Well, despite admitting that the ATF didn’t have the ability under the standard use and meaning of the English language and the use of a former mental tool known as “logic,” which disappeared from existence recently, they want to classify bump-fire stocks as machine guns. They want comments, and some answers. So give them answers, but also politely tell them “shall not be infringed.”
Skip below if you want to write a letter. I’ve included my thoughts on suggested responses to made the ATF attempt to ban these item harder without providing the hoplopaths any ammo. Please take the time to send a letter.
Here’s the original determination letter. An extremely butthurt “batfucker” (old term for the much derided BATF, which added “E” for “Explosives” once that word got out there) wrote a letter to Congress bitching (or defending, you decide) that the ATF simply didn’t have the ability to make bump-fire stocks into “machine guns.”
As much as we are disgusted by the man’s bootlicking attitude towards firearms restriction and the cries to regulate inanimate objects, we give the man and his colleagues a point for steadfastly admitting the law means what it says. “Machine gun” is defined as one shot per pull of the trigger; bump-fire stocks are a stock-and-pistol-grip that slides freely, as if in a track. The shooter must pull the gun forward with their non-dominant hand while holding the pistol grip, pulling the trigger, and tucking the stock into the shoulder normally with their dominant hand. This allows the trigger to push itself against the finger that is held stationar.
Bump-fire probably actually saved lives, versus an actual belt-fed machine gun, in Vegas. Imagine continuous strings of 100-250 rounds, with a quick barrel and magazine change. If Paddock had been planning his attack since around the November 2016, he would have had time to legally purchase any machine gun he wanted. He had the money and the clean record.
And if he had, so what? Criminals are always going to be criminals. These kind of crimes are relatively rare and NFA-item crimes even more so. Frankly, I’m more worried about an out-of-control government, be it federal, state, or local, or a rampaging racist mob, trying to kill me than I am about some absolutely batshit rich guy going nuts. At least the Clark County Commission acted ahead on the threat of Muslims with Trucks® and is installing bollards on the Strip.
So what if this was designed to get around NFA restrictions? Machine guns should be legal and unregulated. In about a decade, the National Firearms Act and most other function/designed based gun control regulations will be impossible to enforce when anyone can print up a machine gun at home. They can’t prosecute everyone. Just imagine if the government tried to regulate free speech because the Internet is destroying the long-standing political and mainstream media monopoly on ideas.
“6. For what use or uses have you marketed bump stock devices?”
Bump-fire stocks are designed and intended to increase the rate the firer’s finger to pull the trigger in order to increase the cyclic rate. This weapon is intended for recreation and weapons controllability training. Bump-fire stocks rely on the coordination and dexterity of the firer to operate properly, thus building general shooting skills and those applicable to military or militia service.
“9. What costs do you expect to be associated with the disposition of existing bump stock device inventory?”
Our costs are expected to be our entire unsold inventory of _____, a cost of _______. Also, our equipment, facilities, and other logistic, production, and business costs and investments would amount to a loss of __________. We expect the United States Treasury to fully compensate us for our losses.
“10. If ATF classified bump stock devices as “machineguns” under the Gun Control Act of 1968, as amended, and the National Firearms Act of 1934, as amended, do you believe that there would be a viable (profitable) law-enforcement and/or military market for these devices? If so, please describe that market and your reasons for believing such a viable market exists.”
No such market would exist precisely because the price point between an actual machine gun versus a semi-automatic rifle and bump-fire stock would favor the machine gun, without the drawbacks inherent to bump-fire systems. Law-enforcement and the military is not restricted to an arbitrarily limited pool of firearms nor a Draconian purchase approval (registration) process. Additionally, we dispute that bump-fire stocks need to have a law-enforcement or military market in order to be available to the general public without infringement.
Bump-fire systems have application for military training of the public, i.e. the unorganized militia, as machine guns are generally unobtainable for most of the general public. While we do not conceive that any rational person could believe that the definition of “machine gun” covers bump-fire stocks, as the ATF has previously admitted, such devices allow high cyclic rates. This can be used by the unorganized militia as weapons controllability training should they be called into military service or needed to secure a free state.
“15. For what use or uses have you marketed bump stock devices?”
Our costs are expected to be our entire unsold inventory of _____, a cost of _______. We expect the United States Treasury to fully compensate us for our losses.
“19. What costs do you expect to be associated with the disposition of existing bump stock device inventory?”
See 9. above.
“23. For what purposes are the bump stock devices used or advertised?”
Choose your answer carefully. Do not answer anything along the lines of “because I can’t get a machine gun.” Those who would ban bump-fire stocks want to point to comments that indicate the stocks are used in place of machine guns, which they have made unobtanium for most of us. Comments that state bump-fire “is essentially a machine gun” is music to hoplopaths’ ears. High rates of fire can be described as “simulated high cyclic rates” rather than “simulated machine gun fire” or “simulated automatic fire.”
A nice little (and polite) statement along the lines of “don’t cave into political security theater, you admitted yourself you don’t have the authority to regulate these as machine guns, the NFA is unconstitutional, and quoting the Second Amendment,” would be appropriate. Let them know we aren’t going to take this sitting down.
The ATF wants an address and your name. The records will be made public, although few will see them. Nothing is wrong with using your initials, a pseudonym (like G. C. Gates, not Shallnot B. Infringed), and giving your address as the nearest post office, general delivery. Such as:
John M. Browning
Your letter must be signed and reference: Docket 2017R-22
Fax your letter to: (202) 648-9741
Attn: Docket 2017R-22
The full notice is here, with instructions to use the online submission portal.