The Ammoland article summarizes it this way:
According to the report, any random part that the user could “readily” convert into a firearm would be subject to ATF regulations. As in the past, the document doesn’t define what the term “readily convertible” means. This term could be that any block of metal could be “readily convertible” into a firearm. In fact, the document shows that the ATF used a court case where it took the user eight hours to covert a kit into a gun. The document does highlight the need for a complete machine shop, and qualified workers to complete a firearm would not fall under the proposed rules.That last sentence leaves out home hobbyists with a reasonably good shop but with no "qualified workers" working for us, leaving us in limbo. Many of us could make an AR-15 lower from a hunk of raw aluminum bar, but using metal that's already part way toward a finished receiver, like say, an 80% lower, next year's 50% lower, or a "0%" forging simply means our shops can generate fewer ounces of metal chips and finish faster.
Inadvertently, the BATFE shows just how small this problem is.
The document makes claims that in the past four years that so-called “ghost guns” have been used in 325 homicides. Their definition of homicide includes justified killings as in self-defense. It does not separate out murders from the total homicides. Even if all 325 homicides included in the report were murders, this number is incredibly small. There are approximately 17,000 murders per year in the United States and that averages out to 46 murders per day. The reported small number they are trying to tie to so-called “ghost guns” highlights that there is not a problem.Note that they're claiming 325 homicides in four years. Out of the 17,000 murders per year, they're worried about 41?
A website new to me, called The Reload, offers an interesting take that Ammoland doesn't go near.
The document also proposes the creation of a definition for “privately made firearms,” which would apply to any gun without a serial number made by somebody who doesn’t have a federal gun-making license. Making guns at home for personal use with devices like 3D printers will not be affected by the definition. However, any privately made firearm sold to a licensed gun dealer would be required to be permanently marked with a serial number by the dealer before it could be sold.When I made my AR-15 from an 80% lower, I added a serial number that meant essentially nothing; I just figured it was easier to engrave a number than to explain to a potential Officer Friendly in a traffic stop why my gun didn't have a serial number.
I've downloaded the draft NPRM. It's likely to change before it's released, and it's 107 pages long so I haven't had the time to read the whole thing yet. One thing I noticed in the few pages I've read is that they seem to be trying to address that nasty little problem they have that an AR-15 lower doesn't match the legal definition of a receiver they're working to, and has made the BATFE drop cases they've been involved in. Back to The Reload:
The document also lays out plans to broaden and update the federal definition of firearms receiver to correct a problem with the ATF’s interpretation of the current definition. Courts have begun questioning the ATF’s long-running determination that an AR-15 lower is a receiver despite not including several of the parts required in the current definition. Prosecutors have been forced to drop cases involving the ATF’s determination in recent years.I've got to admit that seeing ATF incensed at courts for reading definitions as they're written brings a little bit of schadenfreude here.
The ATF admitted in the document that “neither the upper nor the lower portion of a split/multi-piece receiver firearm alone falls within the precise wording of the regulatory definition” but lashed out in the document at the “erroneous district court decisions” that employ a “narrow interpretation” of the definition.
The first video I ever put up on YouTube, one pass around the fire control group pocket in my 80% lower, back in 2010.
The columns are saying that DOJ has until May 8 to publish the NPRM, and then the comment period starts. It's hard to know just where this is going, but I think that at the very least that building a gun will be made harder. What they seemed to object to in all their actions against Polymer80 is the convenience factor of the company selling the kit of parts to complete the gun alongside the 80% frame. Fixtures that help you drill the holes for the trigger and safety, like the one in my video, might be made harder to come by because they add convenience.