ATF rulemaking and comments

 The rule would redefine a firearm receiver as well as modify the definition of 80% receivers.

You can comment here but the comment period closes on August 19th.

FWIW, here's my comment.  Feel free to copy, plagiarize, alter, or share.

For each of my objections I have included a quote and an explanation.

1. "would require acquisition and disposition record changes to accommodate recording multiple frames or receivers that have different serial numbers if the original frames or receivers (with the same serial number) become separated and are reassembled with frames or receivers bearing different serial numbers."

Objection: Would the owner of a firearm with "multiple" receivers have to submit paperwork in order to swap parts between firearms. Many firearms are designed to easily switch components in order to fire different calibers for different purposes. What happens to a firearm owner who changes the caliber of their firearm but then sells the unneeded parts, even through an FFL? Would two background checks be required to purchase an AR-15 for example, one for the upper and one for the lower and would an owner then be required to maintain them together? (As an example I point you to the current situation where "parts for a sound suppressor" are considered a sound suppressor. I have been advised that having spare baffles for a suppressor without a separate tax stamp could be a violation and that a licensed suppressor owner should, therefore, not maintain or service their own items.

2. "such that they may readily be completed,"

Objection: Readily is a value laden term. I have friends who have built pistols from 80% kits. The fitment of parts is poor, they are unreliable, etc. I have also watched videos which generally suggest that building such a firearm is simple and straightforward. With more research I found that completing these firearms requires significant amounts of high quality machining equipment (drill presses, dremel stands, x-y machinist tables, as well as expensive bits) in order to do properly. It is not a simple task if done properly. It is unclear from the proposed rule whether the ATF intends to define the term "readily" to reduce the % designation or if it will vary from firearm to firearm as to what qualifies. Having only talked to people about 1911, AR15, and SIG P320, and having seen different levels of "readily" even across these three, I am unsure if there is a consistent standard that could be applied. If it becomes easier in the future due to the development of less expensive tooling, would the ATF then eventually, on the principle of "reductio ad absurdem", declare that blocks of metal were "readily convertible"? The development of 3-D printers over the past decade suggests that the agency would almost have to.

3. "approximately 23,906 suspected PMFs reported to ATF as having been recovered by law enforcement from potential crime scenes"

Objection to rationale: What percentage of these recovered PMFs were actually involved in the crime being investigated and therefore what percentage are relevant to the discussion of regulation? If I legally build a PMF and then am arrested for embezzlement is there any relevance to the fact that an un-serialized firearm was found at my home or office? Additionally, given my previous comment about the increasingly effective technology available for building firearms, is there any reason to think that the problem of "untraceable firearms being acquired and used by violent criminals and terrorists" is related to the 80% firearms industry that you propose to regulate? Presumably these organizations are capable of manufacturing their own 80% receivers, which means that the regulations proposed will mostly affect hobbyists who like the challenge of building their own firearms but who do not have the resources to do so from scratch.

4. "With the proliferation of PMFs, ATF has also received numerous requests from licensees seeking clarity on how they may be accepted and recorded so that they can ...mreport lost or stolen PMFs "

Objection: Finally, my understanding of federal law currently allows individuals who are legally permitted to possess a firearm to manufacture their own firearm without serialization if it is for their own use and will not be gifted or sold. If a PMF ends up at a firearms dealer, that almost by definition means that it is intended to be sold or transferred in some way. Does not federal law already require that the firearm be serialized before further transfer? Perhaps I am wrong on this but it then becomes the "simple" task of the dealer to serialize the firearm and inform the ATF of said action. I would point out that this action fits a simple definition of "readily" than the actual original manufacture. Unless a regulation is being proposed that would flat out ban the manufacture of a firearm for personal use I don't see the issue here or the point of the new regulation, except as a means to ban something that is, for most, a hobby.

Thanks for taking my opinions into account. As I said earlier, I am a mechanic but not a machinist and I find the process of making these firearms technical and relatively difficult.