ATTN: Bump-Fire Stock Owners, Sellers, Manufacturers, Distributors

From the Firearms Policy Coalition:

If you know of anyone who manufactures, distributes, sells, bought, owns, or possesses a “bump-stock” type device, or you/they did manufacture, distribute, or sell “bump-stock” devices but no longer do because of the ATF’s proposed ban, they should contact the Firearms Policy Coalition (FPC) Legal Action Hotline at https://www.firearmspolicy.org/hotline AS SOON AS POSSIBLE. FPC and Firearms Policy Foundation have retained Firearms Industry Consulting Group attorneys to oppose the ATF’s unconstitutional and unlawful proposed ban on these devices. If the ATF’s proposed rule goes into effect, it would require the destruction of all such devices, nation-wide, or a possessor might face federal felony criminal penalties and the loss of rights. For more information on FPC and FPF’s efforts to oppose the ATF’s proposed “bump-stock” ban, please see “FPC/FPF Opposition to ATF’s Proposed Ban on Bump-Stock-Type Devices (docket no. 2017R-22)” at https://www.firearmspolicy.org/fpc-fpf-opposition-atf-bump-stock-ban.

Bump-Stock-Type Devices Proposed Rulemaking

In case you haven’t commented on the proposed rule to ban bump-fire stocks, you should. Currently victim disarmers seem to be trying to flood the system with pro-ban comments.

Comment Here. Comments are due by June 27, 2018, at 11:59 PM ET.

You might consider something along these lines:

I oppose any rule redefining bump-stock-type devices (BSTD) as machineguns or any other type of firearm.

1. The description of how and what BSTDs do is grossly incorrect. While they assist in trigger reset, each shot fired still requires a separate operation of the trigger.

2. BSTDs do not increase the theoretical maximum rate of fire. In fact, since they bleed off recoil energy in order to assist in trigger reset, they can DECREASE the theoretical maximum rate of fire.

3. The The description of how and what BSTDs do conflicts with existing legislation defining machineguns (multiple rounds fired per operation of the trigger) as each round fired still requires manual operation of the trigger.

4. The rule is unenforceable: a) with no grandfathering it violates the Fifth Amendment as a taking without just compensation, b) no one knows how many BSTDs there are or where they are making confiscation without further Fifth Amendment violations impossible, c) the language is so vague that it would apply to any semiautomatic firearm that can be held in the non-firing hand (any semiautomatic firearm that can be so held can be bump-fired).

5. MILLER defined weapons which may be banned/regulated as those that are not in common military use; if a firearm with a BSTD is suddenly a “machinegun” — which are in common military use, they are protected under the SCOTUS MILLER decision, opening the ATF to lawsuits. You really don’t want to go there.

Welcome to the party, pal

Gun Owners of America finally notices the semiauto problem with bump-fire bans, and the crowd — finally — goes wild.

Let me tell you about a little-known pro-RKBA group. While GOA ignored this until a couple of weeks ago (when I started getting fundraising emails mentioning bump-fire stocks), and the National Restrictions Rifle Association actively pushed for it, The Zelman Partisans has been trying to warn you.

For months.

• The Zelman Partisans Statement on Proposed Legislation to Ban “Bump-Fire Stocks” and other accessories. (October 5, 2017)
  Basically this Constitution-shredding Senator wants to redefine “machine gun” by how fast you can make something fire, rather than being designed to fire automatically as long as the trigger is depressed. Apparently Jerry Miculek is going to be outlawed.
• Training Wheels (October 25, 2017)
  That is incorrect. An automatic weapon — a machinegun — is designed to fire multiple rounds per trigger operation. Bump-fire stocks in no way affect that operation/rounds relationship. If you put a bump-fire stock on a semiautomatic rifle, you still individually operate the trigger for each round fired. Bump-fire stocks don’t make the weapon fire faster. The theoretical rate of fire of the rifle is determined by the physics of the internal parts.
• The fix is in: proposed rulemaking on bump-fire
  Instead of looking at mechanical function, and simple physics, in this document the ATF has adopted the media and gun controller definition of “if it’s fast, it must be a machinegun.” The intent is preordained regardless of comments.
• Commenting Now Open: Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices. (December 29, 2017)
  Considering bump-fire stocks, and other accessories, to be machineguns would not simply regulate a physical device. It effectively outlaws the bump-fire TECHNIQUE, and even pulling the trigger faster than some arbitrary threshold.
• That’ll be our first one-term president in a while (February 20, 2018)
  I wish I could be surprised, but even before Trump began to look like a serious candidate– well before he got the R nomination — I warned that his new-found verbal respect for RKBA was belied by a long anti-RKBA history.
• “Stroke of the pen, law of the land. Kinda cool.”* (February 26, 2018)
  “Machinegun” is defined in statutory law. Short form: a firearm that fires more than one round per trigger operation.If that can be changed by executive order, instead of congressional legislation, then everything is a machinegun waiting for the pen-stroke.What can he — would he — do with that pen?
• Screw Physical Reality (March 10, 2018)
  If words having meaning, this is impossible without making every semiautomatic firearm an NFA item. Please note that this redefines machinegun without offering any grace period or grandfathering for existing gear.
• Bump-fire Banned (March 23, 2018)
  And yes; The Zelman Partisans opposes this. Accepting this is in no way a compromise. We did not get reciprocal carry. We did get a dangerous Fix NICS. And this isn’t a merely bump-fire ban; it’s effectively a ban on semiautomatic firearms (and if you think Feinstein, Schumer et al aren’t aware of that, you weren’t paying attention): parts is parts.
• Bumping Off the Truth (March 25, 2018)
  As noted on Friday, President Trump and AG Sessions announced a coming ban of bump-fire stocks (“bump-stock-type devices,” as the rule notice so eloquently puts it); no grandfathering, get rid of it or go to prison for possession of an unregistered NFA item.
• Theoretically Speaking (March 28, 2018)
  In every case, bump-fire stocks (and trigger cranks and “Multi-burst Trigger Activators”) are bad merely because they assist the shooter in approaching the firearm’s inherent theoretical maximum rate of fire. The semiautomatic rate of fire is the problem.Take away the bump-fire stock, crank, or multi-burp shoulder thingy, and the evil — to the gun ban bunnies — rate of fire remains.
  Does anyone reading this honestly doubt that establishing the precedent of the theoretical rate of fire being the problem is exactly what they want?
• “Bump-Stock-Type Devices” (sic) Commenting Now Open (March 29, 2018)
  The NPRM falsely states: “Specifically, these devices convert an otherwise semiautomatic firearm into a machinegun by functioning as a self-acting or self-regulating mechanism that harnesses the recoil energy of the semiautomatic firearm in a manner that allows the trigger to reset and continue firing without additional physical manipulation of the trigger by the shooter. Hence, a semiautomatic firearm to which a bump-stock-type device is attached is able to produce automatic fire with a single pull of the trigger.”
• Bump Stocks Matter: Banning Semiautomatic Firearms (April 2, 2018)
  If this were a move to specifically ban bump-fire stocks or trigger cranks on product safety grounds (unstable, inaccurate, etc.) you’d see a lot less opposition to it. But if you read the language of the Notice of Proposed Rulemaking [NPRM] (and every submitted bill I’ve tracked down so far), that isn’t what is being addressed. It is clearly and explicitly a “problem” of “rate of fire,” in that these devices — training wheels — assist the shooter in merely approaching the semiautomatic firearm’s theoretical rate of fire. (In the case of bump-fire, by using recoil to let the trigger reset, for the next manual operation.)

That’s a partial listing. You can find more.

You know what else “increases” the rate of fire? The breechloading Ferguson Rifle. Pre-measured paper cartridges. Revolvers. Bolt/lever action rifles with magazines. Slicked bolts and polished trigger groups. New springs.

Anything that improves the action.

Might I suggest joining the one pro-RKBA group that has consistently warned of, and opposed, these bans other others ignored, under-stated, or even supported them?

Trump announces he will not run for a second term

Bump-fire Banned
Let me drop this here before the sun sets.

Obama Administration legalized bump stocks. BAD IDEA. As I promised, today the Department of Justice will issue the rule banning BUMP STOCKS with a mandated comment period. We will BAN all devices that turn legal weapons into illegal machine guns.
— Donald J. Trump, 1:50 PM – 23 Mar 20181:50 PM – 23 Mar 2018

In case you’ve forgotten how stupid (and contrary to physical reality) this is.

And yes; The Zelman Partisans opposes this. Accepting this is in no way a compromise. We did not get reciprocal carry. We did get a dangerous Fix NICS. And this isn’t a merely bump-fire ban; it’s effectively a ban on semiautomatic firearms (and if you think Feinstein, Schumer et al aren’t aware of that, you weren’t paying attention): parts is parts.

As in: all parts of a machinegun are a machinegun, under federal law and rules.

How stupid is this?

This stupid:

Allowing physics

Can someone leak this moron’s college transcripts. He clearly failed physics.

Sessions says Justice Dept. inching closer to banning bump stocks
“We believe in that, and we have had to deal with previous ATF legal opinions, but our top people in the Department of Justice have believed for some time that we can through regulatory process not allow the bump stock to convert a weapon from a semiautomatic to a fully automatic.”

Since it’s physically impossible for a bump-fire stock to convert a semiautomatic rifle into a fully automatic rifle, not allowing it should be a snap.