I just cannot understand how they think this is true:
In this proposed rule, the Department accordingly interprets the definition of “machinegun” to clarify that all bump-stock-type devices are “machineguns” under the GCA and NFA because they convert a semiautomatic firearm into a firearm that shoots automatically more than one shot, without manual reloading,
by a single function of the trigger.
That's on par with saying Air Jordan's make you jump higher.
It's just not true. Were it so, bump stocks would indeed be classified under and subject to the NFA
already. They are not because they employ no concept which would classify them as being an NFA item.
In order to affect continuous shots, one must either have a semi-automatic and pull the trigger quickly (which is what non-spring assisted bump stocks do via recoil -- assist the shooter to actuate the trigger for every shot), or have an auto/burst feature such as in the military's M4/M16's. It is
mechanically impossible to have a semi-automatic firearm that shoots more than one shot per trigger pull, unless it is malfunctioning. The capability of 1 trigger pull = mor ethan 1 round fired is affected by modification of the fire control group(FCG),
not a shoulder stock. Modifying the FCG
is already covered under the NFA. As for semi-automatics and bump stocks, the force which actuates this physical phenomenon is in fact endemic to every semi-auto firearm in existence: namely, recoil and the ability to load a new round with the cycling of an action, and the trigger being pulled again, actuation of the firing process, recoil, repeat until the magazine is empty.
This is contrasted with burst or automatic fire which literally only requires 1 pull of a trigger for either a burst (typically 3 rounds) per trigger pull, or automatic fire which continues until the trigger is released
or the magazine is empty.
Pursuant to the phrase "increase the rate of fire" (Section II), this is in reference to cyclic rate of fire (CRF) and not the actual rate of fire (ARF). Increase of the CRF is impossible without modification to multiple parts, and results in a mechanical degradation and reliability of such a firearm, quickly rendering it useless. By ARF, all that is meant is the literal rate at which one fires. This can and does fluctuate, just as a car's speed fluctuates based on multiple factors. However, the intention behind its use by the Media, etc., is in the realm of the Cyclic Rate of Fire, which is mechanically set. For proof of this concept of ARF by the military's own training manuals, reference U.S. Army TC 3-22.9, Chapters 5 and 8 (introduction, 8-17, 8-18, 8-19, 8-20, 8-21, 8-22, 8-23). CRF reference per (depricated) FM 3-22.9, Chapter 2 (section 1, table 2-1). All semi-automatic firearms have a CRF which is what the Media has been trotting out, but then explaining it as if it is ARF. Additionally, the CRF, while usually around 600-900 rounds per minute, is hampered by the reality of magazine changes, jams, and mechnical breakdown of the system -- often due to heat which is generated by such a ARF nearing the CRF.
In short, it is absolutely ridiculous that the BATFE, Trump Administration, and the Media are trying to reclassify and turn on its head almost 84 years of legal language and precedent. There is literally no modification of the legally termed firearm, as defined by the NFA, which affects this reality of ability to bump fire. It is endemic to the reality of semi-automatic firearms. To change this is to engage with the slippery slope of the eventual reclassification of semi-automatic firearms as "machine guns", which is effectively what this proposed ruling is doing.