AR Pistol braces, let ATF know you opinion

[Sundance]

BATFE has submitted a letter of intent and request for comment on shoulder braces. We have until Jan. 4, 2021 to tell them how we feel.
Noir's video does a ggod job of outlining how dumb it is:

Here's a link to the BATFE request for comment page.

Objective Factors for Classifying Weapons with "Stabilizing Braces"

There is a 'Comment' button in the top right. With 300+ million in the US, only 4700+ comments tells the BATFE that only a small percentage of americans care

Please comment on the offical site.

Read More

 

[aksu747]

BATFE has submitted a letter of intent and request for comment on shoulder braces. We have until Jan. 4, 2021 to tell them how we feel.
Noir's video does a ggod job of outlining how dumb it is:

Here's a link to the BATFE request for comment page.

Objective Factors for Classifying Weapons with "Stabilizing Braces"

There is a 'Comment' button in the top right. With 300+ million in the US, only 4700+ comments tells the BATFE that only a small percentage of americans care

Please comment on the offical site.

Or we don't want the ATF to be tracing our IP addresses.
Anyway F*** the ATF.

F U is all I have to say to these unconstitutional bastards.

 

[Maximum1]

It's clear from the Stabilizing Brace document released by the ATF says that each firearm must be examined on a "case-by-case" basis. Except with all the caveats the agency added, it seems highly unlikely that any rifle-caliber-pistol would pass muster and each would be found to be a short barrel rifle if only one of the criteria is needed to be failed.

ATF Decision Could Lead to Biggest Gun Registration, Turn-in Effort in American History...not surprising given the fact ATF leadership met with members of the Biden transition team at which time the acting heads of the ATF told the Biden team their top two immediate priorities were 1) 80% lower gun kits and 2) Stabilizing Braces

• Within weeks of the meeting with the Biden team ATF raids Polymer80 and issues Objective Factors for Classifying Weapons with "Stabilizing Braces"
  • The ATF now deems the Buy Build Shoot Kit meets the definition of a firearm
  • The ATF now deems Stabilizing Braces constitutes an Short Barreled Rifle

 

[Kindrox]

This is what I wrote as a comment. I am sure posting something is better than nothing, but simply posting "I don't like it" is probably not as useful as pointing out the foolishness in their proposal.


Dear Sir or Madam,

I think you folks need to go back to the drawing board on the topic of guns before you tackle "Stabilizing Braces". Note that "intended to fire . . . when held in one hand" is in your definition of "Pistol".

I have shot many "Pistols" and have almost never shot one with one hand. I have taken pistol and self-defense classes and have never been taught to shoot a "Pistol" one handed.

At the range, anyone shooting a "Pistol" one handed is an oddity to the point of drawing attention.

Your 12/18/2020 letter says that you (BATFE) feel you need to reexamine "Stabilizing Braces" based on how people are using them now versus before.

Well, perhaps you need to reexamine Pistols based on how people are using them now versus before. As a specific example, I am pretty sure the S&W 500 I shot (and all magnum "Pistols") should be classified as a rifle because I am a larger man, and I can barely control a S&W 500 "Pistol" with two hands. It would fly back into my face one-handed. I am quite sure the inventors shot that "Pistol" two handed every single time.

I am not sure if the BATFE has a sense of irony, that many magnum (and brace-less) "Pistols" can't be fired one handed by anyone without a God-like ham-sized hand, but an object like a stabilizing brace which enables a "Pistol" to be more easily shot by one hand might be judged to be less "Pistol" like.

Your proposed list of design features that will help you sort the "Pistols" from not-pistols also seems to be unaware of decades of firearm history. For example:

Type and Caliber design feature - impractical to fire with one hand? Whose hands count under this very subjective test? My wife will not shoot a 357 Magnum even with two hands. Does that mean 357 Magnums can't be pistols now? I will not shoot a S&W 500 with one hand. Does that mean firearms chambered in that caliber can't be "Pistols"?

On the other hand, 5.56x45 NATO was first chambered in a rifle. But my wife loves to shoot it as it has almost no recoil in any firearm. She can shoot a 16 inch AR15 rifle one-handed. Perhaps all those firearms are "Pistols" given the low recoil?

Weight and Length design feature - A S&W 500 can weigh 5 pounds and few adults could safely fire it one handed. AR15 pistols can weigh 5 pounds and most adults could safely fire it one handed. I am losing track of exactly how you will use weight to sort "Pistols" from everything else.

As to length, if your intention is to discourage criminal use of firearms, isn't bigger "Pistol" size (all other things being equal) better? Is criminal use of "Pistols" more heavily weighted towards bigger and heavier models, or is it exactly the opposite?

Length of Pull design feature. If a "Stabilizing Brace" is so long that the average person feels it is the optimal distance between the trigger and the shoulder, then I see your point. However, I understand that most braces have a length of pull of 13.5 or fewer inches. I suspect you will find 13.5 inches is far less than the vast majority of commercial rifle stock Length of Pulls.

Likewise, when you judge a firearm on the presence of a Secondary Grip, because suddenly the firearm is not designed or intended to be fired with one hand, it makes it sound like you have never gone to a pistol range and observed. Who in real life, outside of gang bangers shooting pistols one-handed and sideways, is firing "Pistols" one handed?

Maybe it would be easier for everyone if you (BATFE) went and observed what folks are really doing at the gun range, figure out what gun features criminals are exploiting, and at least base any rules and definitions based on real life.

Stepping on the necks of the law abiding and preventing things that criminals do not want to do anyway is a double waste of time.

Maybe it would make sense to decide that "Pistols" are anything under certain physical size limits, and rifles are anything that are not "Pistols".

Then at least you can be fulfilling your mission of sorting between things that are easily concealed and things that are not, and you can stop trying to stop trying to make arbitrary rules that do not have a basis in the real world.

 

[Elws25]

What part of "Shall not be infringed" do they not understand?

The fact is this:

They don't care. They don't care about our input either. They have an agenda and they're going to follow orders. Thats that.

 

[FireArm]

What part of "Shall not be infringed" do they not understand?

The fact is this:

They don't care. They don't care about our input either. They have an agenda and they're going to follow orders. Thats that.

Call, dont leave your name though. tell them to leave 80%s alone also!

 

[Kindrox]

It is true that Nancy P does not care about your opinion. But many politicians are in competitive districts and do want to get re elected. Those folks will listen if they think enough people are passionate about sometime, enough to affect their election prospects.

If enough people jump up and down about firearms, you might find that Biden decides he just needs to "try" something, let it fail, and move on.

 

[CamoDeafie]

It is true that Nancy P does not care about your opinion. But many politicians are in competitive districts and do want to get re elected. Those folks will listen if they think enough people are passionate about sometime, enough to affect their election prospects.

If enough people jump up and down about firearms, you might find that Biden decides he just needs to "try" something, let it fail, and move on.

What does that have to do with anything the ATF does? After all, the leadership in it was placed by Obama and other politicians, and have not been replaced. The agency is not staffed by elected people (maybe it should be...?) But by appointed people. Sure Congress control the funding for the ATF; but when have we ever seen a funding cut to the ATF?

 

[GrayGoose]

I think you folks need to go back to the drawing board on the topic of guns before you tackle "Stabilizing Braces". Note that "intended to fire . . . when held in one hand" is in your definition of "Pistol".

I have shot many "Pistols" and have almost never shot one with one hand. I have taken pistol and self-defense classes and have never been taught to shoot a "Pistol" one handed.

At the range, anyone shooting a "Pistol" one handed is an oddity to the point of drawing attention.

^^^ That right there!!!^^^
It is too obvious that the BATF knows nothing about shooting pistols. Maybe they should instead be defining the proper way to open a box of Kraft Mac-n-Cheese and leave the important stuff to the experts.

 

[Eveskcige28]

What does that have to do with anything the ATF does? After all, the leadership in it was placed by Obama and other politicians, and have not been replaced. The agency is not staffed by elected people (maybe it should be...?) But by appointed people. Sure Congress control the funding for the ATF; but when have we ever seen a funding cut to the ATF?

I'm liking this idea of elected officials. However given the current election I dont know that we could trust any of it. We might end up with some extremist crackpot at the head of the atf...

 

[Kindrox]

Before the election we heard all about how republicans would lose the senate by many seats. Now, at worst it is tied and at best there is a +2 republican majority.

Politicians know that historically, gun owners vote, and they vote more if you piss them off.

Will democrats support Biden pissing off gun owners when they only have a slight majority, or will they encourage him to spend his political capital somewhere else?

 

[CamoDeafie]

Before the election we heard all about how republicans would lose the senate by many seats. Now, at worst it is tied and at best there is a +2 republican majority.

Politicians know that historically, gun owners vote, and they vote more if you piss them off.

Will democrats support Biden pissing off gun owners when they only have a slight majority, or will they encourage him to spend his political capital somewhere else?

Again... what does that have to do with the ATF ? Far as I can tell, only the head of the ATF is an appointed position and that is by Presidential Cabinet, not by Congress?

Yes funding comes from Congress but, again, when have Congress ever cut funding to the ATF, with Congress under control of either Party?
I'd love to see the ATF completely disbanded and abolished, as well as a complete nullification and voiding of all Federal Gun laws, but that won't happen any time soon

 

[CamoDeafie]

some extremist crackpot at the head of the atf...

As opposed to the current extremist crackpot already there?

 

[Stomper]

What part of "Shall not be infringed" do they not understand?

The fact is this:

They don't care. They don't care about our input either. They have an agenda and they're going to follow orders. Thats that.

Exactly, if the unelected BATFE bureaucrats want your opinion... they'll give it to you.

If you don't vote for the POTUS candidate they want, they'll hack the results and get the one they want anyway.


WTH do y'all think you are anyway? Sit down, shut up, do as you're told... and pay your taxes, plebe.


This comment period is merely a legal formality they're bound by law to observe, before they go forward with their intended direction..... pure theater.

 

[asiparks]

Every firearms forum get monitored by the BATFE, they watch the same youtube vids we do, they're pretty aware of some gunowners thoughts and feelings about braces. Pretty doubtful writing a letter is going to sway anything- The invitation for public comment is a polite formality.

The Firearms Technology Criminal Branch ("FTCB") and the Firearms Technology Industry Services Branch ("FTISB") have samples of every brace and firearm available, whether manufacturer supplied or not. ( Don't forget they examine firarms and accessories submitted by "the public" too. ).
They will be picking up and evaluating each of them and saying- yes, this effectively behaves as an SBR.
Doesn't matter if it has velcro or a squishy, split rubber pad at the end, if you can shoulder it and get any kind of cheek weld, then it's likely going on the naughty list. Again, it hasn't happened yet, but this document does telegraph the BATFE's intent.
Still, this is a proposal. Another, completely different proposal or proposals could be issued as soon as Biden installs his own AG, so I'm just going to keep on keeping on until something actually happens.

"ATF's longstanding and publicly known position is that a firearm does not evade classification under the NFA merely because the firearm is configured with a device marketed as a "stabilizing Start Printed Page 82518brace" or "arm brace." [8] When an accessory and a weapon's objective design features, taken together, are not consistent with use of the accessory as an arm brace, that is, not to stabilize a handgun when being operated with one hand, such weapon, configured with the accessory may fall within the scope of the NFA, particularly where the accessory functions as a shoulder stock for the weapon. Accordingly, ATF must evaluate whether a particular firearm configured with a stabilizing brace bears the objective features of a firearm designed and intended to be fired from the shoulder, and thus subject to the NFA, on a case-by-case basis."

"Intent" is really hard to prove- So likely the regulations will be worded to make sure as many braced weapons are covered- and wording will be inserted to make it harder for manufacturers to get creative trying to circumvent the regs. If the BATFE could show that for every 1 disabled vet firing it braced with one hand, there were 10,000 non-disabled people firing their braced pistols 2 handed or shouldered-ish......

"If ATF's classification of a submitted sample demonstrates that the objective design features of the firearm, as configured, do not support the manufacturer's purported intent and characterization of the accessory on that particular firearm as a "stabilizing brace" or "arm brace," ATF will classify the firearm based on the objective design features, as Federal law requires."

There follows a list of features that pretty much lets you lnow that most existing braced pistols are going to fall into the SBR class.

Type and Caliber, Weight and Length, Length of Pull. Attachment Method and Stabilizing Brace Design Features; The latter, design features, ensure that if it looks stock-like and can be shouldered- it'll be a "stock"

"This notice also outlines ATF's enforcement priorities regarding persons who, prior to publication of this notice, made or acquired, in good faith, firearms equipped with a stabilized brace."

Skipping ahead:

"ATF recognizes that before issuance of this notice, there was a misunderstanding by some that a pistol assembled with any item purported to be a stabilizing brace still would be considered a "pistol" regardless of other characteristics. The objective factors discussed here make clear that while some stabilizing braces may lawfully be used on pistols without bringing the firearm within the purview of the NFA, that is not necessarily the case for every "pistol" because some firearms are configured or have characteristics such that they meet the statutory definition of "rifle or shotgun" (hereafter, "affected stabilizer-equipped firearms"). ATF understands that most individuals who acquired affected stabilizer-equipped firearms did so in good-faith reliance on representations, made by those selling the stabilizing braces or the firearms, that those firearms were not subject to the NFA.

Consequently, following issuance of this notice, ATF and DOJ plan to implement a separate process by which current possessors of affected stabilizer-equipped firearms may choose to register such firearms to be compliant with the NFA. As part of that process, ATF plans to expedite processing of these applications, and ATF has been informed that the Attorney General plans retroactively to exempt such firearms from the collection of NFA taxes if they were made or acquired, prior to the publication of this notice, in good faith. This separate process may include the following options: registering the firearm in compliance with the NFA (described above), permanently removing the stabilizing brace from the firearm and disposing of it, replacing the barrel of the firearm (16" or greater for a rifle, or 18" or greater for a shotgun), surrendering the firearm to ATF, or destroying the firearm.Start Printed Page 82520

Until that process is separately implemented, and absent a substantial public safety concern, ATF will exercise its enforcement discretion not to enforce the registration provisions of the NFA against any person who, before publication of this notice, in good faith acquired, transferred, made, manufactured, or possessed an affected stabilizer-equipped firearms."

So I guess the good news is that although you'll have the option to add your pistols to the NFA register, you won't be taxed.

 

[CamoDeafie]

Its real easy to see what the ultimate endgame is for the ATF....
every gun owner with a semiautomatic firearm is a potential "criminal". That's why they are being intentionally vague about what is, and isn't considered okay.

Were the entirety of NFA 1934 and GCA 1968 repealed, we wouldn't have such issues today

In fact, to simplify things, if Congress must maintain " multiple definitions of arms" ( as if 2A doesn't differentiate between types of arms )
Then I would propose..

A pistol/handgun is simply a firearm with no shoulder stock, and can be made from a rifle with no restrictions.

A rifle has a shoulder stock, no barrel length restrictions, none of that "once a rifle always a rifle" bovine excrement.
It also does not matter if its bolt, pump, semi, burst, full auto.

A machine gun is a fully automatic weapon, with either belt or magazine feed, and heavier than a standard infantry rifle/carbine. It may be classed further into submachine(Sten/Uzi types) , light (M16, BAR 1918, M14, SAW, M240, M60, etc), and heavy machine guns(.50BMG for example). No barrel length restriction, no caliber restriction, no restrictions nor registration needed, no firearm age restriction (elimimate FOPA 1986's Hughes amendment)

A carbine is simply a shorter rifle

A shotgun has a smoothbore barrel, no barrel length restriction, and doesn't matter stocked or not.


Addendum to 2A, arms meant for military use are fully protected with the same "lack" of regulations as sporting arms.

 

[Maximum1]

What part of "Shall not be infringed" do they not understand?

The fact is this:

They don't care. They don't care about our input either. They have an agenda and they're going to follow orders. Thats that.

Tell the BATFE instead of bloviating on a forum. If you are not willing to stand up and fight we don't care about what you post.

 

[BrentN]

This is what I wrote as a comment. I am sure posting something is better than nothing, but simply posting "I don't like it" is probably not as useful as pointing out the foolishness in their proposal.


Dear Sir or Madam,

I think you folks need to go back to the drawing board on the topic of guns before you tackle "Stabilizing Braces". Note that "intended to fire . . . when held in one hand" is in your definition of "Pistol".

I have shot many "Pistols" and have almost never shot one with one hand. I have taken pistol and self-defense classes and have never been taught to shoot a "Pistol" one handed.

At the range, anyone shooting a "Pistol" one handed is an oddity to the point of drawing attention.

Your 12/18/2020 letter says that you (BATFE) feel you need to reexamine "Stabilizing Braces" based on how people are using them now versus before.

Well, perhaps you need to reexamine Pistols based on how people are using them now versus before. As a specific example, I am pretty sure the S&W 500 I shot (and all magnum "Pistols") should be classified as a rifle because I am a larger man, and I can barely control a S&W 500 "Pistol" with two hands. It would fly back into my face one-handed. I am quite sure the inventors shot that "Pistol" two handed every single time.

I am not sure if the BATFE has a sense of irony, that many magnum (and brace-less) "Pistols" can't be fired one handed by anyone without a God-like ham-sized hand, but an object like a stabilizing brace which enables a "Pistol" to be more easily shot by one hand might be judged to be less "Pistol" like.

Your proposed list of design features that will help you sort the "Pistols" from not-pistols also seems to be unaware of decades of firearm history. For example:

Type and Caliber design feature - impractical to fire with one hand? Whose hands count under this very subjective test? My wife will not shoot a 357 Magnum even with two hands. Does that mean 357 Magnums can't be pistols now? I will not shoot a S&W 500 with one hand. Does that mean firearms chambered in that caliber can't be "Pistols"?

On the other hand, 5.56x45 NATO was first chambered in a rifle. But my wife loves to shoot it as it has almost no recoil in any firearm. She can shoot a 16 inch AR15 rifle one-handed. Perhaps all those firearms are "Pistols" given the low recoil?

Weight and Length design feature - A S&W 500 can weigh 5 pounds and few adults could safely fire it one handed. AR15 pistols can weigh 5 pounds and most adults could safely fire it one handed. I am losing track of exactly how you will use weight to sort "Pistols" from everything else.

As to length, if your intention is to discourage criminal use of firearms, isn't bigger "Pistol" size (all other things being equal) better? Is criminal use of "Pistols" more heavily weighted towards bigger and heavier models, or is it exactly the opposite?

Length of Pull design feature. If a "Stabilizing Brace" is so long that the average person feels it is the optimal distance between the trigger and the shoulder, then I see your point. However, I understand that most braces have a length of pull of 13.5 or fewer inches. I suspect you will find 13.5 inches is far less than the vast majority of commercial rifle stock Length of Pulls.

Likewise, when you judge a firearm on the presence of a Secondary Grip, because suddenly the firearm is not designed or intended to be fired with one hand, it makes it sound like you have never gone to a pistol range and observed. Who in real life, outside of gang bangers shooting pistols one-handed and sideways, is firing "Pistols" one handed?

Maybe it would be easier for everyone if you (BATFE) went and observed what folks are really doing at the gun range, figure out what gun features criminals are exploiting, and at least base any rules and definitions based on real life.

Stepping on the necks of the law abiding and preventing things that criminals do not want to do anyway is a double waste of time.

Maybe it would make sense to decide that "Pistols" are anything under certain physical size limits, and rifles are anything that are not "Pistols".

Then at least you can be fulfilling your mission of sorting between things that are easily concealed and things that are not, and you can stop trying to stop trying to make arbitrary rules that do not have a basis in the real world.

I applaud your efforts. But I think it will take someone with deep pockets to fight this in court, a million letters like this won't encourage them to change course. I'm sure they are all well aware that these moves are pizzing off half the country.

 

[spider]

Does anyone remember bump stocks?

 

[Maximum1]

American gun owners did not violate existing regulations, nor did they sign up to, after the fact, to be forced to submit to the largest gun registration in the history of the United State or be forced to give up their personal property under the threat of imprisonment, fine or both.

The fact is the firearm industry has for many years been submitting firearms with stabilizing braces affixed to them and in all those 100+ submissions never has the BATFE warned or put a manufacturer or vendor on notice for violation of the National Firearms Act.

Now after millions of firearms along with stabilizing braces have been purchased Americans must strongly refute BATFE's effort to put millions of Americans in a position of having to jump through regulatory hoops, which is not only going to greatly inconvenience those who now own such firearms, to fill out a form, with the help of an approved dealer, that is then sent to the Bureau of Alcohol, Tobacco, Firearms, and Explosives (BATFE). As an individual, they will need to get a signature from their local law enforcement official and include a set of fingerprints.....fingerprints! Then to require millions of Americans to fill out forms in order to get permission from the government every time they take private property across state lines, in addition to opening up their private residences and storage areas to possible inspection from the BATFE when they never have been subjected to that before is completely beyond inappropriate.

One of the arguments used in favor of adjustable stabilizing braces for AR calibers firearms applies to the SBR debate itself. As we know, adjustable braces don't make a firearm more dangerous-er. They simply allow easy and proper fit of the firearm to the shooter, regardless of size and what they're wearing at the time. A person with a shorter forearm brings in the stabilizing brace. A person with a longer forearm, extends the brace. One size does not work for all. It's simply a feature that helps the shooter use and control the firearm properly. Again, it does not make it more dangerous unlike a fully automatic weapon that is clearly within the scope of the NFA.

BATF must their pursue to restrict the features that facilitate safety and accuracy. It's not like reclassification will prevent criminal use.