Definition of “Frame or Receiver” and Identification of Firearms
 Proposed Rule

Docket Number: ATF 2021R-05

To whom it may concern at The ATF:

Let me start off by saying that I am in agreement with the idea that we need to properly address the mitigation of firearms-related injury and death. If there is an emerging trend of intensification with the illegal acquisition and criminal use of unserialized firearms then this is something that needs to be acknowledged and addressed.

Simultaneously, it is important to acknowledge that the use of regulation (and particularly complicated or vague regulatory ideas) can lack mitigating effect at the level of which these ideas are advertised.

My fair assessment of ATF 2021R-05 has yielded a number of conclusions which indicate excessiveness, vagueness, and a lot of potential for burdening the law-abiding gun reality while delivering questionable efficiency in regards to reducing crime.

Here is a list of these points:

1.The data associated with the exact nature of these most recent, seized batches of unserialized firearms is vague. There are no indications, across the collection, of where these units originated from or if they were initially acquired through the currently legal means of purchasing incomplete receivers. There are some examples given in recent articles and publications about legally acquired, incomplete units being purchased, completed, then used in crime. But we have no idea whether or not these trends continue throughout the larger batches represented in the data.

2.The Frame or Receiver definition essentially paves a road for the serialization of most parts of a firearm. There are substantial, potential effects inside of the use of this definition that will easily lead to mass non-compliance from firearms owners. This applies to firearms already owned and firearms to be owned in the future.

In addition, consider the wording in this following paragraph:

“More than one externally visible part may house or hold fire control components on a particular firearm, such as with a split or modular frame or receiver. Under these circumstances, ATF may determine whether a specific part or parts of the weapon is the frame or receiver, which may include an internal frame or chassis at least partially exposed to the exterior to allow identification.”

This summary paragraph shows the potential for exceptional, inaccurate assessments and potential poor decision making by the adjudicators in these matters. This potential could present exceptional inefficiencies in the courts. The language leaves too much room for error and complexity.

My opinion is that the effect that regulations can have on human behavior is already at a natural minimum. The addition of errors and complexity has the potential to create more ineffectiveness.

3. There is potential in these new rules for the additional protocols and paperwork to create more work for gun-related businesses inside of a commercial reality that is already exceptionally challenging. Such an increase in stress and difficulty may be warranted in the event that this regulatory suite was a proven vector against the crime that the regulations are attempting to address. As it is, the data is vague and the actual mitigating effect of these ideas on the issue is an unknown.

4. There is more potential for further hindrances to the consumer in acquiring necessary parts and desired upgrades, due to the potential serialization of standard parts and components. As the overwhelming majority of these parts are never used in criminal activity, the idea of serialization is overwhelmingly excessive. Whatever hindrances may be created by such serialization, it’s doubtful that such hindrances will have an impact on the targeted crimes.

5. I have a firm belief that no phenomenon should be given over to a governmental entity for complete control. Millions of other firearms owners have the same belief. The excessiveness and complexity of these kinds of regulatory ideas paints a picture of a never-ending effort by a government to obtain such controls. The mass behavioral repercussions of such a picture also add to a reduction in sustainable mitigation of such criminal issues, I argue. As nationwide mitigation is an all-hands-on-deck reality.

6. As it pertains to the ideas surrounding suppressors, I question the existing laws as they pertain to suppressors. Moreover, there is no real data which shows us that suppressors would have any significant effect for the intensification of crime. As such, these additional measures seem excessive and unnecessary.

What I believe is necessary for the mitigation of crime are ideas that are based in reality. Much of what has been proposed here seems complex in some places and vague in other places. There seems to have been very little thought placed on the actual effects that these ideas would have inside of the future process.

There seems to have been very little thought placed on the effects that these ideas would have on the commercial gun market. There seems to be very little thought placed on whether or not these ideas were efficient and sustainable.

My opinion is that ATF 2021R-05 is poorly considered and that The ATF needs to return to square one to assess the actual effects that regulatory ideas will have on criminal behavior. It is also my opinion that the ATF should consider more reality-based approaches to the mitigation of gun-related crime, which will likely yield the conclusion that honed regulatory approaches are often far superior to ever-building regulatory approaches.



Randy Miyan
Executive Director
Liberal Gun Owners