is what activates the trigger, whether firing with a bump stock or with one’s bare hands. No part of the bump stock touches the trigger, only the shooter’s trigger finger. ATF’s insistence otherwise is merely playing politics and hurts their credibility.”

“I fully oppose this ruling. If the bump stock made a semi-automatic rifle fully automatic, then holding the gun with only the trigger-finger hand while squeezing and holding the trigger should cause the gun to repeatedly fire shots. It doesn’t do that and therefore the bump stock has clearly NOT converted a semi-automatic rifle into a machine gun.”

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  1. If they “regulate them like machine guns”, does that mean the full-auto registry will be re-opened?

    *snicker* 😉

    (Fire up a 3-D printer for that Glock select-fire kit, send them $200 and get it registered as a ‘Bump-Stock’…)

      • An understanding of the B.A.T.F. creation by regulatory sleight of hand and ” name changes ” in the years since prohibition , is now more important than ever.

        They can and should be challenged on grounds of NO jurisdiction , and operating under ‘ color of law .’

        ” Walker created the [Bureau of Alcohol, Tobacco, and Firearms] from the [Alcohol, Tobacco and Firearms Division] of Humphrey’s [Internal Revenue Service]. He then says, that, what was transferred, is the same ENTITY as the [Commissioner of Internal Revenue]. He KNEW he could not create something from nothing without the AUTHORITY OF CONGRESS and/or the President, so he made it look like he did something that he had, in fact, not done. TO COMPOUND THE FRAUD, the FEDERAL REGISTER PUBLISHED the unbelievable assertion that a PERSON HAD BEEN REPLACED WITH A THING; ” the term Director Alcohol, Tobacco, and Firearms Division has been replaced with the term Internal Revenue Service.”

        BATF – criminal fraud :

  2. Again, a very important thing has been glossed over. ATF has said that they are not counting form letters , comments with profanity, or general statements of disagreement with the proposal as a comment (so no “molan abe!” Or “shall not be infringed” types)

    Please read the closing paragraphs of the actual proposal. They clearly state the comments must be on the legal basis of the proposed reclassification.

    • All the comments they will actually read probably came in in the first few weeks. When I checked the other day, all the most recent stuff was either “Reee!! Ban Guns!!” or “Muh Rights!! Shall not be infringed!!”.

    • Pretty sure quoting the supreme law of the land is a legal argument. It’s pathetic that these paste-eating communists are even tolerated in our society, much less allowed to create sophistries and tautologies out of our laws and rights.

  3. Great article one of the most pressing and insidious efforts against us at the federal level right now. Regs and bank discrimination are where the fight is at.

    “Suggested comments”
    DO NOT simply copy anothers’ comments, you lazy bones! It’s simple to query the data for duplicates, and discard them. This is not a vote, this is not democracy, this is an opening salvo of a court challenge to strike the rule.

    Trump has already said this gun control is a foregone conclusion, but that’s no reason to fail to publicly petition the king for redress. It’s also important we contact our reps, since like many gun owners, even the friendlies are pretty clueless and don’t realize the ramifications.

  4. I made my comment long enough ago that I don’t remember exactly what I wrote, but the biggest point I made was that they’ll be opening themselves up to a massive number of suits if they try to pass something like this on a federal level. There have been a lot of arguments for and against using ex post facto and “confiscation without compensation”, but I think they’re legitimate points that could take years for the courts to even make a decision on whether or not they apply to this situation. Also, that if a bump stock is “redefined” as a machine gun, then the fundamental language of the NFA/GCA would have to be rewritten, and I believe that would require an act of congress…?(correct me if I’m wrong). As well as, if bump stocks are going to be “redefined” as machine guns and “registered”, than the machine gun registry would have to be reopened, which I can only imagine many politicians would rather die than let happen.

    • They are not being registered. They are being declared contraband. Owners will have to surrender or destroy their bump stocks to be in compliance after some sort of grace period. Then examples will be made.

    • You are correct. Changing even one word of the NFA definition would require an act of congress. That’s the strongest challenge to this silliness. As for registry… don’t get your hopes up, they will be in full-on confiscation mode. Mind you, I expect hundreds of suits to drop the day this goes live with preliminary injunctions to follow. It’s hard to argue that enforcing this regulation would not cause irreparable harm to the plaintiff. This will be tied up in courts for years if it even makes it that far.

      • Those will be years where bump stocks are either actually or effectively contraband; mission accomplished.

        • Read Hollis v Holder/Lynch. Courts will not issue an injunction protecting machineguns. They see too much liability in the freedom, and see the restricted state as the “safe” state for settling the issue.

        • Case not on point. Try again. Besides, we can file hundreds of suits with hundreds of judges. One of them will issue an injunction. We only have to win once.

      • That’s the point I just made in my comment to the ATF.

        There’s no way around the fact that the finger must depress the trigger anew for *each shot*, which means that a bump stock is clearly not a machine-gun device under the letter of the law. And only Congress gets to change the law.

        At least, that’s the way it’s supposed to work in America. If the ATF wants this to not be America anymore, then they can go ahead and start changing the rules every time some politician wants to Do Something ™ and eventually we might find out exactly how many bullets (bump-fired or otherwise) it takes to make America America again. (I didn’t put this part in the comment.)

        • I totally realize that confiscation is unfortunately a strong option for them, but I just wanted to make it clear in the comment I left with the ATF that regardless of which route they may take it’ll be a PITA for them, hopefully enough to reconsider. I personally don’t have a bump stock, but clearly see the slippery slope it represents. Here’s a case where I’d be willing to hypothetically “compromise”, sure, we’ll give up bump stocks, if you give us the HUSH act, take SBR’s off the NFA, or give us National Reciprocity. But I think we’d be more likely to get a balanced federal budget than a “compromise” like that!

  5. Oh, this rule change can be easily understood to include high capacity magazines that weren’t part of the original gun design, such as drum magazines or belt feed conversions. Even ‘unusual’ high capacity stick mags like the Surefire 100s used in the Vegas shooting could be at risk.

    “No, they wouldn’t lie to us by saying they were only targeting those stupid bump stocks, would they?”

  6. Dropped my comment in my own language addressing 4 constitutional issues with this rule. All four are now subject to litigation.

  7. Wait, maybe I’m hosed. I haven’t used one. I thought that the bump stock allows the gun to go back far enough for the trigger finger TO COME OFF of the trigger?

    Bump stocks cure satanic communist POS (D) and should be enshrined in our gun usage history even after they re-open the Post 1986 full-auto ban rolls.

    • Wrong. No grandfathering, no registration. AWBs have spoiled people into thinking that’s how these bans operate. Sorry, I’m afraid you’ll have to actually stop this one if you want to keep your semiautos.

  8. Sadly, their mind is already made up. I’ve noticed, on several forums, comparison being made the the proposed rule change on XM855 ammo. In that case, there were only 2 letters to the ATF that mattered. The first was from the United States Senate, signed by all Republican Senators, with the exception of now unemployed Mark Kirk, and a companion letter from the House of Representatives, signed by a majority of members, mostly Republican, but a few pro gun Democrats signed on.

    That congressional support is lacking from this effort. Most members want bump stocks banned, but don’t want to suffer the fallout from the pro gun side, nor incur the wrath of the Parkland faction if they voice support for keeping them legal.

    If the ATF manages to slow walk their final decision until after the November election, and the Republicans retain control of both houses, there’s a slim chance that the matter will quietly drop, but I wouldn’t bet on it.

    Timing is everything. The Sandy Hook massacre occurred about 6 weeks after election day, so there was a nearly 2 year cooling off period. This time is different.

  9. I am not sticking my hand into a hornets nest when i know theres hornets in it. ( eye blinking unamused face stearing at you ) becides i like to know where every shot is going when i let it lose .
    no skin in this game .
    To be totally fair to everyone; i do think you should have a regular batf application process back ground cheack to ‘licence it as a ‘bump stock michine gun devise ‘ with a free BATF ruling Rubber stamp (later registered sales will need $200 tax stamp) and an amnisty period of a few years to get the paper work done on ANY ITEMS ALLREADY MADE , IN INVENTORY, SOLD or in any ones posession as of the rule change date.
    INSTEAD of a screw you ban. AND a full page decribing each and every gun accesssory type that is affected by this rule change with pictures ect of any devise that should be applied for that could be out there .
    (Thats what was done with street sweepers and other shot guns for a batf ruleing change that made them ‘destructive devices’ )

    IF you like this thought feel free to pass it along as your comment as instructed to BATF with your name and address on the cover sheet as per there instructions ect.

    • And if your aunt had balls she’d be your uncle.

      Also, why should anyone waste their time copying your illiterate and irrelevant comment? Duplicate comments get deleted.

  10. Here is the comment I left the ATF,

    I am opposed to all regulations that deny me and my fellow Americans second amendment rights, how dare you, what are you communists ?

  11. How are they going to know who has one in the first place. No serial number and with some people who just pay cash the name on the receipt just says Cash.
    The attempted enforcement of this is going to be a disaster.
    What about those states who won’t enforce this diaster. What then?

    • Yeah, impossible to enforce, just like those lightning links…

      $100,000 and 10 years in the Federal P is pretty convincing for most folks.

      • Most might just be a overstatement. Look at the two leftard states that did the bump stock ban already with one being life in prison? None revealed in one state, 4 in another. Not very convincing to me.
        People will keep them but will not be open about it. I dont have ARs, only AKs and now I wish to hell I had bought one for each of them when they were only $125.00. Same thing now for 600+ used?
        I thougt they were a cheap toy that would be expensive to enjoy as ammo, altho cheaper now, still isnt a cheap as it once was at the time.

        Now, do you think that people would also give up ANY GUN just because it would get banned? Really?

  12. Under the Obama Administration Between 2008 and 2017, the ATF issued classification decisions concluding that other bump-stock-type devices were not machineguns, including a device submitted by the manufacturer of the bump-stock-type devices used in the Las Vegas shooting. These devices were made for handicapped people.

    A non elected Gov Dept (Justice Dept/BATF) cannot write illegal laws changing the 2nd Amendment!

    To state the obvious, a finger is not the same thing as a trigger. And, while a bump stock is in operation, the trigger functions separately every time a round is discharged.

    The Second Amendment confers no positive right. It recognizes a pre-existing right. It is an additional limitation on federal power to infringe upon gun rights besides the fact that no authority is granted to the federal government in its limited, enumerated powers to infringe upon them in the first place.

    The federal government has no authority whatsoever under the Constitution—even if the Second Amendment were repealed—to ban or regulate handguns, high-caliber guns, shotguns, sawed-off shotguns, rifles, assault rifles, extended-capacity magazines, bump sticks, ammunition, automatic weapons, machine guns, grenades, or bazookas.

    And neither does the federal government have any authority whatsoever under the Constitution to establish or mandate gun-free zones, background checks, waiting periods, trigger locks, limits on gun purchases, age restrictions on gun purchases, gun-barrel lengths, concealed weapons laws, licensing of gun dealers, gun-owner databases, gun licensing, or gun registration.

    If anything should be repealed it is all federal gun laws—even the ones supported by Republicans and conservatives.

    Illegal RED FLAG LAWS=Gun Confiscation Orders pure and simple. Nine states now have RED FLAG LAWS on the books and dozens of others are considering such proposals and now Congress wants it be Federal!

  13. The 2nd amendment is meant to arm citizens with the latest and best firearms to protect the country from all enemies!

    10 U.S. Code § 246 – Militia: composition and classes

    (a) The militia of the United States consists of all able-bodied males at least 17 years of age and, except as provided in section 313 of title 32, under 45 years of age(65 with Military Experience) who are, or who have made a declaration of intention to become, citizens of the United States and of female citizens of the United States who are members of the National Guard.

    (2) the unorganized militia, which consists of the members of the militia who are not members of the National Guard or the Naval Militia.

    End the NFA!

    If the ATF or Gov want to change definitions on functions of Semi-Auto guns and triggers that have been well established for decades and make them all NFA Regulated Firearms then they must Scrap the 1934 NFA and start over with votes in Congress!

  14. The Gun Control Peeps are making many gun ban comments…..we need to shut them out!

    For ideas please use and add ur own words..form letters are discarded!

    Hear is the GOA Letter!

    GOA Letter:

    I am opposed to any regulation on bump stocks.

    These proposed regulations would declare a “bump stock” to be a machinegun because it allows the gun to fire more than one shot “by a single PULL of the trigger” — that is, by a single volitional function of the finger.

    But federal law, at 26 U.S.C. 5845(b), defines a part as a “machinegun” ONLY if it is designed solely and exclusively to allow the gun to “fire more than one shot … by a single FUNCTION of the trigger.”

    To state the obvious, a finger is not the same thing as a trigger. And, while a bump stock is in operation, the trigger functions separately every time a round is discharged.

    So these regulations are proposing a radical change — as they effectively define a gun as a machinegun even if the trigger resets for every round that is fired, so long as the finger only pulls the trigger once.

    While bump stock devices will now be treated as machineguns under these regulations, they also raise serious questions in regard to AR-15s and other semi-automatic rifles — as they are now on the brink of being designated as machineguns by the next anti-gun administration.

    In the past, one had to fundamentally change the firing mechanism of a semi-automatic firearm to convert it into a fully automatic firearm.

    But now according to these regulations, a bump stock is a machinegun — and it can “readily restore” a semi-auto into a machinegun, simply because the gun owner can effectively fire the weapon continuously with a “single pull” of the trigger. This would invoke the statutory definition for a rifle, which is classified as a machinegun (26 USC 5845(b)).

    It won’t matter that a gun which is being bump fired has not been fundamentally altered. AR-15s will be on the brink of extinction once these regulations go into force.

    These regulations dismiss Second Amendment protections, by appealing to the Heller court decision. But the Constitution trumps the Supreme Court — so when the Second Amendment says that the right to keep and bear arms “shall not be infringed,” any limitation of the right for law-abiding citizens should be treated as unconstitutional.

  15. Here’s my comment:
    I emphatically oppose the proposed rulemaking changes to classify so-called “bump stocks” as machine guns. As defined under US law, a machine gun is designed to fire more than one shot with a single interaction of the user with the trigger mechanism. The action of the firearm is activated only by the pressure of the operator’s finger against the trigger. A machine gun does not need to be held in any specific way – upside down, overhead, laying on its side, even with no user contact other than pressure against the trigger, the gun will fire.

    A bump stock operates in a completely different manner. Not only must the trigger be depressed by the finger for each shot in a string – contrary to the definition of a machine gun – but the gun itself must be held in a specific manner. Strings of shots cannot be fired if the gun is not held specifically by the stock in a certain way, such that the firearm’s action is free to slide back and forth in the buttstock, the stock is retained against the operators body, and the finger is held in a specific manner across the trigger mechanism. If any of these requirements are not met, the gun will not fire a string of shots, but will operate as a conventional semi-automatic firearm.

    I do not own any bump stocks, and think they are primarily a range toy. There is no evidence that they have ever been used in a crime, despite their appearance at a single crime scene in Nevada. Most importantly, it is not within the BATFE’s authority to alter the legislated definition of the term “machine gun” to include assisted, rapid semi-automatic operation of a conventional firearm. If there is sufficient desire to classify bump stocks as machine guns, this requires legislative action, not Executive Branch rulemaking.

  16. Rich people will always have machine guns. But poor people will not be allowed to have a less expensive alternative.

    It was a rich man who could have used a real machine gun to shoot up a concert in Las Vegas, but decided to save money and buy several slide Fire equipped AR15s.

    Also no wait time and no registration for a bump stock, because no serial number.

    Because he knew having one machine gun could jam. So having several Bump Stocks as a backup was part of his plan.


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