Speaking your piece

Folks, it’s time to chime in on the proposed rulemaking by the BATFE that is meant to make firearms ownership such a burden that people simply give up: 2021R-05. You can read and comment on it here.

Here’s what I’ve just dropped on them. Feel free to steal it in its entirety, adapt it to what you want to say or create your own. Just get moving and do it.

I object, in the strongest possible terms, to the proposed changes to current firearms rules contained in proposed rulemaking 2021R-05.

These proposed changes create language and intent that does not exist in the 1968 Gun Control Act, the 1934 National Firearms Act or any other act of Congress that I am aware of. The language contained in the proposed rulemaking is vague to the point of uselessness. Under the proposed rulemaking it would be possible to consider many children’s toys, such as the Nerf gun, a firearm. Additionally, these changes allow the BATFE to arbitrarily define what is and what is not a firearm, and to make arbitrary changes in that definition in the future.

This proposal would make parts requiring extensive skilled work, but that are not currently considered firearms, such as a replacement trigger group, into firearms and regulated as such. Given the vagueness of the language, where doe this stop? Can the raw forging of an AR-15 lower or upper receiver be considered a firearm? Under current rules, no, but the new rules would open the avenue for the answer to be yes. In the case of modular style weapons, such as the AR-15, owners of those that have already been manufactured and sold would likely face the onerous burden of placing serial numbers on parts that did not previously require them. Since tens of millions of these guns and hundreds of millions of these parts already exist, it is likely there would be no practical way to accomplish this, thereby turning legal gun owners into criminals. Worse yet, these rules would apply to every firearm in the United States. At that point, the numbers become immense-hundreds of millions of firearms and billions of parts. Valuable antiques would be vandalized in the name of compliance with this rule.

If our laws regarding firearms are out of date, it is duty of Congress to amend them or pass new ones. It is not within the purview of BATFE to do so, no matter how much political pressure is being applied to them. This power must not be usurped by a non-legislative government entity. Proposed rulemaking 2021R-05 should be rejected in its entirety.

Quit worrying that you’ll “get on The List”. You’re already on a dozen or more. If you own a gun, buy ammo, anything firearms related, you’re there. Stop worrying about it. It may not help, but if the day comes, it’s important that we tried every other box, even to the point of foolishness, before we reach for the cartridge box.

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