Sunday, November 24, 2013

Comment Now on Proposed Additional Regulations on Gun Mufflers and Short Barreled Rifles and Shotguns (NFA Trusts)

The Firearms Coalition has provided an alert about the proposed BATFE Obama administration rules.  The proposed rules make the application for trusts and companies to obtain federal tax stamps for gun mufflers (silencers, suppressors), short barreled rifles and shotguns, full-auto guns and a few other items, considerably more convoluted.

The Firearms Coaliton supplied a sample comment in the article on ammoland to use as reference for comments, which can be made here.   I found the proposed rule change comment section with a search for NFA trust at that link, and by clicking on the Comment Now button  on the right side.  After reviewing the Firearm Coalition comment, I decided to write my own.    Feel free to use it or to take points from it as you choose.

These proposals attempt to provide solutions for problems that are non-existent.   The existing problem with the regulations is that they are non-responsive, result in unreasonable waiting times, and create barriers to good safety practice.  I have not heard of a single example of criminal misuse of these items that resulted from NFA trusts or companies.   The excessive federal regulation on gun mufflers, suppressors or silencers, has caused millions of people to have substantial hearing loss, a federally mandated health disaster.  The regulations on short barreled rifles and shotguns, given the Supreme Court decisions in Heller and McDonald, no longer make any rational sense.  To make them even more intrusive and complex is bad policy, on the edge of irrationality.

The BATFE currently handles the annual caseload of about 30,000 transactions poorly, with delays of six to nine months.  Instead of potentially doubling this caseload for frivolous political reasons, the administration should be looking to eliminate the requirement for these intrusive and unnecessary checks on items that are treated no differently than common firearms or accessories in many European nations.  In Finland, for example, gun mufflers, suppressors or silencers are considered a constitutional right.   No crime problems have resulted from this.  Short barreled rifles and shotguns are functionally no different than handguns, possession of which has been ruled to be a constitutional right in the United States.  They should be treated the same as handguns.   If these actions were approved, the wait times for other applications could be handled in a timely manner.

The current Chief Law Enforcement Officer certification requirement should be done away with completely.  At present, local officials are able to stop individuals  from obtaining federal licenses based on nothing by individual bias,  discrimination, an unwillingness to process the forms, or simple caprice, without any appeal.   The proposed rule changes would extend this affront to the rule of law to trusts and companies as well.

The citizens that apply for these "tax stamps", which are in fact, poorly disguised licenses, have been shown to be the most law abiding of the top 10 percent of the country.   They should not be punished for the remarkable safety record that they have established.   There is no rational basis to make these regulations more restrictive. 
After submitting the comment, you will be given a tracking number to track it through the system.  My tracking number is: 1jx-88wl-w71t.

When we push to remove these frivolous infringements on the second amendment, we will be able to show that they were opposed by large numbers of commenters, but only if we bother to make a comment.  Comments close on December 9th, so now is a good time to get your comment in the system.

©2013 by Dean Weingarten: Permission to share is granted when this notice is included.
Link to Gun Watch 

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