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.