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Below are some suggested comments from VCDL.
Suggested Comment #1
Policymaking which imposes such a significant burden upon both citizens and industry should not be undertaken lightly. Here, we have burdensome definitional changes / expansions which have the potential to damage or destroy segments of one of America’s few growing industries and it is not based upon an identified problem. Rather, it is based upon mere conjecture.
Suggested Comment #2
The supposed ‘criteria’ laid out in this guidance document are so arbitrary and capricious that no reasonable person could look at them and make an informed decision. The ATF admits as much when they say that evaluations will take place “on a case-by-case basis.” This fails to give adequate notice to those subject to the rules thereby imposed against them. This violates both the procedural and substantive due-process rights of manufacturers, buyers, and those who already own such items.
Suggested Comment #3
Without concrete guidance (comprised of quantifiable design features that place a product in the purview of the NFA), this will only serve to have a chilling effect on the entire marketplace for stabilizing braces. The ATF is empowered to regulate NFA items based upon the clear language of the act, not upon an “I know it when I see it” arbitrary system. It is past time that Congress revisits and refines the deference granted to the administrative aspect of the legislative branch.
Suggested Comment #4
ATF has failed to consider less intrusive forms of regulation that might accomplish the same goals. By specifically defining design characteristics that bring an item under the purview of the NFA, they could achieve the same stated goal without exposing law-abiding citizens to the chilling effect of this arbitrary and capricious definitional scheme.
Suggested Comment #5
Passage of this proposed rule would do nothing to enhance safety but would only place additional bureaucratic roadblocks in front of law-abiding collectors and swamp ATF staff who are already overwhelmed. The result would be a drastic increase in the processing time for NFA applications and potentially a collapse of the stabilizing brace industry.