Here's what I wrote (files as a response to the ATF writing)
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Agency/Docket Number:
Docket No. 2020R-10
Document Number:
2020-27857
Greetings:
This writing is in response to the above referenced document promulgated by BATFE on 12/18/20202.
1 - My interest in this matter is as a civic duty only. I do not own any of the "stabilizing braces" referenced by the above referenced document. All of my short barreled rifles are registered.
2 - Is there any such thing as an "AR-Pistol" ?
If the answer was NO, this whole issue would be simple. That the answer is not NO, has made the issue complex.
3 - Consent of the governed.
Per the Declaration of Independence, "Governments are instituted among Men, deriving their just powers from the consent of the governed". I believe it is still important today, that all government agencies retain this maxim and present the attitude of "public servants".
4 - Should the ATF "change" their determinations about the classification of various types of "firearms" due to political pressure ?
I note that in the case of bump fire stocks,
It was stated that the President had announced the ATF was changing their rules and had been directed to use all available resources to do so. This sounds like political pressure.
In the the bump fire stock case, the word "clarification" is used many times. This could make some persons think the ATF is avoiding saying they are "CHANGING" the definition, yet clearly they are. And it is even clearly stated that the ATF has the power to "reconsider and rectify" (aka CHANGE). In this writers opinion, such changes are fine, PROVIDED they are supported by a body of new evidence, justifying the reclassification. They should be called CHANGES, since there is nothing wrong with CHANGES, provided that are supported by a body of new evidence.
As an analogy, in my lifetime, Dinosaurs were first classified as cold-blooded reptiles. Based on new evidence, scientists have reclassified many dinosaurs as warm blooded creatures and grouped birds with dinosaurs. The NEW evidence supported this change in classification;
In the case of bump stocks, it was also the case, that new evidence regarding the danger of bump stocks existed, to wit the LV shooting.
The above referenced ATF document 2020-27857 does not present new evidence supporting the reclassification of pistol braces or evidence of increased danger.
5 - Can the ATF tell us we cannot place the pistol grips of our Glocks up against our shoulders and fire them in that way ? No one shoots a Glock in this way to my knowledge, but does the ATF tell us that we cannot ?
6 - Can the ATF tell us we cannot use a two hand grip when shooting our Glocks and fire them in that way ? Most people use a two handed grip when shooting pistols, this is what is taught. Why is two handed grip ok for some pistols and not others?
So #6 and #7 get back to point #2 above. Is there any such thing as an AR Pistol ? If there is, then why is an AR Pistol any different from a Glock pistol? Why does the ATF care about "intent" with regard to some pistols and not others ?
8 - Response period.
For bump stocks, we were given a 90 day response period. For pistol braces we are given a 14 day response period, which overlaps on top of the primary holiday season of the year. This raises questions about the integrity of the process. Why was this done ??
Thanks for the opportunity to respond.
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I will also sent to senators and rep.