I think it's extremely important to find out how the bureau interprets the written law and how they don't. And it is quite critical to know when they've changed their position(s).
Bad idea. A poorly worded query is how we got the clarification we have, now (vs the previous "yes they can be shouldered" one). Moreover, it was unnecessary; the three items asked of "mother, may I?" already had letters and guidelines outlining their legal use. All another request can do is prompt a new ruling (which can happen whenever, but these letters present a more frequent excuse), which is almost certain to define a new barrier on our activity.
Better idea is to read the law yourself, use your head, ask around if the question is one anywhere near a "grey area," and then use your head again if it is. If it is your intention to willingly push the envelope, muster some resources and council, and know for sure what you are getting yourself into. Only then, send in the paperwork. Think of it like pinging the SCOTUS --some broader strategy and preparation is required for all our sakes.
"Can I turn right on red?"
"Is it legal to speed? Will you arrest me for going one over? Two? Three? What if I'm in a hurry?"
This is what many of these letters come off as. The individual points are either plainly in the statute or already widely known, or the series of questions itself is an obvious request to know "for what will I be prosecuted?" which is a boundary the ATF is both unwilling to divulge (legal advantage), and strongly suggests a tendency towards impropriety regarding the topic in question. IIRC, the ATF doesn't even have the authority to make such definitive/binding proclamations, being mere regulators and not legislators (hard to tell from their attitude, sometimes)
"It's illegal to make or shoot an unlicensed short rifle, but you won't arrest me if I shoot a nearly identical pistol off my shoulder, right?"
What could have possibly gone wrong?
BTW, no one go and ask something stupid like if it's legal to shoot a bare or tennis-balled buffer tube off your shoulder...remember when the tennis ball's were 'shady?' They still are, as is shooting an AR pistol off your shoulder. Sorry to all you who bought in while ignoring plain intent in a law as written
Anyone still think the ATF will suspend enforcement of SBR/SBS rules in the near future? I heard that tossed around quite a bit until recently...they may have, had we not tried to make them fools along the way, but there's little question, now.
TCB