My comment as submitted. I think I see their "intent," and as usual, they have a ham-handed, complicated response:

docket number (ATF 2020R-10)

I do not own nor have any interest in arm braces myself.  I understand the published criteria and subjective nature of the difference between a brace that is functional and one that may be a workaround for an actual stock.

However, ATF should consider that constant flexible and re-interpreted definitions serve at one level to create contempt and distrust of the agency. One outcome of this could be greater deliberate disregard of the law and refusal to attempt to comply. Another significant risk, one that has been observed, is the inadvertent violation of an increasingly complicated set of criteria beyond the grasp of the casual, non-expert firearm user. In the former case, deliberate violations of fine points of law may lead to greater violations of the NFA and other firearm law. In the latter case, people with no criminal intent may be found guilty of serious federal crimes over purely administrative details.

ATF notes that some firearms with braces are long and heavy enough to not function well with a brace. However, such weapons are also difficult to conceal and therefore the risk of deliberate violation of the INTENT of the law regarding SBR/SBS is very low.  Such crimes, if they occur, are usually part of another violation and can be punished as such. 

ATF's criteria seem to favor shorter weapons with smaller cartridges, that ironically function better in a concealed role. However, with a brace mounted, these become less concealable, and this supports the intent of the NFA proscription.

I would urge that any brace be considered to be exactly that--a brace.

A shorter brace on larger firearms does not function well as a stock due to eye-relief and recoil. While there would be an administrative violation in such case, the practical ability to commit a crime of violence isn't great.

A shorter brace on a bona fide pistol makes shouldering cramped and ineffective, and hinders concealability.

ATF should therefore research if a maximum possible length of pull of say, 10-12", serves the practical purpose of supporting a small weapon for one-handed firing, while limiting the ability to convert a firearm into a de-facto short carbine or shotgun.



DOCTOR: The bad news is your grandfather has COVID.  The good news is with current treatment, his odds of surviving are 99%. He’s a fit 83, and might have another 3-4 years.


FAMILY: Those are good odds. Thank you.


STATE GOVERNMENT: We can actually improve those odds with some help.


FAMILY: Okay, go on.


STATE:  This woman is hard of hearing. We’re all going to cover our faces and she won’t be able to read lips.


FAMILY:  That’s inconvenient, sounds even problematic.


STATE:  These two people are asthmatics.  We’re going to cover their faces up and restrict their breathing several hours a day. It won’t be quite as bad as COPD.


FAMILY:  What?  But that’s going to cause health problems for them.  That’s not really a fair trade.


STATE:  This woman was raped as a child with a cloth over her face. We’re going to wrap her face up. This will terrify her into PTSD, but, it will reduce her exhalations. Also, seeing our faces wrapped up will trigger her, too.  But it’s for the greater good.


FAMILY:  Are you fucking kidding me? That’s monstrous.


STATE:  These children will also have their faces wrapped up. They’ll have trouble learning how facial expressions work and how to interact with people, during a critical developmental stage.  But it may reduce the viral spread.


FAMILY: Jesus. They’re children.


STATE:  We’re also going to shut this business down and bankrupt an entire family. It will mean people can’t gather in groups as easily, though.


FAMILY:  Why? What kind of improvement are we talking about here?


STATE:  We can possibly make a 2% improvement over the 99%, so 99.02% survival.


FAMILY:  That’s so tiny, though.  Does it really matter?


DOCTOR:  It might save his life.


FAMILY:  I guess we can try it, if they all consent.


GOVERNOR:  Why would we ask their permission?


INFORMED FAMILY:  Holy fuck, you’re a complete sicko! Forget it. We don't want to do that. 



Moral grandparent: I’ll take my chances. Please do what’s right for the kids.


The asthmatics, rape survivor, hearing impaired, and small kids is _MY_ family.  The businesses are hundreds of thousands of family incomes (not “profits” in the corporate sense.  And even those employ people who are now laid off).

When you wail about being “mask shamed,”

When you ableist condescend that, “There’s no one who can’t wear a mask, it’s just a scrap of cloth,”

When you call the rape survivor “princess” and “snowflake” and say, “We’re going to need to see some documentation” and “maybe you should wear some kind of badge so we know this is real,”

When you jerk off that a business that feeds a family (or a lot of families) is putting “profit over people,”

You are a piece of shit.

Thanks for wearing a fashionable face panty, though. It makes you easy to identify.


Me: Why are you still wearing a panty on your face?

Branch Covidian: Because of the Covids!

Me: There’s 45 years of professional studies in literally every Western nation that cloth and paper masks can’t stop viral transmission.

Branch Covidian: But we have new science!

Me: You have a couple of meta studies that didn’t account for demographics, movement patterns, or environment, that at their most tortured showed a 1.9% reduction in transmission, well within normal modeling error.

Branch Covidian: Science says masks work! We need to wear them for 4-8 weeks!

Me: You said that 26 weeks ago, and now you say it’s worse than ever. Obviously, by your standards, that didn’t work.

Branch Covidian: Not everyone wore them! Deniers!

Me: US compliance is over 80%, on par with most of Europe, the exceptions largely explained by medical exemptions. And either way, you claim it didn’t work. Which is odd, because the death rate was back to normal before you started all that.

Branch Covidian: But case count is higher!

Me: No, test count is higher, but you’re using PCR tests far beyond their 30 cycle standard.

Branch Covidian: It’s so pervasive you have to dig deep to catch it!

Me: So at 35 cycles, you’re testing 100 thousand times over the normal sensitivity. At 37 cycles, 10 million times, at 40 cycles, 10 billion times, and at 45 cycles, you’re dialing the sensitivity up 1,000,000,000,000,000 times beyond what is considered standard. Approximately, but still.  Doesn’t that seem a little excessive? It’s literally homeopathic medicine.

Branch Covidian: I follow the science!

Me: Yeah, I’m just going to get on with life.  There are far bigger issues for me to worry about.

Covidian: Wow! Are you a paranoid conspiracy nut! Don’t get too close to me!


My David Prowse Story:

Dave and I were on a first name basis. We met multiple times at conventions, starting in the 1990s. The first time, he bought a few items at my booth, and I advised him one of the items was prohibited in the UK (He had homes here and there at the time).  He commented he'd just stuff it in his kit bag, it wasn't as if he was a criminal planning to harm anyone.  I guess it worked.

He wasn't as tall as I expected, and I asked about that and his overall fitness (still good), that he hadn't gotten fat like some pros who stopped.

He said the height loss was from hip surgery, and that, "You have to keep working out, it's a lifestyle, and once you're in, you need to maintain it."  Then he added, "But you have to remember, at my biggest, I was only four inches bigger than Arnie."

"ONLY." Four inches. Bigger.  Than Arnold Schwarzenegger. So, a 64" chest. No big deal.

Sure, there were bigger builders by then, though most of them are just knotty and lumpy and not as well formed.

But damned few.

The year GenCon moved to Indy, I was setting up, and he and Jerry (Jeremy Bulloch) were part of a celebrity autograph ring.  I walked past and said, "Hey, Dave!" 

"Hi, Mike."

I said we were doing dinner later, Chinese, did he want to come along?

He said the hosts had plans for them, but thanks.  

I said he should stop by the booth when he got a chance, right over there. And he did.

The amusing part was one of the teenagers early in line, waiting for an autograph, who exclaimed, "He just calls him, 'Dave'!"

Yeah, dude, actors have names too.

The autographed pic I have of Dave as Vader reads, "Impressive. Your knives are impressive."

Yeah, I heard it in James Earl Jones' voice, too. But it was Dave who wrote it.