The ATF’s White Paper Options to Reduce or Modify Firearms Regulations is just that, a paper with no regulatory power. It is the thoughts of one person about what should be done and the little freak paranoid in me is screaming that it is just BS from somebody aiming to keep his job, but  does not mean a word of it.

Let me go through a couple of things, nothing sophisticated or FFL related which I know squat.

Since that time, ATF has been asked to hold off on any AP ammo 4 determinations. Continued inaction on these requests poses significant litigation and reputational risks to ATF. ATF can readily mitigate these risks by using the criteria established in the framework to process and approve many of the applications, while leaving the 5.56 “green tip” AP ammunition exemption intact.

We know the Green Tip controversy, but who asked ATF to stop making determinations? The why? More than likely to shaft gun owners.

(the projectiles/calibers at issue will generally penetrate body armor regardless of whether AP-classified metals are used in the manufacturing process).

Holy crap, finally somebody gets it! Soft body armor will not resist most rifle calibers out there, including the venerable and well over a century old 30-30.

The State Department and ATF have worked over the past several years with the Administration on requests for the importation of U.S. origin military firearms, ammunition, and parts that were once sent overseas to support allies. There are surplus rifles, pistols, ammunition, and other importable U.S. origin Curio and Relic (C&R) defense articles (including M1 Garand and Carbine rifles) and pistols (M1911) overseas awaiting importation authority. There is no clear public safety reason why taxpayer-funded US-origin C&R defense articles should be denied re-importation to the American public, while many non-U.S.- origin C&R items are approved.

The only reason to stop their importation was the pettiness of the past administration.

Additionally, these items do not represent any discernable public safety concern, as demand lies with collectors of vintage military firearms. Importation and sale through licensed dealers would effectively regulate the lawful transfer of these firearms through a licensee and a background check.

One word: Duh!

Since the sunset of the Assault Weapons ban in 2004, the use of AR-15s, AK-style, and similar rifles now commonly referred to as “modern sporting rifles” has increased exponentially in sport shooting. These firearm types are now standard for hunting activities. ATF could re-examine its almost 20-year old study to bring it up to date with the sport shooting landscape of today, which is vastly different than what it was years ago…Restriction on imports serves questionable public safety interests, as these rifles are already generally legally available for manufacture and ownership in the United States. Low cost foreign made firearms are also still imported and converted into “non-sporting” configurations. These restrictions have placed many limitations on importers, while at the same time imposing a heavy 6 workload on ATF’s Firearms and Ammunition Technology Division.

Is it saying “let’s get rid of the Sporting Purpose” bullcrap or at least modify it heavily?

Creation of a Database of Agency Rulings: ATF lacks a consistent internal database to maintain and readily access private letters and ruling. The public also has no direct access to public rulings in a manageable format. The inability to access these rulings can create inconsistent agency interpretations of agency guidance. ATF can create a retrievable database for internal use that includes access by the public for open rulings.

That would be interesting to see happening, but I also know that the “invisibility” of these regulations was not a bug but a feature.

If such a change were to be considered, a revision in the definition of a silencer would be important. The current definition of a silencer extends to “any combination of [silencer] parts,” as well as “any part intended only for use in” a silencer. Compared to the definition of a firearm, which specifies the frame or receiver is the key regulated part, any individual silencer part is generally regulated just as if it were a completed silencer. Revising the definition could eliminate many of the current issues encountered by silencer manufacturers and their parts suppliers. Specifically, clarifying when a part or combination of parts meets a minimum threshold requiring serialization would be useful.

This is pretty much an admission that some of the latest lawsuits they had (IE: SIG) are the death bell tolling for such an arbitrary set of regulations. Old heads know damn well about ATF agents arresting people for owning “Silencer parts” that were nothing more than rubber gaskets from garden hoses. The “Oil Filter” silencers need to be sent back to the manufacturer in order to change what is basically a $5 common filter you can buy at your local auto part store because it is considered a silencer.

There is a bunch more stuff in the paper linked at the top of this post. But remember, it is just a proposition that somebody inside ATF made and it has no regulatory power at all.

And we still need a Director for the ATF which is maybe the reason Ronald Turk wrote the White Paper thinking the new Administration will see him Gun Favorable and thus material for Director.