Final Comments On Bump Stock Device Rulemaking, Federal Register Number 2018-06292
BY Herschel Smith
6 years, 8 months ago
Since it is obvious that the decision has been made and all comments will be submitted to no avail, these will be my last comments concerning the rulemaking.
First of all, unless and until you have dealt honestly and in detail to my first set of comments, your response is incomplete and lack of forthrightness cowardly.
Second, I realize I am demanding that you do something beyond your capabilities, but until and unless you honestly address every one of the comments made by James Wesley Rawles, it will be apparent to readers that you have no way to respond in a manner that is logically coherent, legal, and rhetorically compelling. In other words, the vacuous nature of your position will be manifest before the public.
Finally, I offer two additional comments beyond what I proffered earlier.
- Note for the record any and all registered professional engineers employed and/or contracted and remunerated by the ATF or DOJ, whose job it was to provide input, calculations, analysis or opinions on the technical issues pertaining to this rulemaking. Provide those analyses for our review, and list the PEs by name, license number and state. State laws for all fifty states require that such analyses be traceable and sealed or stamped by the PE. If no PEs have reviewed the technical issues pertaining to this rulemaking, say so with specificity and clarity.
- Note for the record any and all licensed professional gunsmiths employed and/or contracted and remunerated by the ATF or DOJ, whose job it was to provide input, analysis or opinions on the technical issues pertaining to this rulemaking. Provide those analyses for our review, and list the gunsmiths by name, license number and state. If no gunsmiths have reviewed the technical issues pertaining to this rulemaking, say so with specificity and clarity.
The goal of said discovery will be to hold licensed PEs accountable before their respective state licensure boards. If no PEs have reviewed the rulemaking, the goal will be, among other things, to trumpet loud and long the illegitimacy of the rulemaking due to lack of technical rigor or qualified oversight. Illegitimacy of the rulemaking will redound to the illegitimacy of the ATF itself.
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On April 19, 2018 at 11:20 am, Gryphon said:
Professional Engineers providing Input on a non-Constitutional bureaucratic ruling? HAHAHAHAHAHAHA!!!!
As You said, Public Comments/Input is Meaningless, so would be trying to Pursue and Harass any ‘outside consultants’ the bureaucracy ‘hired’.
Only Thing that will matter Now is just How they try to Enforce what will be a Backdoor Ban on semi’s.
On April 19, 2018 at 3:02 pm, Mike said:
Quote from barnbwt –
“This “insignificant act” applies to damn near anything you can do to damn near any autoloading firearm design. “Rate increase” is such a vague and broad term, anything from drop in triggers to muzzle brakes, to silencers, and even lubricant could be drawn in if desired.
It effectively puts *ALL* semi-autos under a “sporting purposes” clause at the Attorney General’s discretion. If they think the gun was designed to have an “increased” rate of fire (whatever they think that means; anti-gunners think revolvers shoot too quickly) they would be able to have it classified as a machine gun. Same goes for any accessories that can be installed to make a gun shoot faster (which includes sights, stocks, and even lubricants)
Just because you aren’t interested in bump stocks, doesn’t mean you won’t experience consequences from your refusal to defend them. ”
-Well said