Last Push Needed for Comments on ATF Rule Change ~ “What’s a Firearm”

Polymer 80 PFC9 Serialized Glock 19 Compact Frame
Polymer 80 PFC9 Serialized Glock 19 Compact Frame

USA – -( Time is running out on the Comment Period for the BATFE’s proposed changes to the definitions of “Firearms,” “Frames and Receivers,” and the marking of same.

In short, the proposed regulations would define as a “firearm” the upper receiver or slide of a firearm, as well as the barrel of a firearm, and possibly other parts, all at ATF’s discretion. As firearms, those parts would require serialization, maker information, and all of the other controls and restrictions currently applied only to lower receivers. The regulation also redefines “Gunsmith” and the word “readily,” as it applies to phrases currently in the regulations about guns that may be “readily restored” to fire in fully automatic mode, or “readily converted” to expel a projectile.

The objective is to control and regulate the lawful sale of major firearm components and restrict what gun owners can legally do to modify their personal guns, or to build their own firearms.

The comment period closes on August 19, 2021, so it’s important that you get your comment in before that deadline.

Comments should be businesslike, factual, and to the point, and should never include vulgarities or threats. Additionally, declaring “shall not be infringed,” has not proven to be a successful argument. Copying and pasting the arguments of others, or pieces of them, is not a good strategy, as the agency is looking for original thoughts, not ditto marks. Comments don’t need to be long and detailed, but a valid argument does help, and can seem to make an impact.

Below is a sample comment I am submitting. You are welcome to steal ideas, but please couch them in your own words, not mine. It’s best to read the proposed regulation, to have a clear understanding of what is being proposed, then write your comment.

You will find the draft regulation here. Follow the links to the Comments section.

You may submit comments on or before August 19, 2021, by mail, fax, or the Federal eRulemaking Portal at

“I am writing in strong opposition to the proposed regulatory changes in the Definition of Frame or Receiver and Identification of Firearms.

The ATF is overstepping their authority with this proposal. Such a major change to firearm definitions is the purview of Congress, not the ATF.

The US has operated under the existing definitions since at least 1968, with much of it dating back to 1934 or before, with only minor adjustments during all of that time. Very little has changed regarding firearm design or function since those definitions were developed, and certainly nothing so drastic as to warrant these major changes. While manufacturing technology has advanced, and some would argue that it is more available today, the reality is that our fathers and grandfathers, most of whom worked with their hands and had a wide variety of tools at their disposal, along with the skills to use them, we’re much more capable of home manufacture of firearms than the vast majority of Americans today, even with the expensive new tools.

Americans have always had the ability – and the right – to make and modify guns.

What has really changed is a false alarm raised by those who don’t like civilian ownership of any sort of firearm. They are constantly looking for angles to encroach on the right to arms. Whenever they find some particular gun, feature, or practice that can alarm their base and the uninformed public, they ride it for all it’s worth. That is what is going on in this case and what has instigated the current proposed regulation.

The documents supporting this proposal include a number of false assumptions, chief among them being the idea that marking and regulating more parts of a firearm, will reduce firearms-related crime, or assist in the solving of crimes. There is no valid evidence to support this claim, and there is plenty of evidence that it is a pipe-dream.

The estimated costs of the proposal are also distorted. The regulatory burden alone will cost gun manufacturers, distributors, retailers, gun owners, and police and sheriffs offices, untold millions of dollars in man-hours, not to mention new tools and equipment. In the case of law enforcement, this represents money and man-hours that would otherwise be spent on actually preventing and investigating crimes. These are funds and resources that law enforcement agencies – and the public – simply can’t afford to be wasting on bureaucratic busywork that has little impact on crime or the activities of criminals.

And that’s the crux of the issue: These proposed regulations, if implemented, would have little effect on criminals, but would have major impacts on regular gun owners and the industry that serves us.

Riding herd on the public as our “Gun Nannies,” is not supposed to be the ATF’s mission. Stopping and catching violent criminals who use firearms to harm and intimidate others is what you’re supposed to be doing, and this proposal does not advance that mission at all.

The proposal should be scrapped in its entirety.”

…but wait there is more.

There is another ATF proposal regarding the classification of firearms with arm braces attached, that you should also leave a comment on. That comment window closes on September 8, 2021, and can be accessed by clicking here. I hope to have more about that in another column soon.

About Jeff Knox:

Jeff Knox is a second-generation political activist and director of The Firearms Coalition. His father Neal Knox led many of the early gun rights battles for your right to keep and bear arms. Read Neal Knox – The Gun Rights War.

The Firearms Coalition is a loose-knit coalition of individual Second Amendment activists, clubs, and civil rights organizations. Founded by Neal Knox in 1984, the organization provides support to grassroots activists in the form of education, analysis of current issues, and a historical perspective of the gun rights movement. The Firearms Coalition has offices in Buckeye, Arizona, and Manassas, VA. Visit:

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Ryben Flynn

The ATF will ignore the comments like they did on bump stocks and implement the changes anyway, meaning more lawsuits and years in Federal Court. The bump stock thing has been going on for over 3 years and still no resolution.

APG member

Legislators and bureaurats attempting to legislate that which they lack the technical knowledge to understand result in the usual arbitrary and capricious laws. This is the S.O.P. in Washington DC…


It’s called, “Administrative Law” and is about as unconstitutional as you can get. It allows FEDERAL agencies, any and all of them, to make up rules and regulations that they want or think they need, and then publish them in the Federal Register, which is supposed to be the same as making them known to the public (which it is not). Then the agency is required to obtain public comments over a designated period of time (30-90 days usually), and after that “review” the comments (all the agencies ignore any and all negative comments in actuality) and then the proposed… Read more »


And the continued apathy of WE, The People ALLOWS this to remain the status-quo. WE must change the status-quo!


Blah, blah, blah. Thank God it isn’t a “democracy”, but you should move to one, since you constantly complain about how you are a victim here, while you intentionally worked for the government and enforced unconstitutional incarceration of free men based on the laws the government You whine about created.


If you leave off the proposal designation number, 2021R-05, like the author, they will ignore the comment. FYI, be sure to include it.

They have to read and reply to all comments, so at the very least, submitting comments will delay any action. In addition, comments will form the basis for lawsuits should this despicable and unconstitutional proposal be pushed through.

Heed the Call-up

Yes, ATF regs are full of idiocy. One of my favorites is that a black powder, muzzle-loading cannon manufactured before 1898 or replica is not a destructive device and is not required to be registered as such by the ATF.

Heed the Call-up

My point was that of course those cannons are destructive, they were used in war for centuries. The pic in the attached link shows the physical effect on a human hit by a projectile from one of them.

Cuirass with Cannon-Ball Hole – Age of Revolution


I suppose the constant ranting and bickering back and forth is the protocol on Ammoland and far more effective and important rather than attempting to formulate a solution, deployment of and follow through in coalition action against those that abrogate the law to further erode our rights, freedom and liberties? Aside from the Rare Breed issue, WE, The People are being attacked by the federal government from ALL angles, so much so “they” rely on OUR ignorance, lack of backbone and apathy in order to win against US… Last Push Needed for Comments on ATF Rule Change ~ “What’s a Firearm”… Read more »


Why the fork won’t Congress do their job…… these lazy shitz constantly hand off their responsibilities to lobbyists and biased bureaucrats. Most are know-nothings, suckling off the government teat until retirement, constantly trying to accrue power in their little fiefdom, so they can pinch more ass, or grab more tit…. (and I’m actually unsure if I’m berating the bureaucrats, the lobbyists or the congressional creeps)


Because it is OUR DUTY, WE, The Sheeple’s duty to dictate to Congress and WE, The People are too damn apathetic to get up off our spineless asses to do so!


Still no veteran organization opposing Chipman.

If only they would get up off their apathetic, spineless asses and send an open letter to Jon Tester, the ranking member of the Veterans’ Affairs Committee, and indicate their opposition to Chipman.

Marine Corps Values

  • Honor
  • Courage
  • Commitment

That’s understandable… MOST Veterans Orgs are waiting for the civilians to get up off their dead asses and make the first move before the Veterans move in to support.


Veterans, who are civilians, are not shy about organizing to get more benefits or to push for never ending gun control – #VetsForGunReform:   “I recognize the power of firearms. I’ve seen what they can do” “Some of us are combat veterans. Some of us have seen what firearms can do to people.” As a Marine, Lucier led training on M4s and MK-12 special-purpose rifles. He felt especially equipped to explain why access to certain weapons should be restricted.“Those weapons were extensions of me. I know everything about them and how to use them,” Lucier said. “So, if we’re… Read more »


 what firearms can do to people.”  If this is their take then they are very wrong. It is what People do to People, firearms are just the tool same as a wood chipper.


I agree. Also, I wonder if any of those people have ever gone elk hunting and understand what a rifle chambered for a cartridge typical for hunting elk can do (as opposed to a rifle chambered for a varmint cartridge). “I spent a career carrying typically either a M16, and later a M4 carbineand a M4 carbine fires a .223 caliber round, which is 5.56 millimeters, at about 3,000 feet per second. When it hits a human body, the effects are devastating. It’s designed to do that. That’s what our soldiers ought to carry. I personally don’t think there’s any… Read more »


What if anything have you done personally to remove any of these cretins from office?


If I’m a gunsmith then they should have to grandfather me in and I should be able to buy mail order guns.