I don’t think any of us like to see new proposed regulations when it comes to gun rights but the fact of the matter is that it is simply the reality that we live in right now. Thankfully, we have many tools at our disposal for making our voices and opinions heard and we aren’t just stuck shouting into the void with our guns in our hands. One of the most effective means by which we can counteract any proposed rulemaking by the ATF is by submitting comments. This is a fairly quick and simple method to encourage the ATF to rethink their proposed rulemaking. So today I’ve put together a brief guide for you to follow when commenting on proposed ATF regulations now and in the future.

More on the ATF @ TFB:

• ATF: Factoring Criteria for Firearms with Attached Stabilizing Braces
• New ATF Regulations Turn Every Nerf Gun into an 80% Receiver?
• Breaking: Marijuana Disqualification Question To Be Removed From ATF 4473
• AutoKeyCard Shut Down, Website Seized, Owner Arrested

How to Effectively Comment on Proposed ATF Regulations

1. Focus Focus Focus

One of the easiest things for us to do when submitting a comment regarding any specific rulemaking is to get off in the weeds about something else that might be tangentially related to the current topic at hand. I most recently submitted a comment on ATF Proposed Rule 2021R-08 which is specifically talking about pistol braces. While it would be easy for me to also comment about 80% receivers, I should specifically avoid that because to a bureaucrat anything not specifically related to the topic at hand will just be thrown out as useless information.

So when you go to submit a comment, stay focused on the topic at hand. For ATF Proposed Rule 2021R-08 you can make specific mention of the following items regarding pistol braces:

• You can point out the vague nature of the proposed rule or the needless complexity of the rule
• You can point out that the rule is inherently subjective in nature
• You can mention that millions of pistol braces exist and this is a direct result of previous ATF rulemaking
• You can remind the ATF that the rule will disproportionately affect law-abiding citizens rather than criminals

2. Own it Like John Hancock and Don’t be a Jerk

John Hancock is probably best remembered for his extremely large and ostentatious signature on the Declaration of Independence. I know it seems really cool to remain anonymous online but when it comes to ATF rulemaking, you’ll want to make sure the ATF knows you’re a real person. Don’t use an alias, fake name, imaginary name, meme name, offensive name, or any other name that isn’t your own. Anonymous comments don’t count. I think this quote from the movie Troy best sums this point up:

Like I said above, bureaucrats don’t tend to receive online humor well and they will more than likely throw out a comment instantly if the name SniperDragon420 shows up in the name field. You’ll also want to avoid any profanity, name-calling, or accusations against the ATF or their personnel that could be construed as personal attacks. The most effective comments will be ones that are polite, to the point, and show that you have a clear understanding of the proposed rulemaking and why you disagree with it.

3. Don’t Spam the ATF – Spread the Word Instead

The ATF does in fact review and classifies each comment they receive as being “for” or “against” their proposed rulemaking. The ATF also keeps track of how many comments are essentially cut and paste versions of the same prefab comment and while this might be an effective way to flood the ATF with the same information, it simply doesn’t look good on our part.

Leave a unique comment. Remember to keep it to the point and on the topic but make it your own. Use your own language and don’t submit several comments just to pump the numbers up. You should encourage your friends, your parents, your kids, and anyone who is even remotely interested in firearms to write their own comment. Social media is often a tool that can be weaponized to spread awareness on an important subject so you should use your access to Facebook, Instagram, Twitter, and all other social media platforms to encourage others to take action.

4. Some Simple Do’s and Don’ts

To sum things up in a more concise matter here is a small list of Do’s and Don’ts to help you construct your own comment to the ATF:

Do:

• Make sure you are commenting on the correct proposed ATF Regulation. (ATF proposed rule 2021R-08, “Factoring Criteria for Firearms with Attached ‘Stabilizing Braces”)

Note: There was a similar ATF Proposed Regulation last year and your comments on that proposed regulation will not count towards this one. Do not google search “ATF Arm Brace Rule” as the first result is usually the proposed regulation from last year and not the current one. I have provided links below to the correct ones.

• Make a comment
• Write plainly
• Be polite and respectful in your comment
• Be knowledgeable in your comment
• Use facts in your comment
• Point out what you disagree with and why
• Encourage your friends and family to comment (and help them)
• Point out the logical and factual inconsistencies with the proposed rulemaking
• Point out how the law essentially criminalizes people after the ATF’s own rulemaking made it legal in the first place
• Point out that there are at the current time well over 3 million pistol braces in the country
• Resist the urge to go on a 2,000 word vocabulary-salad rambling rampage about how the founding fathers would have gone ham on the ATFs asses for even proposing such rulemaking

Don’t:

• Call the ATF Tyrants, Devils, Nincompoops, Idiots, Nazis, Gestapo, Dog Killers, Fools, Ron Perlman, Cockalorums, Snollygosters, Pillcocks, Ninnyhammers, Dickasses, or Douchebaggettes, etc
• Simply copy and paste a response that has already been posted – use it as a starting point for forming your own unique letter
• Bring up Waco, Ruby Ridge, The 2020 Sonic movie, or the Ken Ballew Raid
• Mention any other proposed ATF regulations aside from the one you’re currently commenting on
• Use memes or other esoteric internet culture references in your comment
• Become discouraged

The theme of the Day: Stay Calm

A number of years ago I was sent to court to contest a traffic ticket that was handed to me in a completely improper way. Instead of cursing the officer who wrote me the citation, the bailiff who made me sit in the courtroom for 2 hours waiting for my case to be heard, or the judge who mispronounced my last name, I instead remained calm. Boring story short, I presented myself in a respectful manner, spoke plainly, presented my factual evidence and in less than 5 minutes my chargers were dismissed – easy as pie.

On the flip side of things, during my 2-hour wait in that courtroom, I saw numerous guys swaggering into court in sweatpants, speaking incoherently, getting agitated and verbose with the Judge various staff inside the courtroom, and in the end, three of them received what I believed to be far worse sentences than they would have had they simply taken the time to calmly and logically respond.

It’s times like we are now where a dispassionate and logical response can mean the difference between making a good impression or getting the hammer dropped on you.

To Read ATF Proposed rule 2021R-08, you can click HERE. 

To Submit your own Comment on ATF proposed rule 2021R-08, “Factoring Criteria for Firearms with Attached ‘Stabilizing Braces” you can click HERE.

Related Documents regarding ATF Proposed rule 2021R-08:

• Regulatory Impact Analysis
• Sample ATF Worksheet 4999  (this is the worksheet that they would use to determine if a stabilizing brace turns a pistol into an SBR)