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ATF Taking Comments on Bump Stocks until Jan 25.

Discussion in 'Activism' started by SKILCZ, Jan 12, 2018.

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  1. SKILCZ

    SKILCZ Member

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    The ATF is considering redefining the "machine gun" definition to include bump stocks and is soliciting comments at this link. You have until January 25th, 2018 to submit them or forever hold your peace.
     
  2. badkarmamib

    badkarmamib Member

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    Thanks, added my comments to the mill. Personally, don't need one, don't want one. But I have a serious problem with the government allowing something to be legal for 15 years, and arbitrarily changing their mind and creating thousands or millions of felons overnight.
     
    Last edited: Jan 12, 2018
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  3. Mauser lover

    Mauser lover Member

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    commented... Hope they read it!
     
  4. AlexanderA
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    AlexanderA Member

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    You might want to mention in your comments that if they open the registry for bump stocks, they should open the registry for everything (a Hughes amnesty, if you will). That seems to be the logical conclusion if they redefine bump stocks as machine guns, unless they are prepared to confiscate all of them.
     
  5. hdwhit
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    hdwhit Member

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    Please note that in making your comments you are responding to a type of notice called an Advanced Notice of Proposed Rulemaking (ANPRM). The stated purpose of this ANPRM is:

    Please note that if your comments are not responsive to the questions being asked in the ANPRM, the costs and benefits of the proposed regulatory change or the methodology of computing those costs and benefits, they will be included in the list of the 3,000+ comments already received, but will not actually be considered by the agency in formulating the regulation.

    The ANPRM specifically asks questions directed at manufacturers or retailers, but there are three directed towards consumers, so unless you're a manufacturer or retailer of bump stocks you will probably want to focus on responding to these questions.

    Consider carefully what you are going to say before you write it down because it could get taken up by the drafters of the regulation.
     
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  6. hdwhit
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    hdwhit Member

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    No, you shouldn't. None of the questions specifically asked have anything to do with the registry. Such a comment, being non-responsive, would not be considered by the people actually drafting the regulation.
     
  7. hdwhit
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    hdwhit Member

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    Your comment will be read. It may be read multiple times. The first time it is read, it will be by a $12 an hour staffer who is looking to see if your comments addressed the items Section III of the ANPRM (scroll down from the comment box) asked be addressed. If not, that is as far as your comment will go since it was not responsive to the request.

    Comments that are actually responsive to what the ANPRM asked to be addressed (i.e. the 23 questions, the costs and benefits or regulation and the methodology of computing those costs and benefits) will be passed on to either attorneys who are drafting the regulation or if the material is technical in nature to the technical specialists who assist the attorneys with matters of engineering, economics and the like.

    It is important to note that it is during these public comment solicitations that you are about as close as it gets to influencing how your government works. You can contact your Congressman directly, but he/she serves 435,000 other people with divergent interests. Here, there are 3,000+ comments. And the vast majority are going to be from people who write in saying bump stocks are great and that will be as far as their comment goes. Maybe 10% of the respondents will actually address what the ANPRM asked them to address. And it is those comments that will be read directly by the attorneys and their technical advisors who are going to actually draft the regulation. So, at the end of the day, between ignorance of the process, lack of interest or failure to read the directions before spouting off, maybe no more than 300 or 400 people are going to have any influence in that the resulting regulation says.
     
    Last edited: Jan 12, 2018
  8. Mauser lover

    Mauser lover Member

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    Yeah, I did read the questions that they wanted to be answered. I hope I answered them satisfactorily. I didn't just rant, at least as far as I could tell.
     
  9. AlexanderA
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    AlexanderA Member

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    The whole issue here is whether to reclassify bump stocks as machine guns. That's the crux, stated in simple terms. Pointing out the adverse consequences of such a reclassification is entirely relevant and responsive.

    Comments in such an early stage of the proceedings are expected to be wide-ranging. The "questions" in the ANPRM are not straitjackets, and are more in the nature of suggestions. They're open-ended. The agency, at this stage, is trying to get a general sense of the public reaction, and gather information.

    I agree that we should avoid rants, and keep our comments well-reasoned and specific.
     
  10. hso

    hso Moderator Staff Member

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    As hdwit has pointed out, we need to understand what this comment submission is for, what our comments must focus on and what format they must be in.

    Let's not throw away an opportunity to make relevant and compelling comments to the BATFE by jumping the gun and going off half cocked. Please read the below carefully and make a short and compelling argument against rulemaking treating this, or any other "accessories" as a machine gun regulated part.

     
    Last edited: Jan 12, 2018
  11. hdwhit
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    hdwhit Member

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    Sorry, but if the ATF wanted wide-ranging responses, they would have asked for them.

    They did not. They specifically asked that one or more of 23 specific questions be answered as well as comments regarding cost and benefits of the reclassification and methods for measuring those costs and benefits.

    Anything else will be considered non-responsive and will not be advanced to the people charged with writing the proposed regulation.
     
  12. hdwhit
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    hdwhit Member

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    The wonderful thing about the rule-making process is that any comment relevant to the request is passed on the drafters and they have to consider it. They can consider it and decide to ignore it and so long as their reviewer (i.e. supervisor) concurs that their reason for ignoring it is valid, it gets ignored, but it at least has to be taken up and considered before it can be ignored - that's part of why the regulatory process moves as slow as it does.
     
  13. Intox

    Intox Member

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    Glad you pointed this out. I know this will shock everyone here.....but I have a tendency to be somewhat long winded and rambling...lol
     
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  14. JTHunter

    JTHunter Member

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  15. DoubleMag

    DoubleMag Member

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    The primary question they ask is financial impact. Inventory, sales, inventory, $$$. I hardly believe that they (gov) are asking that to receive answers that show, financial burden therefore no regulation change. More likely gauging compensatory ($$) if the items are....removed.

    So yes I'll answer the questions, but will also add comments. Perhaps even in a 2nd letter to the provided address. If they do /do not read it all, that's their affair
     
  16. AlexanderA
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    AlexanderA Member

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    Yes. I agree completely. Don't let the opportunity go to waste to address the elephant in the room: what happens at the end of this process? Do they proceed to confiscation (post-1986 machine guns are contraband) or do they try to do some type of grandfathering -- or do they do nothing? The subsidiary questions about the commercial market for these devices are mostly irrelevant.
     
  17. giggitygiggity

    giggitygiggity Member

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    Comments made. Don't think that just because Republicans are in office that everything is hunky dory.
     
  18. JeffG

    JeffG Member

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    I sent my 2 cents in....
     
  19. SamT1

    SamT1 Member

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    I personally think the bump stock is a pretty dumb device. But that doesn’t mean I don’t think you should have one. Someone with Bad intentions would be a lot better off just converting to full auto.
    I wish I knew what happened in Vegas. Why would someone that’s going to commit a felony use a legal (seriously inferior) method of making a weapon “automatic”? Unless of course it was for political gain.
     
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  20. M1key

    M1key Member

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    The wording of the regulation will be critical. The proposed regulation is wide open to interpretation. The NRA apparently isn't speaking up about it either.

    M
     
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