Whenever the ATF tries to make a broad and sweeping change in the industry, they have to submit it for public commenting. ATF comments allow us to voice our own concerns, refute claims, and proposition our opposition to any new rule changes. I’m sure most of you know two big changes the ATF is trying to make regarding pistol braces and firearms frames and receivers.
Why So Late?
Many of you may feel this article is late. I think it’s right on time. When this all begins, tons of great articles and videos pop up on the interwebs discussing it; then it tends to peter out. For these two moves by the ATF, I decided to wait it out. The reason being is to keep the fire lit! To remind people the fight ain’t over, and if they haven’t made their ATF comments just yet, it’s time to jump on and get after it.
As many of you know, the ATF is targeting the legal use of pistol braces and working to redefine frames and receivers. Both rule changes are a terrible mess of bureaucracy. They are vague, unclear, and a massive pain to decipher. Caleb and Keith did two Gunday Brunch episodes that dive into both. Give both a watch if you want an in-depth explanation of the proposed rule changes.
Today we are going to talk all about how to form your ATF Comments and how to make them effective.
How To Construct Your ATF Comments
Ditch the Molon Labe
Seriously, comments just referencing the 2nd Amendment over and over are not going to work. If that was a factor, the ATF wouldn’t exist. I’m not saying I disagree with you or your sentiments. I’m just saying it won’t work. You can be right, or you can win. No one reading your ATF comments cares, sadly.
Focus On One Topic
The ATF might be a garbage fire of an agency with plenty of crimes that they never paid for, but these comments aren’t the time and place to come at them. Yep, they perpetuated Waco, Ruby Ridge, Fast and Furious, and so many more, but that won’t help preserve pistol braces or frames/ receivers. Keep your ATF comments on topic.
Use Facts
If you read the proposed rule changes for either the pistol brace or frame/receiver rule change, it’s easy to feel confused on the whole manner. Why? Because the rule changes are vague and seemingly sweeping. Point this out. Mention the confusing metric used in both rule changes.
Tell them that the definition of a frame or receiver will only affect law-abiding citizens and not criminals. Point out the definition of frame and receiver is much too vague to include the massive variety of firearms on the market. The proposed definition of the phrase readily is much too vague, and it’s impossible to know what’s legal or not.
With pistol braces, point out that their proposed rule is not based on law or the legal definitions of firearms. Mention that the ATF approved these devices for use and how a rule change could affect over 3 million gun owners overnight. If possible, personalize it. I’m a veteran who has had a nasty shoulder injury from my second deployment. Pistol braces are made for people like me, and I dang sure mentioned that.
Both rules are labeling themselves definitive definitions, but neither does that. It’s wise to point that out and mention how unclear the rules are and how the rules do not accomplish what they purport to do.
Don’t Copy and Paste.
Sometimes someone else’s comment says exactly what you want to say, and you think, boom, copy, paste, and now I’m done. I get it, but it turns out copy/pasted comments aren’t going to weigh as much as well-thought-out individual comments.
By all means, use a well-constructed comment, I found one on Reddit that was fantastic, and I used some of the same points in my comment. Sure it’s like cheating on your homework, but you’re just putting it in your own words.
Don’t Be a Jackass
Listen, none of us like the ATF or Fed Bois in general, but these comments are not the place to run your mouth. There are plenty of forums for that. Insulting, cursing, and acting like a jackass can and will get your comment tossed into the trash bin. It becomes a waste of time, and threatening feds will seemingly get you on a watch list.
Here’s what the ATF says – ATF may not consider, or respond to, comments that do not meet these requirements or comments containing profanity.
Don’t Forget the Docket Number!
Make sure you reference the docket number in your comments! If not, the comment doesn’t count. I can’t help but feel this is silly since the page you go to comment specifically links to the docket you’re commenting on. I’m saying it’s purposeful, but it sure seems that way. When making your ATF Comments include these two numbers.
Pistol braces – ATF 2021R-08
Frames/Receivers – ATF 2021R-05
If you’ve already commented and forgot the docket number, go back and comment once more referencing it. It might be a hassle, but it’s worth it!
The gun industry can be a lot of tough talk, but I’m constantly amazed how much tough talk turns into absolutely zero action. A comment, a letter to an elected official, etc, is the first step to fighting for your freedom and doesn’t even require you to work up a sweat. If proposing a comment is too tough for you to do, drop the tough talk and take that Molon Labe sticker off your F150.
