Well said, and I agree completely. I don’t mind giving my name and contact info. Didn’t John Hancock purposefully sign his name big enough for King George to see it?
Anyway, I know little about pistol braces, and much less about this proposed rule that’s stirred controversy recently in our 2A community. So before I comment on it, I’d like to learn more so my comment contains meaning and substance, lest it be dismissed as ignorant drivel. I googled it and think I understand the difference between braced pistols and PCC’s, or at least I think I do.
So I read the proposed rule’s summary, but I’m still a bit confused by what they’re proposing to regulate. From the little I understood, they want to set up a supposedly objective rule to help brace manufacturers and the ATF better determine what falls under it and what doesn’t. To that end, they’re looking at the length and weight of the firearm, caliber and other factors to help make that determination. I guess what they’re trying to get at is if it’s bigger and heavier and shoots a poweful round, then with a “brace,” especially one that’s more easily used as a stock that can be shouldered as opposed to a strap that wraps around your arm, then it’s really just a short barreled rifle in disguise. Did I understand that correctly, or am I way off?
ATF’s summary cites a bunch of statutes (bills passed by Congress) they claim gives them the authority to propose this rule, like the NFA, GCA and a few other acronym laws I’ve never heard of. Congress often does that - passes the buck so to speak to an executive agency to sort out the minute regulatory details. Those details then become rules and regulations. If the rule falls outside the parameter of a Congressional statute, it’s invalid. But the ATF’s summary never cites to any specific provision or subparagraph of any of these statutes, most of which can be quite lengthy. Or if it does, I must’ve missed it.
I thought I could check the actual text of the proposed rule to see if I might be able to find any specific provisions, but I couldn’t figure out where to find a link to the actual text. My google skills so far just turn up the summary. Main reason I’m harping on about this is that I’d like to see whether any of those statutes actually give the ATF authority to issue this particular rule. One or more of them probably does, but it’s always good to read the statute to double-check. Otherwise, the rule can be invalid.
Aside from that, one other comment I thought might be worthy is how this rule might affect owners of braced pistols that were once legal, or at least not subject to being regulated, to now being subject to regulation. Most of those folks are regular, working Americans who thought they bought something perfectly legal at the time. How many people are we talking about here? Either way, the rule could cause undue burden to all those people, all in the name of curbing the use of guns to commit crime, supposedly. And if curbing gun use in crimes is the reason for this rule, how many pistol braces have been used in crimes? If it’s little, then is the burden on all those innocent Americans really worth having to issue this rule? Not sure how to articulate that in a meaningful public comment, but it might be effective if the point gets across.
Lastly, and this has nothing to do with writing a comment, but why would the Trump Administration’s Department of Justice and ATF feel the pistol brace issue is important enough to promulgate a rule? This Administration is forever known as the only administration that effectively rolled back, and in some cases outright repealed, many rules and regulations issued in years past. Just google the environmental regulatory rollbacks to get an idea. Great for the big players in the petrochemical and oil and gas industry, but why is this particular rule being pushed by the “regulatory rollback” Administration at the burden and expense of individual American gun owners? That may be a moot point now after the 2020 election, but it wasn’t many months ago when this process started.