When I'm not blogging, machining, 3D printing, playing in the ham shack or doing things related to those hobbies, I've been reviewing the ATF's Notice of Proposed Rule Making 2021R-05. That's the one changing definitions of frames and receivers along with trying to greatly curtail the ability to make "Privately Made Firearms" or PMFs. My intent is to put together as coherent an argument as I can, so I tend to have the NPRM open and a document in Libre Office in which I'm collecting thoughts.
This leads to an Old Graybeard story.
The whole thing is reminiscent of the effort to stop the FCC from permitting the use of a bad technology back in the early part of the '00s. The technology was called Broadband over Power Lines, or BPL, and it was a boneheaded idea if ever there was one. The concept was to take broadband Internet to the homes and instead of putting it over cable TV coaxial cable or Fiber Optics, they were going to use the power grid. The amount of bandwidth a signal takes is related to the data rate; it's not 1:1 like a 10 Megabit per second line doesn't necessarily take 10 MHz, but in the "you don't get something for nothing" world of engineering, the 10 to 20 Mega Bits per Second signals they were talking about delivering, would take up essentially the entire HF spectrum.
This was being sold to solve some imaginary problem of lack of broadband into rural areas. Except the powerline technology isn't compatible with HF signals. Transformers are integral to the AC power grid, stepping voltages up and down over and over again. These things work at 60 Hz; they won't pass the HF signals. Every. Single. Transformer would need to have data jumpers around it, the system would need signal processing like amplifiers and filters all over.
There are many things wrong with the concept besides the hardware problems. The HF spectrum is allocated internationally and there are many services in there. Marine radio, commercial aviation, military services, industrial uses, international broadcast and ham radio are just some of the things you hear in HF. This threatened to wipe those services out near powerlines, which is virtually everywhere in the country. As a country, we're signatories to several treaties that would obligate us not to interfere with anyone else in the world.
I spent a long time responding to the NPRM from the FCC as just myself; so did
the company I retired from. Since HF receiver design was one of my
specialties, I was much more familiar with the reality of those signal
levels in that chunk of spectrum, and it was instantly apparent they were
going to seriously interfere with every single occupant of the shortwave
spectrum. Not just hams but aviation, broadcasters, military,
everyone. Conversely, ham transmitters could render the BPL system useless, too.
"Word on the street" was that the head of the FCC (Colin Powell's son Michael) was in the pocket of industry so it wasn't surprising the FCC made it legal. They exempted certain frequency bands, notably where their own monitoring stations were located, and a few other government frequency bands. They allowed other users to sue to shut down the BPL providers and the providers decided fairly early on they'd be facing bankruptcy from lawsuits and quietly went elsewhere in the spectrum. (My interpretation). Today, long distance/wide area BPL is gone and all that remains are some things that work over the powerlines in your house.
So what does that have to do with the ATF NPRM?
The lesson that I got out of that experience was the FCC was going to do it regardless of what anybody else said. The NPRM step was something they had to do because the Administrative Procedure Act of 1946 says so. They collected the thousands of comments against the idea and threw them out.
To be fair, I've seen honest NPRMs from the FCC in the years since. The FCC has accepted expert testimony from the ARRL or from groups of amateurs and modified proposed rules.
In the case of the ATF, it's hard to believe they'll respond to comments and improve the rules. I've never seen them be even as "sorta sometimes reasonable" as the FCC. I don't see why I'm bothering to work at it, but I just can't not do it. We can't just say, "whatever you say, Master" to them. Maybe a massive ground swell of opposition might have an effect.