Expert Analysis on Contradictions & Dangers in Proposed ‘Bump Stock’ Ban

Savage (center) with author and the late Mike Vanderboegh at Knob Creek Gun Range in 2008.

U.S.A. – -( A comment posted Tuesday to the Bureau of Alcohol, Tobacco, Firearms and Explosives’ proposed “Bump-Stock Type Device” rule shows the administration’s intended action sets up conditions for a wider ban on semiautomatic firearms. Filed by firearms designer, expert witness and Historic Arms, LLC President  Len Savage, the response to the government’s mandated-by-law request for comments, is posted as four distinct “pdf” files.

Savage notes that so-called “bump stocks” owe their existence to the government ban on post-Hughes Amendment machineguns, and that “ALL semiautomatic firearms can be ‘bump fired’ regardless of any ‘bump-type-stock device’ installed or not.”

Shoe String Bump Fire

Who thinks the gun-grabbers won’t use that to further their goal of banning all such guns? And there’s another inconvenient truth that refutes their “commonsense gun safety” pretext.

“Put bluntly…devices make using the bump fire shooting technique safer for the shooter and those around the shooter,” Savage observes.

He also notes the Department of Justice specifically explained—in federal court — “why a bump-stock-type-device is NOT a machinegun: ‘Because of the manual, skill-based methods required to operate a bump-fire device…’”

“The [Notice of Proposed Rulemaking] scheme is fatally flawed,” Savage demonstrates. “The NPRM does not address several serious issues:

  1. The change in policy asks for a willing suspension of disbelief of basic science and physics.
  2. The change in policy will put ATF experts at risk of being impeached as expert witnesses.
  3. The summary of the NPRM is filled with demonstrably false or misleading statements that are disputed by DOJ’s own experts at ATF.”

Savage also questions compelling government interest with an observation raised in this column last month arising from an ATF Freedom of Information Act response.

“Just how many crimes are committed using ‘bump-stock-type devices’ anyway?” he asks, noting unanswered questions submitted to the government, and that reports on the Las Vegas shootings have not yet confirmed that devices found at the scene were used, and if so, how.

Also included with Savage’s filing is the federal court case where the government made many of the arguments now being contradicted by its proposed rule, as well as a copy of the Freedom of Information Act request filed on his behalf by attorney Stephen Stamboulieh.

Regulations.Gov will continue accepting comments to the proposed rulemaking until Jun 27 2018, at 11:59 PM ET.

Slide Fire SSAR-15 SBS Bump Fire Stock
Slide Fire SSAR-15 SBS Bump Fire Stock

Read More:

About David Codrea:David Codrea

David Codrea is the winner of multiple journalist awards for investigating / defending the RKBA and a long-time gun owner rights advocate who defiantly challenges the folly of citizen disarmament.

In addition to being a field editor/columnist at GUNS Magazine and associate editor for Oath Keepers, he blogs at “The War on Guns: Notes from the Resistance,” and posts on Twitter: @dcodrea and Facebook.

Most Voted
Newest Oldest
Inline Feedbacks
View all comments

Having exactly zero intent to pick nits with anyone here, the following question comes to mind. Regarding people who have here commented in opposition to this Bump Stock regulation baloney, how many have been in contact with their federal elected representatives, aka congress critters, elected things, and so forth, voicing their opposition to such regulatory action? Also, how many have utilized the now running comment period to officially voice their opposition?

Noelia Tesalona

More people die from 1) Doctors mistakes. 2) Booze 3) Sugar 4) Government (war, black ops and police, etc) and not only is there no talk of a ban but God forbid you mention term limits or contribution limits. Political bribes, er, lobbying is legal. Guess who is represented in the representative republic? Not you, that’s who.


Why does everyone appeal to logic and facts?
The bump stock ban, like all other gun control has nothing to do with safety or crime or any other reason.
It is about incremental chipping away of gun rights.
10 years from now this rule will indeed be used to ban semi auto rifles.
That is a feature, not a bug

Rich in Mo.

It’s time we ban assault-style shoelaces of war; we don’t need them on our streets. Only police should have shoelaces.


This demonisation of a silly chunk of plastic is a kneejerk (or simoly just a “jerk” reaction to one specific incident whereupon one individual (or so THEY say….) acted independntly )we’ve heard THIS one before, haven’t we?) supposedly using the device in the commission of what already was a multiple capital felony crime spree. This harkens back to the era when Chicago gangland thugs carried about their “violin cases” whilst wearing their suits and, from time to time, would open them and “play a concert” (happened to be all percussion instruments…) and many folks would fall over dead. So, the… Read more »


+1 to Charlie Mac above. A bump stock relates to real full auto like jerking off relates to sex with a human being. I would not have one on a rifle/carbine for serious social work, but I don’t want to deny them to people who want one. I can’t stand beets or grapefruit either, but I’m not advocating a ban on them.

In light of the FBIs connivance with the DNC, the Klintoons, and foreign agents to further treason and sedition, the Sicherheitspolizei have proven themselves unworthy of the trust of the American people.


Knee jerk political action put the BATFE in a box. With an anti gun President they said a bump stock is ok, now with a President that claims he is pro gun and the NRA saying it is a danger leaves them with their a$$ hanging out the window.
Good luck getting over this one without more scars.



Politicians are untrustworthy, bureaucrats are, if possible, worse. Bureaucrats, having been given the power to legislate via decree, oops I should say via the power to promulgate regulations, ATF being an example thereof, are totally beyond the pale. Sad to say, but the foregoing is exactly what the law abiding citizenry face, this sad conclusion being, in part anyway, their own doing. Lack of attention can extract a terrible price.


As the article states ATF is asking for permission to claim that trigger devices don’t have to actually involve the trigger. Which mean in the future ATF could claim a hand grip or a sight makes a weapon a machine gun.


The one and only answer to this question from ATF is NO!!

Carl "Bear" Bussjaeger

I’ve been trying to make people understand this since October of last year. Maybe folks will listen to Len Savage.

Charles May

It is ALREADY illegal to convert any Firearm to a fully automatic Firearm!!


The gun grabbers will go after the low hanging fruit first then work their way up. I personally have no use for the bump stock, but there are a lot of shooting items I would not use and does NOT mean they should be ban.

Wild Bill

The BATFE is on the horns of a dilemma. I believe that the dilemma came to their door because of the NRA’s advice to the Trump administration. Once the Administrative Proceedures Act mandated comment period closes, the BATFE could take 99 years to make a rule… or not.


Wild Bill: If, as you say, the BATFE is in the horns of a dilemma, it is SELF PLACED in that position, the agency under several names, having long since prostituted itself. Instead of exhibiting some backbone, it has repeatedly bowed to political whoremasters, and the anti constitutional operators of the Anti Gun Rights movement. That sums up my view of this agency concerning it’s firearms enforcement activities. Particular agents might well be on the level, though obviously some aren’t, and likely never were, their employment being a power trip. The basic problem has lain, and continues to lie in… Read more »

Charlie Mac

I agree with you. I’ve no need for a bumpstock or suppressor. However that’s my choice just like these auto driving cars they are coming out with. I’ll have no use for those either and when it’s determined they contributed to a few accidents I’ll bet they won’t go down the road about banning those. Don’t ban things if you don’t like them, just don’t buy or use them. Leave my guns and constitution alone. (And my big gulp sodas!). Lol. Knee jerk snowflake reactions.

Roy D.

This was the same tack that was followed after the 1968 Gun Control Act. Remember the demonization of “Saturday Night Specials?” And it is done because it works quite often.