BATFE proposes to ban SS109 & M855 ammunition for civilian sales.

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Trent

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PREFACE ADDED 2/16/2016:

There has been some concern that writing the BATFE will get you added to "lists." When you write the BATFE on this issue, your comments indeed become testimony and are included in the Federal Record for the proposed rulemaking proceedings - along with your personal information such as name and address (and company, if you are submitting a trade industry opinion). This fear is not wholly unfounded, if you look at the history of the agency in question.

I would like to remind potential authors of letters, that there is a particular history in our nation - a heritage even, starting with the very first big, bold signature that John Hancock laid down. To shirk our civic duty at a time of need out of personal fear is neither brave, nor wise; the only action required to fail to hold the line on our rights and heritage is to do exactly NOTHING.

When I became a gun rights activist 20 years ago during the Federal Assault Weapons ban period, it was for wholly selfish reasons - I was worried about *me*, and what *I* could own. Over time that viewpoint has transitioned 180 degrees; I no longer worry about me and my rights, I worry about what sort of nation my 6 children, and future grandchildren will live in. Will it resemble the nation I knew?

Think on what I just wrote. Be selfless, and lose your fear of your public servants.

Write the letter, put a stamp on it, and send it to them.


Trenton D. Lawrence, Sr.
February 16, 2015



Original Post:

BATFE ban on SS109/M855 is immenent;

As posted in legal:

Write the ATF asking that they do NOT ban SS109/M855 ammunition (the ban is pending to happen in March).

This is ammunition that many high power shooters use in across the course matches.

BE POLITE AND EXPLAIN YOU USE THIS AMMUNITION FOR SHOOTING RIFLE MATCHES.

ATF will carefully consider all comments, as appropriate, received on or before March 16, 2015, and will give comments received after that date the same consideration if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before March 16, 2015. ATF will not acknowledge receipt of comments.

Submit comments in any of three ways (but do not submit the same comments multiple times or by more than one method):

ATF website: [email protected]

(Follow the instructions for submitting comments.)

Fax: (202) 648-9741.

Mail: Denise Brown, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, 99 New York Avenue, NE, Washington, DC 20226: ATTN: AP Ammo Comments

The link to the full proposed armor piercing reclassification framework is available here:

MOD NOTE: NRA-ILA has opened a webpage facilitating comments/letters to the BATFE, POTUS, VPOTUS, and your Congresspersons. https://www.nraila.org/take-action/write-your-lawmakers/stop-batfe/ Please read through this thread for example comments/letters before posting through the webpage. Do not assume that this goes to the BATFE comments solicited by BATFE until we confirm it.
 
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It looks like the BATF has already made up their minds.

Maybe they will rethink their position (somewhat) if they get enough mail?

No, BATFE is proposing to remove the LEOPA exemption from SS109/M855. They've always considered it as AP, but exempted it under their "sporting use" clause. They're making public notice for comment prior to making a final decision. That is how making significant changes to legislative interpretations is supposed to work. Once the comment period closes they may or may not make a move, often based on the comments AND Congressional or Presidential pressure. It is not a "done deal".


We have until March 16 to comment and contact our elected officials to push them to oppose this proposed change so the window hasn't closed yet on the best opportunity to stop the removal of the exemption of SS109/M855 ammunition as armor piercing. Second approach would be to get a bill into Committee and then before Congress RIGHT NOW from a sympathetic Senator and Representative that would reclassify SS109 and similar ammunition as NOT AP. That bill would cause the BATFE to hold any decision until the bill went through or failed. If such a piece of legislation succeeded it would block BATFE from treating SS109 as AP and we might get the chance to get some other ammunition protected as well.

We need language people should send so we don't look like just a bunch of whining whiners whining instead of citizens pointing out the error of the BATFE proposed interpretation of LEOPA wrt this ammunition classification as armor piercing and of the removal of the exemption that has protected the supply to civilians? Relevant arguments are the constitutional, technical, fiscal, and enforceability for these sorts of things.

What do we need to point out to our elected officials so they push back on BATFE? We have champions for the 2A in Congress as well as a bunch of follow-along Congress Critters so what do we each need to say to them (and how do you reach them) to get them to tell BATFE they're wrong (their voices are pretty "loud" since they're supposed to be amplifying our voices in government)?


It will be important for everyone here to read the BATFE position on this change to the classification of SS109/M855 as armor piercing so here's the link to the BATFE's position on this - http://www.atf.gov/sites/default/fi..._primarily_intended_for_sporting_purposes.pdf


Here's the LEOPA armor piercing ammunition definition as a place to start -

Specifically, the definition of “armor piercing ammunition” in 18 U.S.C. 921(a)(17)(B) provides:
(B) The term “armor piercing ammunition” means—
(i) a projectile or projectile core which may be used in a handgun and
which is constructed entirely (excluding the presence of traces of other
substances) from one or a combination of tungsten alloys, steel, iron,
brass, bronze, beryllium copper or depleted uranium; or
(ii) a full jacketed projectile larger than .22 caliber designed and intended
for use in a handgun and whose jacket has a weight of more than 25
percent of the total weight of the projectile.

Is the SS109 projectile a projectile with a core or constructed entirely of these materials? Doesn't it have a tip instead of a AP core that is the penetrator and not a core or the entire projectile? Doesn't that mean it isn't AP in the first place? Didn't BATFE exempt it in '86 in spite of the fact they never should have treated it as AP? Why remove that exemption now after nearly 30 years in the face of continuously falling violent crime rates vs. the increase in common ownership of the firearms shooting 5.56mm ammunition firearms and the SS109/M855 ammunition? Were LEOs safer in '86 than they are now? Were they safer at any time between '86 and now? The FBI's Uniform Crime Report shows they're much less at risk now than in '86 or '96 or 2006 or even 2012. Why ban the ammunition that the common 5.56 firearms used for sporting purposes now have barrels with twist rates specifically tailored to shoot SS109/M855 accurately for hunting and competition need? The 5.56 rifle is the most common sporting arm in America shooting M855/SS109 ammunition. The twist rate of most barrels is idealized for the SS109/M855 because of the superior ballistics of this ammunition. How does this ammunition not meet the sporting purposes provision that the exemptions have been based on in the past? Why change now? Why levie the financial burden on the citizens of the United States that not only will make the cost of ammunition increase, but will necessitate the expense of changing out $200+ barrels on their firearms to shoot a different round? Why add the financial burden on the U.S. taxpayer of having the surplus or out of spec SS109/M855 ammunition produced by GOCO (government owned commercial operated) ammunition plants no longer be sold to the public to recover costs to the government and avoid the ADDITIONAL cost of destroying the ammunition that the government can't use? If the military classifies M855 as "ball" and M995 as armor piercing why is BATFE treating it as AP?

Here's the information on how/where to submit comments to the BATFE on this.

PUBLIC PARTICIPATION
ATF will carefully consider all comments, as appropriate, received on or before March 16,
2015
, and will give comments received after that date the same consideration if it is practical to
do so, but assurance of consideration cannot be given except as to comments received on or
before March 16, 2015. ATF will not acknowledge receipt of comments.
Submit comments in any of three ways (but do not submit the same comments multiple
times or by more than one method):

ATF website: [email protected]. Follow the instructions on the site for submitting comments.

Fax: (202) 648-9741.

Mail: Denise Brown, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs
and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, 99 New York Avenue,
NE, Washington, DC 20226: ATTN: AP Ammo Comments


As to making your opinion heard with your Congress Critters so they might intervene (cut of BATFE funding for this), if you know your Senate and House politicians contact them directly. If you don't - go to http://votesmart.org/ and type in your zip code and look down the list until you get to your 2 Senate and one House congress critters and then click on each of them to see a page open that has their email and snail mail information on the left. Send an email immediately touching on the points above and other RATIONAL (not emotional) points you want to make and then use the body of that email to print out and send a real paper letter to them. Do the same for your governor since they have voting taxpaying citizens like you that will be affected and some of them have the ammunition plants that won't be able to keep voting taxpaying citizens employed if they can't sell ammunition to the public.
 
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From a personal and sporting perspective SS109/M855 is about the perfect cheap practice ammunition for high power shooters who have rifles which shoot 62gr better than 55gr. Many of my shooters (depending on twist rate of their rifles), will prefer to use the 62gr SS109/M855 in practice, matches, or both, because it's economical and more than accurate enough to do the job on the 200 yard stages.

Meanwhile the XM193 ammunition (55gr FMJ, ball ammo) doesn't work nearly as well in those rifles, and while inexpensive, gives accuracy out of certain twist rates that is sub-par and not really ideal to either practice or compete with.

(Generally speaking rifles shoot one or the other very well, but not both)

That leaves no real affordable alternatives for people whose rifles prefer 62gr projectiles for their given twist rate.

This will increase the cost of competing as a large chunk of High Power shooters will be faced with buying higher cost commercial 62 grain projectiles to practice and compete with, which may or may not work as well as the SS109/M855 projectiles due to subtle changes in weight distribution, and bullet profile, and ballistic coefficient, that a full lead core gives. (SS109/M855 has a steel core up front and a lead core in back; so they have a different shape and size than a 62gr FMJ ball round).

Forcing competitors to exclusively choose the remaining inexpensive source of 55gr projectiles isn't ideal, as there are always going to be those who prefer the heavier 62 gr projectiles for ballistic characteristics (slightly better performance in wind, sights which are regulated for their drop rate, etc).
 
It would also be valuable to have Congress specifically define SS109/M855 as not AP since it does not meet the definition under LEOPA for AP. These bullets have a TIP and not a core of the prohibited materials and this was because there conventions against shooting AP or dual purpose ammunition at troops. If the design was to have a "penetrator tip" and not an AP design to comply with international convention then BATFE was in the wrong initially saying that this ammunition was AP and fell under LEOPA and that there was any exemption needed. Getting someone in Congress to put language in a bill, or a specific bill itself, stating that SS109/M855 and M855A1 and others are designed and manufactured in compliance with international convention to use ball small arms ammunition fired at troops, therefore SS109/M855/M855A1, et al are NOT classifiable as AP.
 
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Good points, through and through!

I'm going to piece together a sample form letter that people can use tonight.

If anyone has any additional point of fact they want to add before this evening, post 'em!
 
Going the wrong way guys.. "Sporting", isn't that like duck hunting?

Instead fight them in 2nd Amendment grounds. If you have the right to arms, you have the right to ammo.

Deaf
 
I drafted this letter and sent it in via e-mail. Please feel free to use and abuse as you see fit.

PDF:
https://drive.google.com/file/d/0B4AePys-pI6sSExPS1ItQ1pzUVk/view?usp=sharing

Denise Brown
Mailstop 6N-602
Office of Regulatory Affairs
Enforcement Programs and Services
Bureau of Alcohol, Tobacco, Firearms, and Explosives
99 New York Avenue, NE
Washington, DC 20226

ATTN: AP Ammo Comments

To Whom it May Concern:

I am writing to comment on the proposed determination regarding SS109/M855 .223/5.56 ammunition.

Based on the language used within 18 U.S.C. 921(a)(17)(B), I believe that this ammunition is, in the first place, improperly classified as armor piercing:

(B) The term “armor piercing ammunition” means—*

(i) a projectile or projectile core which may be used in a handgun and which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper or depleted uranium;

or

(ii) a full jacketed projectile larger than .22 caliber designed and intended for use in a handgun and whose jacket has a weight of more than 25 percent of the total weight of the projectile.*

First, as can be seen in Figure 1, the core is NOT constructed ENTIRELY of any of the listed materials, but instead consists of a two-part core comprised of lead and steel.

ss109.jpg
Figure 1: Cross-section view of the SS109 projectile

Secondly, Figure 1 also makes it apparent that the projectile is NEITHER (1) fully jacketed OR (2) has a jacket that comprises more than 25 percent of the total weight of the projectile.

Because of this, the ammunition does not fall into the definition of “armor piercing ammunition.”

In addition to not falling within the definition above, the primary civilian use of this ammunition is for sporting purposes, and, even if it fell within the definition of “armor piercing ammunition,” should enjoy an exemption as outlined in 18 U.S.C. 921(a)(17)(C).

Competition shooters (which the ATF has consistently classified as falling under sporting purposes) prefer this ammunition due to its improved ballistic characteristics and availability when compared to other bullet types, particularly commonly available 55 gr and less available commercial 62 gr bullets. The fact that a small percentage of the population, criminals, might utilize this ammunition outside of this use does not change its PRIMARY use: competition shooting.

For these reasons, I do not believe that SS109/M855 ammunition should be banned under 18 U.S.C. 922(a)(7).

Thank you for your time.
 
Comment period ends March 16.
Act now.


Here is the email I sent today.
I encourage like-minded members of this group to do likewise.


email to: [email protected]

TOPIC: I object BATFE proposed ban on M855 ammunition



Dear Sir or Madam:

I am writing to object to the proposal to ban “M855” ammunition and projectiles as described in your agency letter titled: “Framework for Determining Whether Certain Projectiles are ‘Primarily Intended for Sporting Purposes’ Within the Meaning of 18 U.S.C. 921(a)(17)(c).”

Please DO NOT restrict this ammunition.

There are millions and millions of rounds of this ammunition in circulation.
Thousands of shooters use this ammunition every day for bona fide sporting purposes.

I am unaware of even ONE INSTANCE of this ammunition being used in a handgun, and for the purpose of defeating body armor of any law enforcement officer. This proposed ban on M855 ammunition is a solution in search of a problem. There is no need whatsoever for this ammunition to be banned.

Please do not ban M855 ammunition or projectiles.

Respectfully,

NAME
ADDRESS
TELEPHONE
EMAIL ADDRESS
 
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Additionally, you might want to look at your state laws as the removal of this exemption may make simple possession of M855 a state crime in some states (such as Illinois apparently). ATF glossed over that in their notice stating that M855 would still be legal to possess under federal law; but neglected to note that it would make possibly millions of criminals for states that take their cues on definitions from the Feds.
 
Additionally, you might want to look at your state laws as the removal of this exemption may make simple possession of M855 a state crime in some states (such as Illinois apparently). ATF glossed over that in their notice stating that M855 would still be legal to possess under federal law; but neglected to note that it would make possibly millions of criminals for states that take their cues on definitions from the Feds.

I'll show my ignorance now but I have to ask, where would one generally begin to look for that info?

ETA: Nevermind. I think I found it in the TX penal code. It appears that if the exemption is removed, possession of M855 would become third degree felony although it does state "to be used principally in pistols and revolvers".
 
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Keep those examples letters/comments coming.

Use diagrams instead of photos. Diagrams may not go through, but photos take too much "space". All we need to do is point out that the LEOPA AP definition doesn't fit SS109/M855/M855A/etc and the military designates M855 as ball ammunition as opposed to M995 armor piercing. As such, if the U.S. is going to classify M855 as "ball" ammunition the BATFE can not declare by fiat that SS109, et al, is AP when it doesn't even meet military and LEOPA standard for AP.

Below are the military definitions of M855 Ball ammunition and M995 Armor Piercing ammunition. If the military calls M855 Ball and M995 Armor Piercing and the two are of different design then the BATFE is making up their own terms for military ammunition to allow them to regulate it as AP.

Cartridge, Caliber 5.56 mm, Ball, M855 (United States): 5.56×45mm 62-grain FN SS109-equivalent ball cartridge with a steel penetrator tip over a lead core in a partial copper jacket. [green tip]

Cartridge, Caliber 5.56 mm, Armor Piercing, M995 (United States): 5.56×45mm 52-grain AP cartridge with a tungsten core. [black tip].
 
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(this is going to look like crap without formatting.)

Remember gents, since you are creating a Federal testimony that will remain on record, and not trying to convince a busy politician to read a couple of lines of text (like many of our letters are...), BREVITY is not strictly required.

Comments can be as long as you choose to make them, and it will not matter - they will become part of the record on this issue. The BATFE is *required* to read your comments submitted before the due date. After that, it becomes optional.

So explain things at your liesure.

This is a rough draft:

Denise Brown
Mailstop 6N-602
Office of Regulatory Affairs
Enforcement Programs and Services
Bureau of Alcohol, Tobacco, Firearms, and Explosives
99 New York Avenue, NE
Washington, DC 20226
Ms. Brown;

In response to the document issued by the BATFE, entitled “ATF FRAMEWORK FOR DETERMINING WHETHER CERTAIN PROJECTILES ARE “PRIMARILY INTENDED FOR SPORTING PURPOSES” WITHIN THE MEANING OF 18 U.S.C. 921(a)(17)(C)”, I respectfully submit my comments and testimony for ATF review. (I have previously submitted comments in December 2012.)

Prior to providing a list of my specific grievances I would like to indicate the perspective from which I issue these statements for your review. I am a Federal Firearms Licensee, Collector of Curio and Relics of War, and in the past I have held both Dealer and Ammo manufacturing Federal Firearms Licenses.

I am an avid shooter and collector, as well as a multi-discipline NRA Certified Rifle, Pistol, and Shotgun instructor, NRA Certified Chief Range Safety Officer, and an official at NRA approved High Power and Smallbore tournaments. It is primarily from the C&R and High Power tournament official viewpoints from which I make the following rebuttals;

1. The BATFE has erroneously listed SS109/M855 ball ammunition as “Armor Piercing”. I would call attention to the United States Military and NATO designations for three ammunition types:
a. Cartridge, Caliber 5.56 mm, Ball, M855 (US military designation)
b. Cartridge, Ball, SS109 (NATO designation)
c. Cartridge, Caliber 5.56 mm, Armor Piercing, M995

2. The composition of the first two cartridges has a two part core with a steel portion in the front 1/3 of the projectile, and lead composing approximately 2/3 of the remainder of the “core.”

3. The composition of the third cartridge (what the US Military and NATO consider armor piercing) contains a core composed 100% of tungsten
Clearly there is a substantial difference in these projectiles; two are listed as Ball ammunition; one is listed as Armor Piercing. Which leads to a dissection of the Proposed Framework referenced above:

4. In the Proposed Framework document referenced above, the BATFE states:

“It is important to note that only projectiles that meet the statutory definition of “armor piercing” – i.e., those made out of the specific listed materials that may be used in a handgun – are subject to the statutory restrictions.”

5. Later in the proposed framework, the BATFE cites the applicable Federal Law (18 U.S.C. 921(a)(17)(B))

(B) The term “armor piercing ammunition” means—
(i) a projectile or projectile core which may be used in a handgun and which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper or depleted uranium; or
(ii) a full jacketed projectile larger than .22 caliber designed and intended for use in a handgun and whose jacket has a weight of more than 25 percent of the total weight of the projectile.
(continued)

6. Notwithstanding any other point, it is clear that according to Federal Law, and your own admission in the Proposed Framework, projectile composition is the only relevant point to consider from a lawful context of prohibition. The relevant point here is under (i); projectile core, and the key word, "entirely."

7. Consider the Federal Statute above states, in no uncertain terms, the deciding point in (i) is “[a] projectile core [..] which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper or depleted uranium” (emphasis again added on the word "Entirely")

8. SS109/M855 bullet composition is a copper alloy jacket (which does not exceed 25% bullet weight), with a projectile core composed of BOTH mild steel (approx. 33%) and common lead alloy (approx. 66%). Therefore, SS109/M855 does not qualify under the Federal Statutes as Armor Piercing ammunition; the core is not entirely composed of a prohibited material.

SS109/M855 projectiles have a widespread use in sporting events. At High Power tournaments, participants shoot thousands upon thousands of rounds of this ammo each year. Many shooters choose to use SS109/M855 ammunition as many of their Service Rifles prefer the 62 grain projectiles over the 55gr M193 projectiles. Clearly there is a sporting purpose for this ammunition.

However, on the basis of facts provided by the BATFE, and after examining the Federal Statute under 18 U.S.C. 921(a)(17)(B), it is abundantly clear that the BATFE has erred grievously on this issue; and that claiming a "Sporting Purpose" is irrelevant.

The proposed framework document you presented which references SS109 / M855 as “armor piercing”, however, the projectiles themselves DO NOT qualify based on material composition. The very discussion of removal of LEOPA exemption raises a startling question – why was SS109/M855 listed in the first place? The very consideration of removal of LEOPA exemption is a moot point, as the ammunition never should have required an exemption in the first place.

The BATFE is very clearly and definitively in the wrong on this issue; as neither projectile qualifies by Federal Law to have ever been categorized as an Armor Piercing projectile.

While you are in a period of consideration of your Proposed Framework, the BATFE should carefully consider what the ramifications of the agencies continued and willful violation of Federal Law will be.

As you specifically mention in your Proposed Framework;
“ATF recognizes that this ammunition is widely available to the public. Because it is legally permissible to possess armor piercing ammunition under current law, withdrawing the exemption will not place individuals in criminal possession of armor piercing ammunition.”

Prohibiting manufacture, transfer, and sale of a consumer good in widespread use, which the BATFE mistakenly classified in the first place, will undoubtedly grant cause for legal remediation of those affected individuals and organizations.

Rebuttal:

As a Federally Licensed Collector of Curio and Relics of War, as a sportsman, an avid NRA High Power shooter and tournament sponsor, and a concerned citizen and taxpayer, I respectfully request you consider the following:

1. Immediately vacate the Proposed Framework referenced at the start of this response.
2. Immediately vacate the Armor Piercing classification on SS109/M855, as this classification was not made in accordance with the defined Federal Statutes in 18 U.S.C. 921(a)(17)(B).

Sincerely,

{yours truly}

(Obviously you would need to change parts of the letter to suit you personally. I wanted to get my letter created first, then work on a form letter; or perhaps several versions. But I also wanted to get material on here ASAP for those who might need a little inspiration on points.)

I'll sleep on this one*, review again tomorrow, and finalize what I am sending before Monday. I'll also try to put out a shorter 1 page form letter for those of you who don't want to mail a novel.

*It is Valentines day so I am obviously not being fully truthful in how I plan on utilizing my time the rest of this evening. :evil:
 
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''ATF will carefully consider all comments...''[!]

Important phrasing, actually. Letters you send during the comment period are part of the official record (and thereby useful as evidence).

My rough draft above needs refined but the real goal of all of the letter writing, is to add to the trail of paperwork. This particular issue (as with any gun issue) has the very real possibility of becoming a larger legal issue (e.g. lawsuit), at a later date.

(To be tongue in cheek, this is assuming, of course, they aren't as bad at losing letters as some other government agencies are at losing e-mail.)
 
ATF has stated they will disregard duplicate submissions, so a copy and paste form letter may be ignored (ETA: ATF never published around 1000 comments submitted for 41P); however reading these letters can give some excellent ideas on general format and points you want to make.

I'll show my ignorance now but I have to ask, where would one generally begin to look for that info?

ETA: Nevermind. I think I found it in the TX penal code. It appears that if the exemption is removed, possession of M855 would become third degree felony although it does state "to be used principally in pistols and revolvers".

You would probably want to look in your state's penal code. In Texas, that would be Chapter 46. However, I think it extremely unlikely the state of Texas would start considering M855 type ammo as AP even after this ruling; but it is a bit of a gray area.
 
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Remember that a letter to your Congressperson should be brief and to the point and not as long as the comment sent to the BATFE.

Dear Congressman/woman ZAYB,

I ask that you stop the BATFE from banning the sale of M855/SS109 ball ammunition to the public.

Our military classifies M855 as ball ammunition and M995 as armor piercing, but BATFE classifies M855 ball ammunition as armor piercing in defiance of logic, military specification, and the LEOPA definition of armor piercing ammunition.

As a sporting shooter and owner of America's Rifle (the AR15 type), M855 ammunition is used in recreational, competitive, and hunting uses more than any other type of ammunition in the world and allowing BATFE to ban this ammunition after nearly 30 years would pose a hardship without benefit on the American shooting public and have a negative financial impact to the United States as it would force the cost of surplus and out of specification ammunition normally sold to the public to be destroyed at the expense of GOCO ammunition plants. The loss of such sales would be a financial hardship on the commercial operators of these plants supporting our military and put American taxpayer jobs at risk.

Please stop the BATFE from banning M855 ammunition sales to the American public.

Thank you,

AABBCC
 
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+1^^^
I've been saying the same thing on other boards but actually run into quite a few "it does not affect me, I don't like the M855 ammo, BATF's mind is already made up, our voice does not matter, etc." This type of indifference and inaction is what the BATF is betting on.
 
While many people don't care for SS109 ammo, and the BATF may well have their minds made up, we still need to do this. They must understand that we won't lay down while they scheme to take things away.
 
ATF is accepting comments on the subject until 03-16-2015.

ATF website: [email protected]. Follow the instructions for submitting comments.

Fax: (202) 648-9741.

Mail: Denise Brown, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, 99 New York Avenue, NE, Washington, DC 20226: ATTN: AP Ammo Comments.
 
A whitehouse.gov petition is another avenue to communicate our concern, but they're of value as long as we don't use them as our sole way to communicate that concern.

Do NOT let the easy routes like the whitehouse.gov petition website be your only way to tell the government and our elected officals that we do not want M855 type ammuntion banned from public sale.

DO send a personal and unique comment to the BATFE that meets the posting criteria (complete information, no profane or vulgar language, no insults) AND send a copy to your Congresspersons so they know you've sent a comment in to BATFE. There have been accusations that BATFE has not ultimately included comments complying with their posting requirements and having your congressional representative aware that you commented before the deadline can help them keep BATFE from undercounting comments.
 
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