Apologies for all the exclamation marks! But…the number of comments left so far (59k) on the Federal Register RE ATF’s ridiculous planned restrictions on pistol stabilizing braces is simply not enough. And your comments really DO matter. Here’s just one recent example of how it can derail ATF’s anti-gun ambitions, plus a few suggestions of how to craft a meaningful comment that won’t be rejected.
First, what are we talking about here? The FPC video above explains the proposed new guidance pretty well. It’s basically the December proposed guidance — which I tore to shreds line-by-line HERE — with the addition of an asinine points system.
It’s bad. It would force stupid, arbitrary, nonsensical, and horribly vague restrictions on how the owner of an arm brace-equipped pistol is allowed to configure his or her gun.
So let’s fight it. Right now, this very minute, you need to go leave a comment on the Federal Register that clearly states you are against the proposed rule. It’ll take you 60 seconds.
Here are a couple comment rules to keep in mind:
• No profanity
• Anonymous comments will not be considered, so fill out the name and info fields
• Don’t copy-and-paste another comment; yours should be unique
Here are some topics you may want to include in your comment:
• Millions of pistol brace-equipped firearms are owned by law-abiding people who purchased firearms or pistol braces in good faith with the ATF’s express acknowledgement of their legal status. These new rules may turn many of these people into felons overnight.
• ATF’s proposed “objective” guidance is vague and highly subjective, with no quantifiable metrics. It increases confusion and fear among legal gun owners and manufacturers rather than provides clear guidance to follow.
• Many of ATF’s “objective factors” are non-sensical and self-contradictory with previous ATF rulings. For instance, ATF has always affirmed that resting one’s cheek on a pistol’s receiver extension (buffer tube), stabilizing brace, or pistol cheek rest (example) is entirely legal and acceptable. How, then, can the use of optics designed for this cheek placement create an illegal configuration?
• Many of ATF’s “objective factors” would directly discriminate against individuals based on physical stature and physical abilities, such as the very subjective “so heavy that it is impractical” weight limit. This factor is entirely vague and undefined, and would clearly violate equal protection of the laws under the 14th Amendment, the Civil Rights Act, and the Americans with Disabilities Act.
• This is a direct attack on disabled Americans who have difficulty controlling a large format pistol due to injury or other disability, such as the disabled combat veterans for whom the pistol stabilizing brace was originally invented.
• ATF states that the purpose of the National Firearms Act is “to regulate certain weapons likely to be used for criminal purposes.” With approximately six million pistol brace-equipped firearms in private hands in the United States and literally one known criminal act committed with such a firearm, it’s clear that in no way do these guns belong in the purview of the NFA.
• In point of fact, the United States is the only country in the world to specifically restrict rifles based on barrel length, further proving that the entire concept of “short barreled rifles” requiring unique regulation is not based in fact or reality. These firearms are not “likely to be used for criminal purposes” and do not belong in the purview of the NFA.
• Clear infringement of the Second Amendment
• ATF’s unclear, secret, capricious, and ever-changing rulings related to pistol braces created this situation. Not only do these new, vague guidelines not help in any way, it is unreasonable to retroactively apply them to persons who followed previously-published and even unpublished guidelines in good faith in the past.
• Forcing law-abiding gun owners who might be in violation of these subjective, unclear new rules to register with the National Firearms Act or destroy their legally-purchased property is unreasonable.
• What else do you have? Comment below this article with other topics and avenues of attack on ATF’s latest rogue, ridiculous action.
And, yes, leaving a comment does truly make a difference. Here’s an example:
The Bureau of Alcohol, Tobacco, Firearms and Explosives said Tuesday it was backing down from a proposed ban on manufacturing and selling one of the most popular bullets used in AR-15 semiautomatic rifles.
The agency pulled the plug early, with still a week to go before the end of a one-month informal comment period on the proposed rule change that would have targeted these armor-piercing bullets. The ATF noted it had received more than 80,000 comments, and “the vast majority of the comments received to date are critical of the framework, and included issues that deserve further study.”
TTAG covered the news HERE.
Heck, the ATF quickly backed off on similar brace restrictions last December, literally ending the comment period early and withdrawing the proposed guidance entirely, due to the tens of thousands of public comments.
Let’s do it again. Go comment.