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Dear ATF,
I am emailing this as a comment for the proposed changes to the SS109/M855 exemption to the armor piercing rules.
Your proposal states the change will have no impact on people already in possession of this ammunition.
This is incorrect. Several states have laws prohibiting possession and/or use of armor piercing ammunition. Some states, in fact, consider a person in possession of AP ammunition a felon. Considering how widespread and common this ammunition is, I believe implementing this proposal would be an extreme burden on the unsuspecting public. This ammunition is sold at Walmart. Making felons out of consumers overnight seems to be a terrible decision.
I am also confused about how SS109/M855 was considered armor piercing to begin with. Most believe it is because part of the core material is the steel penetrator. But the definition in the code specifies the core be constructed entirely of (one of the prohibited materials). The majority of the core of the SS109/M855 is lead. The word "entirely" exempts SS109/M855 from the definition of armor piercing. The steel "penetrator" inside the bullet makes up less than 50% of the weight/volume. No rational person would say that the core is made entirely of steel.
In my opinion, the special exemption given to SS109/M855 was unnecessary as it never met the definition to begin with.
Thank you for consideration of this comment.
Sincerely,
Your name
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