As many of our viewers are aware, Firearms Industry Consulting Group, a division of Prince Law Offices, P.C., has been following ATF’s proposed framework for determining whether certain projectiles are “primarily intended for sporting purposes” within the meaning of 18 U.S.C. 921(a)(17)(C). Today, we filed our formal Comment in opposition to ATF’s proposed framework. With exhibits, it is over 330 pages. You can download a copy here.
While gun owners and groups rejoiced after ATF announced it was no longer moving forward with the proposed reclassification on SS109/M855, many seemed to overlook a key phrase. ATF stated, “Accordingly, ATF will not at this time seek to issue a final framework.” Furthermore, there are still many inherent dangers in ATF’s proposed framework which are addressed in detail in FICG’s comment.
ATF’s Director Todd B. Jones appeared in front of a Senate Appropriations Committee this morning and was quoted as saying that all types of the 5.56 military-style ammo used by shooters pose a threat to police as more people buy the AR-15-style pistols.
The firearms community needs to remain vigilant about future action ATF may take with regards to .223/5.56 ammunition.
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Published by Adam Kraut, Esq.
Adam Kraut was born and raised in Chester County, PA. Active in scouting since kindergarten, Adam achieved the rank of Eagle Scout in 2004. After graduating high school, Adam attended SUNY Binghamton where he graduated in 2009 with a major in Political Science concentrating in politics and law. After taking a year away from academics, Adam attended Widener Law School at night while maintaining a day job and graduated in 2014.
Adam is an avid firearms enthusiast, whose love for firearms began in Boy Scouts at Camp Horseshoe. Adam’s experience in the firearms industry as the general manager of a Federal Firearms Licensee, who is a Class 3 dealer, gives him a working knowledge of the challenges the industry, licensees and individuals face on a daily basis. Having worked with industry leaders, individual licensees and individuals both from behind the counter and in a legal context, Adam is in a unique position to give advice with insight others may not have.
In addition to being active in the courtroom, Adam is politically active to ensure that the Second Amendment rights of future generations continue to be protected. He is the host of The Gun Collective‘s show, The Legal Brief, where he dispels the various legal myths and misinformation in the gun world. In his free time, Adam volunteers with his old Boy Scout troop, cranks out ammunition behind the reloading press, can be found at the range training, enjoys hiking through the woods and cares for his small pack of dogs.
View all posts by Adam Kraut, Esq.
6 thoughts on “FICG Files Comment in Opposition to ATF’s Proposed Framework for Determining Whether Certain Projectiles are “Primarily Intended for Sporting Purposes””
What a coincidence with the Perez V MBA decision coming down 9 March. 15. One would hope in this case only, not affecting the cases cited in Perez; since the ATF voluntarily asked for comments it would be held as setting a precedent and made to allow further comments after the “further study”. I wouldn`t hold my breath though.
So, writing and submitting comments letters to the ATF is no longer needed? Dan
If you have not submitted a comment to ATF we encourage you to do so before the comment period is over (Monday March 16, 2015).
I agree, I still left a comment with the ATF. All rifle ammo will penetrate most vests so why ban one type. It`s just an end around gun control since the most popular rifle is the AR15.
“To characterize the steel penetrator as a “core” is as humorous of a notion as declaring that the shouldering of an item causes it to be redesigned, even though no physical changes were made.”