GOA and GOF are opposing the ATF’s ban on 40 million braced firearms.
ATF’s Notice of Proposed Rulemaking is entirely arbitrary and capricious, effecting a complete policy change as to how the ATF treats firearm stabilizing braces, yet failing even to acknowledge (much less provide justification for) that tectonic shift. Masquerading as a helpful rulemaking “to assist” gun owners and the firearms industry in complying with the law, in reality the NPRM is designed with the obvious and specific intent to largely outlaw the use of stabilizing braces on firearms, threatening millions of current owners with imprisonment and putting a large segment of the gun industry out of business entirely.
To accomplish this goal, the NPRM creates “Worksheet 4999,” which contains three sections of analysis, each more restrictive than the last, designed to ensure that virtually no stabilizing brace is eligible for use on a non-rifle firearm, and thereafter ensuring that most firearms do not qualify to even use an allowed stabilizing brace. After all of that, ATF reserves unto itself the unbridled discretion to override the results of the worksheet at any time and for any reason, creating a system where no person or company could possibly rely on anything the agency says.
In setting up this impossible new regime, the NPRM conflicts with numerous existing ATF policies as to how firearms are analyzed, repudiates all prior agency guidance and classification letters on stabilizing braces, and rewrites the language of the statute Congress enacted. For those reasons and others, discussed in more detail below, the NPRM should be withdrawn.
You can download GOA’s official comments here.