"@ATFHQ repudiates its existing regulatory definition of “the frame or receiver," claim[s it] has never actually applied to anything[&]simply ignored it—deliberately misinterpreting & misapplying its own rule even while chiding federal courts for not participating in the charade"
"ATF attempts to explain what it means by claiming that an item becomes a firearm when it 'may readily be completed'–defining 'readily' by changing the statutory term 'readily be converted' to 'readily be assembled, completed, converted, or restored.'"
"To preserve its unrestricted authority to impose arbitrary standards on a case-by-case basis, ATF injects an additional half dozen vague adjectives and adverbs which are inherently malleable, flexible, vague, standardless, and open to infinite interpretation"
"Then, to provide further “clarification” of its clarification, ATF provides an additional eight-part test with even more vague and standardless concepts such as “how long” and “how difficult.” Par for the course, ATF never explains what any of this means."
"ATF then adds another 7 types of items it may consider to determine if an item is a firearm such as 'instructions'& 'equipment' but doesn't explain how the[y] would be considered"
"ATF thus creates a definition, within a definition, within a definition, within a statutory term"
"Moving even further down the rabbit hole of absurdity, the agency offers the famous 'looks like a duck test.'"
"ATF opines that items which are 'identifiable as an unfinished component part' are firearms regardless of functionality or even their stage of completeness."
"Apparently recognizing the confusion inherent in its tests, @ATFHQ promises that it won’t arrest anyone for possessing a solid block of metal–the 'primordial state' test."
Of course, if the owner of the block of metal also dared to possess a drill bit, or if the block of metal had a drawing of a gun on it, then it is definitely a firearm.
"It has yet to be seen whether, under th[e PR], users of 3D printers will need to pass a background check before they can purchase spools of plastic filament from licensed gun dealers"
"After all, Legos can be dangerous if they fall into the wrong hands"
"Lurking just inside this Trojan horse lies the true intent of ATF’s proposed changes:"
"to eliminate the sale of. 'solvent traps' & "fuel filters...' eliminating the ability of most @gunowners to lawfully manufacture their own suppressor after receiving an approved Form 1"
"Anyone who changes his own oil is now a felon"
- @ATFHQ violating Americans' constitutionally-protected rights
"ATF claims that an item is a silencer if it 'contains all the component parts necessary' to build a suppressor, regardless of whether they were ever intended or possessed for that use & regardless of whether they are even 'operable' once assembled"
"In order to accomplish this illegitimate purpose of serializing “all firearms,” the PR... rewrit[es] & greatly expand[s] the statutory requirements that only “manufacturers” & “importers” (not all FFLs) must mark guns they “manufacture” or “import” (not all guns they “acquire”)"
As its pièce de résistance @ATFHQ seeks to thread the various parts of its Proposed Rule together in order to further an apparent scheme to create a national gun registry
For the reasons stated above, the Proposed Rule should be withdrawn in its totality
⚠️ It appears that ATF has intentionally designed its Factoring Criteria for Rifled Barrel Weapons w/ Accessories Commonly Referred to as “Stabilizing Braces” to effect a complete ban of every pistol-braced firearm currently on the market