12-20-2020, 06:34 PM
I would ask for any and all to take 10 minutes to push back on the ATF. Please feel free to use my version attached or customize as you see fit. I'm attaching the letter that I am physically mailing in response to the ATF. I am also providing a letter to my elected representatives to also confirm the ATF responds to my letter as well as requesting the ATF director brief them individually and in person. My intent is to make the bureacracy work against the effort. First, the more physical letters that have to processed the more time before they can take action. Second, I want them to have to do detailed multi-phased analysis to support any such proposal. This is intended to take them time until either it is determined not to be worth it or administration change.
Text of Letters below.
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Office of Regulatory Affairs, Enforcement Programs and Services,
Bureau of Alcohol, Tobacco, Firearms, and Explosives,
99 New York Ave. NE, Mail Stop 6N518,
Washington DC 20226; ATTN: ATF 2020R-10.
Cover Letter.
Please review and respond to my comments starting on page 2 for
ATF 2020R-10: Objective Factors for Classifying Weapons with "Stabilizing Braces"
Signed,
Insert First and Last Name
Insert Street Address
Insert City, State, Zip
?
Response to ATF 2020R-10: Objective Factors for Classifying Weapons with "Stabilizing Braces".
ATF's proposal to regulate stabilizing braces under the National Firearms Act appears to be politically driven instead of being based on facts, data, and analysis and does not seem to regard the impact on American citizens.
Stabilizing braces are not a niche product any longer. The devices enable the handicapped, disabled veterans, smaller statured shooters, and the elderly to handle a pistol more effectively.
The product's success can be seen because multiple firearm OEMs have incorporated these devices into their standard offerings and have for numerous years. Many of these firearms were submitted to ATF for approval before being integrated into their product offerings. A trip to any firearms retailer or review of OEM catalog will find multiple brace enabled platforms on their shelves for purchase.
The bottom line is the product is a mainstream firearm product owned by a significant number of law abiding citizens who could be inadvertently impacted by the proposals identified.
These impacts include:
being exposed to felony charges under the NFA if unaware of the rule change,
being required to destroy lawfully acquired property,
being added to a government firearm registry to enable future firearm confiscation,
being required to get government approval to transport their firearm when they travel with it.
Before implementing such a sweeping rule change that will negatively impact such a significant volume of law abiding American citizens, the ATF should have to follow a properly structured plan. To fully understand the impacts and justify the rule change, I propose ATF must follow the following 4 step plan:
1. PROVIDE A MORE COMPREHENSIVE RESPONSE TIME: Repost the letter for commentary during a non-holiday period. The current approach appears to be an attempt to "sneak-in" a politically driven rule. This reposting should occur outside a special holiday period such as Christmas break.
2. EVALUATE DISPARATE IMPACT TO DISADVANTAGED GROUPS: The ATF must conduct a detailed statistical level analysis to demonstrate the rule does not have a disparate impact and discriminate against the disabled and the elderly. This analysis should compare and contrast any specifically intended crime reduction or impact versus what appears to be something that would discriminate against these populations. Congress members should review this analysis to ensure transparency on rulemaking with such an enormous negative impact on law-abiding American citizens.
3. DETAILED ANALYSIS OF ALL PRODUCTS ON MARKET: The ATF must conduct detailed statistical level analytical work and studies to inform each of the proposed parameters, i.e., type, caliber, weight, length, length of pull, attachment method, and all stabilizing brace design features. Members of Congress should also review this analysis to ensure transparency on the rule.
4. FINANCIAL IMPACT OF MANAGING SPECIAL REGISTRATION PROCESS: Assume 1.5 million braced pistols now exist in the marketplace approved by the ATF. What is the ATF's budget impact required to support the registration process? What is the ATF's budget impact on supporting the out of state travel approval process for NFA firearms? What is the ATF's plans to bear the cost of notification to consumers since ATF previously approved these products? ATF approved the product for sale, so ATF should pay the cost of notification and not the OEMs.
This rule change could negatively impact the 2nd Amendment rights of more than 1 million law-abiding American gun owners.
Under this proposed rule, any effort should be done in a disciplined and transparent method that would provide detailed requirements, assess impact to disadvantaged populations, and cost versus benefit on such proposed action. I will ask my representatives to require exactly these actions in a step-by-step process before rule changes are made.
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Re: Require ATF to follow attached plan on pistol braces
Senator Cornyn:
The ATF appears to be implementing a hasty gun control plan without proper debate and analysis in the public's eyes. The timing of the effort is suspect, considering the holiday window in which it is occurring.
I voted for you and have supported you. I request that you require the ATF Director to prove that they have comprehensively responded to my comments and that the ATF director briefs you personally in your office. I would also request that your team coordinates among your fellow elected representatives so that briefings are not streamlined into one comprehensive briefing on the same day. If the ATF director wants to pursue this path, it should require time-consuming interaction, multiple individual trips to Capitol Hill, and significant socialization effort.
I want full accountability on the ATF if they proceed in this manner. To date, ATF has approved multiple versions of "pistol braces", and many manufacturers have legally incorporated them into their products. The initial evidence points to more than one million pistol braces in circulation. ATF's actions could expose more than a million gun owners to the National Firearm Act (NFA) rules and the exposure to felony charges within it.
Additionally, many handicapped, disabled, and elderly Americans use these braces to handle a pistol more effectively. This new rule would unfairly target these groups of people.
I appreciate your willingness to serve the republic. Thank you for your continued support of the 2nd Amendment.
Sincerely,
Text of Letters below.
\\\\\\\\\\\\\start of ATF \\\\\\\\\\\\\\\\\\\\\\\\\
Office of Regulatory Affairs, Enforcement Programs and Services,
Bureau of Alcohol, Tobacco, Firearms, and Explosives,
99 New York Ave. NE, Mail Stop 6N518,
Washington DC 20226; ATTN: ATF 2020R-10.
Cover Letter.
Please review and respond to my comments starting on page 2 for
ATF 2020R-10: Objective Factors for Classifying Weapons with "Stabilizing Braces"
Signed,
Insert First and Last Name
Insert Street Address
Insert City, State, Zip
?
Response to ATF 2020R-10: Objective Factors for Classifying Weapons with "Stabilizing Braces".
ATF's proposal to regulate stabilizing braces under the National Firearms Act appears to be politically driven instead of being based on facts, data, and analysis and does not seem to regard the impact on American citizens.
Stabilizing braces are not a niche product any longer. The devices enable the handicapped, disabled veterans, smaller statured shooters, and the elderly to handle a pistol more effectively.
The product's success can be seen because multiple firearm OEMs have incorporated these devices into their standard offerings and have for numerous years. Many of these firearms were submitted to ATF for approval before being integrated into their product offerings. A trip to any firearms retailer or review of OEM catalog will find multiple brace enabled platforms on their shelves for purchase.
The bottom line is the product is a mainstream firearm product owned by a significant number of law abiding citizens who could be inadvertently impacted by the proposals identified.
These impacts include:
being exposed to felony charges under the NFA if unaware of the rule change,
being required to destroy lawfully acquired property,
being added to a government firearm registry to enable future firearm confiscation,
being required to get government approval to transport their firearm when they travel with it.
Before implementing such a sweeping rule change that will negatively impact such a significant volume of law abiding American citizens, the ATF should have to follow a properly structured plan. To fully understand the impacts and justify the rule change, I propose ATF must follow the following 4 step plan:
1. PROVIDE A MORE COMPREHENSIVE RESPONSE TIME: Repost the letter for commentary during a non-holiday period. The current approach appears to be an attempt to "sneak-in" a politically driven rule. This reposting should occur outside a special holiday period such as Christmas break.
2. EVALUATE DISPARATE IMPACT TO DISADVANTAGED GROUPS: The ATF must conduct a detailed statistical level analysis to demonstrate the rule does not have a disparate impact and discriminate against the disabled and the elderly. This analysis should compare and contrast any specifically intended crime reduction or impact versus what appears to be something that would discriminate against these populations. Congress members should review this analysis to ensure transparency on rulemaking with such an enormous negative impact on law-abiding American citizens.
3. DETAILED ANALYSIS OF ALL PRODUCTS ON MARKET: The ATF must conduct detailed statistical level analytical work and studies to inform each of the proposed parameters, i.e., type, caliber, weight, length, length of pull, attachment method, and all stabilizing brace design features. Members of Congress should also review this analysis to ensure transparency on the rule.
4. FINANCIAL IMPACT OF MANAGING SPECIAL REGISTRATION PROCESS: Assume 1.5 million braced pistols now exist in the marketplace approved by the ATF. What is the ATF's budget impact required to support the registration process? What is the ATF's budget impact on supporting the out of state travel approval process for NFA firearms? What is the ATF's plans to bear the cost of notification to consumers since ATF previously approved these products? ATF approved the product for sale, so ATF should pay the cost of notification and not the OEMs.
This rule change could negatively impact the 2nd Amendment rights of more than 1 million law-abiding American gun owners.
Under this proposed rule, any effort should be done in a disciplined and transparent method that would provide detailed requirements, assess impact to disadvantaged populations, and cost versus benefit on such proposed action. I will ask my representatives to require exactly these actions in a step-by-step process before rule changes are made.
\\\\\\\\\\\\\\\\\\\\\\\Start of Elected Representative Below\\\\\\\\\\\\\\\\\
Re: Require ATF to follow attached plan on pistol braces
Senator Cornyn:
The ATF appears to be implementing a hasty gun control plan without proper debate and analysis in the public's eyes. The timing of the effort is suspect, considering the holiday window in which it is occurring.
I voted for you and have supported you. I request that you require the ATF Director to prove that they have comprehensively responded to my comments and that the ATF director briefs you personally in your office. I would also request that your team coordinates among your fellow elected representatives so that briefings are not streamlined into one comprehensive briefing on the same day. If the ATF director wants to pursue this path, it should require time-consuming interaction, multiple individual trips to Capitol Hill, and significant socialization effort.
I want full accountability on the ATF if they proceed in this manner. To date, ATF has approved multiple versions of "pistol braces", and many manufacturers have legally incorporated them into their products. The initial evidence points to more than one million pistol braces in circulation. ATF's actions could expose more than a million gun owners to the National Firearm Act (NFA) rules and the exposure to felony charges within it.
Additionally, many handicapped, disabled, and elderly Americans use these braces to handle a pistol more effectively. This new rule would unfairly target these groups of people.
I appreciate your willingness to serve the republic. Thank you for your continued support of the 2nd Amendment.
Sincerely,