As the two new ATF Proposed Rules are open for comments in the Federal Register, GOA has established a web page with helpful tools that will help gun owners take action.

Gun owners can click here to simplify the commenting process and to encourage more people to voice their concerns against these two unconstitutional Proposed Rules.

GOA would also like to clarify some areas of concern that have been raised in the past to help gain more comments and ease any concerns.

Submitting a pre-written comment is useful. Submitting a unique comment is also useful. Doing both in the same comment is the best of both worlds.

So here are some things to consider:

• Submitting comments based on or identical to organization’s comments like Gun Owners of America’s comments WILL NOT DISQUALIFY YOUR COMMENT.
• While we openly encourage you to submit your own individual perspective on the new rule, following GOA’s model will benefit everyone greatly. Here’s why:

1) Submitting a Gun Owners of America model comment will help bolster GOAs legal arguments when we sue to overturn the rule down the road. It will be clear to the court that ATF disregarded thousands of certain common-sense arguments.

2) Submitting your own unique comment or customizing the GOA model comments gives the ATF more work to do when sorting after the comment period is closed and can thus help delay the final rule. You can also help ensure that every unconstitutional point is given as much attention as you see fit.

• The tool for submitting comments against a Pistol Brace Ban is here, and the tool for submitting comments against a Frame and Receiver Definition is here.
• Racism, harassment, submitting anonymously, and irrelevant information WILL DISQUALIFY YOUR COMMENT
• Using bots, fake email addresses, submitting multiple comments with duplicate email addresses, fake home addresses etc. will also disqualify your comment

To further ease your concerns regarding the disqualification of pre-written comments:

FROM EPA.GOV

Mass Mail Campaigns have special posting guidelines:

“In instances where individual submissions are deemed to be duplicate or near duplicate copies as part of a mass mail campaign, EPA will post to Regulations.gov one representative sample comment along with the total comment count for that campaign.”

Following this guidance, your model-based submission will in fact be counted as part of the comments, however you may not receive an individual response from the ATF, which is fine, as they will still respond with a comment regarding the general submission as well as note the number of times the comment was submitted.

There are major benefits to this:

1) The ATF is more likely to give a more comprehensive response to one comment that has been submitted a thousand times, rather than a thousand individual comments that may not cover the entire scope of implications from this rule.

2) This allows those who do not have time to read the entire 40+ or 70+ page proposed rule to still articulate a sound argument, thereby increasing the amount of engagement and attention each of these rules will get. Arming gun owners with the tools to participate in the public process to fight gun control is the core mission of Gun Owners of America.

3) The best of both worlds is to use the GOA Take Action tool to submit your comment along with a customizable message in the box labeled “Please add your own story about this issue to personalize your message.” That way our core arguments get made thousands of times, your submission gives the ATF more work to do, and more submissions talk about more elements of the Proposed Rule.

Regarding whether comments were getting deleted from the FCC’s Net Neutrality Proposed Rule, this PewResearch.org article sheds light on why many submissions were not accepted:

“57% of the comments used temporary or duplicate email addresses.”

While some of these comments were accepted, FCC’s attempted to sort out, “if any given comment came from a specific citizen or from an unknown person (or entity) submitting multiple comments using unverified names and email addresses.”

GOA encourages you to take action once, using your real email address, rather than using our tool to spam comments with false information.

“On nine different occasions, more than 75,000 comments were submitted at they very same second – often including identical or highly similar comments.”

This is what many are incorrectly citing as evidence that the FCC deleted identical or similar comments and therefore why you should supposedly not copy and paste a comment model.

However, the FCC deleted these comments not because the messages were similar but because these comments came from the same location and the same instance. This could easily be seen as fraudulent events, since it would be impossible for even 75,000 individuals to such precise timing.

In FCC WC Docket No. 17-108 Restoring Internet Freedom, 21.7 million of comments were submitted. Of these comments, only 6% were unique submissions and the remaining 94% were either similar or identical to organization’s model comments. These comments were then accepted and overturned the Proposed Rule.

Conclusion:

Pewresearch.org states:

“Nor is there anything inherently wrong or sinister about bulk filing of comments. This analysis simply highlights the scale at which digital tools are being brought to bear in the long-standing practice of commenting on proposed government rules.”

Using comment templates or even copying and pasting the information will not disqualify your comment from being submitted. In fact, taking action this way is a useful tool to encourage more citizen engagement with the government’s rulemaking process.

Using GOA’s Take Action tools, please submit a customizable comment to the federal registry using your name, full address, and email address so that that it will be accepted and we can tell these unconstitutional bureaucrats the American people won’t stand for these actions!