Firearms Industry Consulting Group (“FICG”), a division of Prince Law Offices, P.C., continues to present evidence and argument to ATF in opposition to its proposed rule 41P. FICG drafted and filed a Comment on behalf of David M. Goldman (ATF-2013-0001-1899) that set forth arguments echoed in many subsequently-filed comments. FICG submitted its own Comment (ATF-2013-0001-8364 and ATF-2013-0001-8365) covering a wider range of objections. Earlier this week, FICG supplemented its Comment with sixty-five pages of additional argument and exhibits.
ATF’s failure to timely post public submissions throughout the comment period denied FICG and other interested persons the ability to reference and build upon useful material, on the one hand, and to rebut incorrect assertions and clarify the record, on the other hand. That problem was exacerbated by the slow pace that has continued to mark ATF’s posting of comments, with nearly 12% of all comments submitted still awaiting processing. In addition, developments subsequent to December 9, 2013, that shed light on ATF’s rulemaking proceeding had to be put on the record to facilitate later judicial review.
FICG’s Supplemental Comment can be found here.