*TAKE ACTION* ATF bump stock comment period open.

[Justin///M]

Go here to file a formal comment. Here's what I submitted along with some .pdfs on the ATFs previous decisions regarding bump stocks.


Notes courtesy of Buckengr:

"Important point: Write your own letter. Diversity of comments is essential here. Form letters will be grouped together and will not require additional review by ATF.

Also, lawsuits can ONLY be brought based on points raised during the comment period, so please, please consider as many possible issues with this regulation as you can think of and submit comments accordingly. Having standing is important in order to challenge this regulation.

Be polite, and don't use profanity.

Be sure to use your REAL NAME and REAL ADDRESS. I'm sure you're already on a list. You might as well stop worrying about it and comment now while your words are all that are required from you."


https://www.federalregister.gov/docu...k-type-devices




REFERNCE THE NFA HEARINGS ON HR 9066 FOR APPLICABLE PAGE NUMBERS CITED BELOW.

http://www.nfaoa.org/documents/NFA-1934house.pdf


During the original testimony on the NFA '34, a Congressman asked the President of the NRA a question which essentially is about the possibility of things like bump stocks. The NRA president responded that while that would be possible, it wouldn't be as a good as a machine gun.
The Congress AGREED with the that response and ACCEPTED the NRA's proposed definition of a machine gun.

Here is the exchange:

"Mr HILL: Suppose your definition were adopted. Would it be practicable to manufacture a gun that would be classed either as an automatic or semiautomatically operated gun even with more than one function of the trigger and still answer the purpose in a large way of a machine gun which requires only one function of the trigger.

Mr FREDERICK: I do not think so. For purposes of example you may look at the automatic pistol which is the standard weapon of the United States Army. That has an automatic discharge of the empty cartridge and a reloading principle which is operated by the force of the gas from the exploded cartridge. But with a single pull of the trigger only one shot is fired. You must release the trigger and pull it again for the second shot to be fired.You can keep firing that as fast as you can pull your trigger. But that is not properly a machine gun and in point of effectiveness any gun so operated will be very much less effective than one which pours out a stream of bullets with a single pull and as a perfect stream.

Pages 40 - 41

...

Mr FREAR: You are a lawyer you are not a firearms manufacturer as you have said. Let us assume that we accept your proposed suggestion I suggest that we pass it and get to the other serious questions that are involved in the bill."

Page 42.

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26 U.S. Code § 5845 Defenitions

The 2018 definition of a machine gun:

"(b) MachinegunThe term "machinegun" means any weapon
which shoots, is designed to shoot, or can be readily restored to shoot,
automatically more than one shot, without manual reloading, by a
single function of the trigger. The term shall also include the frame
or receiver of any such weapon, any part designed
and intended solely and exclusively, or combination of parts designed and intended, for use in converting a weapon into a machinegun, and
any combination of parts from which a machinegun can be assembled
if such parts are in the possession or under the control of a person.""



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The BATFE has already determined that bump stocks and other such devices do not fall under the purview of the NFA and that you cannot ban them outright yourselves. This would require an act of congress, and I suggest you stand by your previous decision.

Furthermore, consider enforcement. How, exactly, will you enforce such a ban? They're unregistered, 3D printable, pieces of plastic. You may find yourself having to open the machine gun registry again.

Please consider that they've been used in exactly ONE crime. What is the scientific and statistical evidence that banning bump stocks and other such devices will make citizens safer? When we consider infringing on the rights of Americans, shouldn't there be a good intention and purpose? What purpose would this ban serve, since statistically, they aren't a crime problem in the USA (neither are machine guns, for that matter).

Finally, how can the government justify creating felons out of thousands, if not millions, of law abiding Americans? In a free society such as the USA, the unjust use of force against peaceful people of America is the antithesis of liberty. That's how laws are enforced, threat of force. In this case, it is suggested that we ban something that was legal, and then threaten people that purchased these item legally with unjust force if they do not comply with the ban.

That is un-American.

Thank you for your consideration,

Justin

[Emptymag]

I thought there was already a comment period on bump stocks?

[coppery]

By the ATF's own research, and testing, Bump Stocks do not convert semi-auto firearms into full auto firearms. They simply give a mechanical advantage to the user to bump fire the firearm to fire faster. Bump firing can already be done to the same effect, that a Bump Stock helps to facilitate, without using any tools. The appeal of these sort of products is that they do not require much practice, which to individuals who wish to have fun at the range, is very appealing. Regulating such a device, or the action of bump firing, requires a definition of what the rate of fire is when firing a semi-auto firearm. Semi-auto firearms do not have a rate of fire because by definition a semi-auto firearms rate of fire is as fast as an individual can manipulate the trigger. Some individuals are more than capable of firing faster than a bump stock can facilitate. Bump Stocks still require that the trigger be pulled each time a shot is to be fired. It is still a semi-auto action.

There is no rational sense in regulating these devices, or the action of bump firing, as such a decision regulates an action more than it does a device. Bump Stocks have only been used in one crime, to ill effect, and are used daily for recreational purposes where no crime is being committed. It simply is not right to regulate them, and regardless, that power lies with Congress to pass such a regulation into law, not with a government agency to make a decision, when it's own findings do not consider the device to be, or convert a firearm into a machine gun.

Rate of fire increasing devices are just a phony term used by politicians, and the media about a subject they do not, and refuse to understand. There is no rate of fire standard for a semi-auto, because by definition there can't be one, whether or not a mechanical advantage is given. If the firearm does not operate as a machine gun with a single trigger pull resulting in multiple rounds being fired, the firearm is semi-auto, regardless of any mechanical advantage, and therefor legal by every definition, which only Congress has the authority to define.

Do not regulate.

Thank you.

That's my letter. AM I kicking ourselves by mentioning "mechanical advantage" which could open pandoras box on trigger jobs, and other such modifications? I have not submitted it yet, so i'm open to editing.

[Justin///M]

I thought there was already a comment period on bump stocks?

This is another. Please go forth and comment.

[Rook]

That's my letter. AM I kicking ourselves by mentioning "mechanical advantage" which could open pandoras box on trigger jobs, and other such modifications? I have not submitted it yet, so i'm open to editing.

Inertial advantage may be more accurate. Sorry if this is long, and mostly repeats what has been said.

It allows free movement of the rifle independant to the stock, while allowing the trigger finger to remain rigidly fixed to the stock body by means of an extention. To work, both the support arm, and trigger arm must be co-cordinated by the operator for proper function. It basically allows the operator to use the inertia that is freed by not having the stock mechanically fixed. Look up the many videos showing stops and starts by first time users.

Mechanical advantage suggests the 'action' is acheaved soley by the stock itself thru use of a lever, or spring. Neither of which is present. It is simply a loose fitting stock, attached to a grip, with a trigger finger rest extending from the grip. Nothing exciting going on.

Can probably acheive the same result using a thumb hole stock, with a few modifications.

If you have really good muscle co-ordination, and have no care for range safety, can probably do it with any normal semi-auto firearm with no modifications, as long as the reset isn't too long. Maybe even semi-auto shot guns, but I won't be the first to try, I have shoulder issues, lol.

[coppery]

makes sense. but mechanical would also cover trigger cranks, binary triggers, etc. so should i just strike out mechanical advantage products all together and just stay on bump stocks with inertial advantage, or should i include both?

[Hodgie]

Pretty good breakdown of the proposed regulation.

[Rook]

hmm, hard call. May be best to sleep on it.

When I am worried how I would word something important, I re-wright the whole thing and compare the two.

Usually best not to complicate, or give them more 'food' to chew. Keeping things simple is not natural for me, so I know how hard it is to do so.

[wanneroo]

Having read parts of it and skimmed some, I plan on reading it all during the holiday, taking notes and then writing my letter. Sessions left a poison pill in it via the 5th Amendment. Government is supposed to compensate you for property taken for the benefit of public welfare. The regulation paper lays out all the costs, says they are going to ban, confiscate and expect people to destroy these stocks for the benefit of the public welfare but then has no compensation for it.

[Emptymag]

I don't really think the ATF needs an explanation of the operation of a device that they have already thoroughly examined, saw how it operates, and determined that it does not fit the legal definition of "machine gun".