To Whom It May Concern,
It has come to my attention that the Bureau of Alcohol, Tobacco, Firearms and Explosives is considering further restrictions for various types of ammunition used in both rifles and handguns as they pertain to the Federal Gun Control Act of 1968. I am personally concerned that further restrictions on commonly used ammunition would represent a serious breach of the intended scope of the original limitations set forth under the laws created in the Gun Control Act. As the file, dad-richardson-opening-statement-at-ap-ammunition-listening-meeting.pdf, posted at your website states, “The law also provides a sporting purpose exemption from this definition for any projectile ‘which the Attorney General finds is primarily intended to be used for sporting purposes.’” What is the difficulty, and why are you speaking of a “broad” or a “narrow” sporting purposes test, other than to control ammunition and firearms through bureaucratic fiat instead of according to legal and constitutional means? The English grammar in the law is clear, even though the law is clearly unconstitutional (what part of “shall not be infringed” is unclear)?
Nevertheless, I do understand that as Federal civil servants you are required to follow the laws as they are passed, whether or not they are constitutional. From that standpoint, your “narrow” (as you define it) sporting purposes test goes too far and you freely admit it (As BATFE documents note: “…in developing a narrow sporting purposes test, ammunition in traditional hunting calibers will become regulated.” ) This “narrow” test clearly violates the intent and the words of ” … intended to be used for sporting purposes.” If so-called hunting calibers are not intended for sporting purposes, I would be hard-pressed to find any that are.
Without the sporting purposes test, the law bans all rifle caliber ammunition larger than .22 Long Rifle — As a small businessman who regularly performs ballistic testing of armor materials for industry, I know of what I speak — because that ammunition readily defeats personal ballistic armor of the sort worn by law enforcement ( without SAPI plates). All you are doing by suggesting there may be a reasonable “narrow” test is opening the door to a creeping usurpation of the current law through bureaucratic rule-making. If Congress wants to ban Barnes copper-alloy hunting bullets, let them try to pass a law that specifically does so! Otherwise, keep your hands off.
Interestingly, your action in suggesting use of this “narrow” test may finally force citizens to begin exerting pressure on Congress to repeal the portions of the GCA regarding ammunition (that portion, which anyone with any knowledge of long guns knows, is more idiotic than the remainder of the act), if not the entire act.
Dr. Baird works in the areas of blast testing of composite material/masonry construction retrofits, structure demolition, development of new blasting agents, gas turbine and chemical rocket propulsion, energetic materials, advanced polymeric and composite materials, explosive taggant research, and most recently, explosive-driven magnetic flux-compression generators for pulsed power applications.