I didn't go after the letter, but I was interested in this from the article:
"
“There are several things that are interesting,” Savage told AmmoLand News about the classification letter. “One, it shows pre-Gun Control Act ATF policy on the AR-15 system,” He noted. “It also shows why the most likely reason an AR lower is considered a ‘frame or receiver’ is that from 1962-1968 Colt marked the lower receivers with the information (flat surface as the upper is round). Meaning the regulatory scheme used by ATF 1968 to [the] present is based on what Colt marked pre-1968 and not the statute. Willfully and knowingly.”
“Len hit the nail on the head,” Stamboulieh weighed in. “The current notice of proposed rule-making reads as if there was just no way the ATF could have known that the AR-15 split modular design [various uppers fitted to the lowers] was a thing. Back in 1968, the agency promulgated the definition of frame or receiver, post-dating the classification letter of the AR15, and that shows why they should have originally known what they were making a definition for.”
He and Savage also cleared up a point of potential confusion on why the classification letter refers to the AR-15 as an “automatic rifle.”
"
[Bracketed material and underlining mine]
And so on.
I have long objected to folks referring to the uppers on these things as "the upper receiver" since in my paranoid mind, that opens the door to requiring serialization of the uppers and hence regulation thereof.
Once when I mentioned this people started defending calling uppers "upper receivers" and my thoughts were that they were just unwittingly helping the "ATF" extend its regulatory authority and I had no more truck with the issue at that time.
I decided to remain paranoid about the "ATF" and went no further with the idea at that time.
Terry, 230RN
