As no standards were given, a subjective examiner’s guesstimate of “rear surface area” could pass a brace, or put it right on the edge of alleged short-barreled rifle by itself. Will one examiner estimate the “rear surface area” of a cuff-type brace by the physical area of the rear EDGE of the cuff, while another goes by the area of the space ENCLOSED by the cuff?
The Zelman Partisans also note that once again the ATF has violated the Administrative Procedures Act by opening docket 2021R-08, taking comments on that docket, DELETING it, and opening new docket ATF-2021-0002 without the old docket comments. The ATF does this on such a regular basis that we believe it is a deliberate attempt to discourage public comment on legally dubious proposed rules.
Gotta get that documented for posterity. And future lawsuits.
While the TZP comment is more elaborate, you may notice some similarities with my own
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