A Treatise to ATF Regarding 'Bump Stocks'
By Mauricio Tavares. June 22nd, 2018
(This article may be downloaded as a PDF file.)
Comments on docket number ATF 2017R-22
Comments
I would like to present some of the reasons why I do not agree with your plan to classify bump-fire stocks as machine guns (ATF 2017R-22, Bump Stock Type Devices). A condensed version of your argument is found in the following quote from ATF 2017R-22 (I will be placing such verbatim quotes between *** and *** to make it easier to find in case my formatting is deleted):
*** "bump fire" stocks, slide-fire devices, and devices with certain similar characteristics (bump-stock-type devices) are "machineguns" as defined by the National Firearms Act of 1934 (NFA) and the Gun Control Act of 1968 (GCA), because such devices allow a shooter of a semiautomatic firearm to initiate a continuous firing cycle with a single pull of the trigger. ***
For the duration of my argument whenever I refer to a bump fire stock I will be specifically talking about the bump fire stock as defined in the United States Patent No. 6,101,918. Main reason for that the details of operation of this bump fire stock are documented in the patent.
A semiautomatic firearm uses the energy from the fired cartridge to load a new round and then to position itself for another shot, completing one firing cycle. Unless it is broken in any way, it would not satisfy your original definition of a machine gun because it cannot fire another round. The user has to first reset the trigger by moving it forward until it releases the sear (the fact long range competitive shooters will only allow the trigger move forward just enough to reset is beyond this discussion) and then once again press the trigger to fire the loaded round and repeat the entire process.
The recoil energy not used for performing the firing cycle is wasted either on the user’s shoulder or used by a muzzle break if available to attenuate the “kick” on the shoulder.
....... 
The author has gone to considerable trouble to argue the case against any proposed ban on 'bumpstocks'. The ATF wants to declare something that has been legal for almost a decade retroactively illegal, added to which it is illogical to state that the device is a 'dangerous and unusual weapon' when it is little more than an accessory. By that logic, is a rifle sling or bipod to be regarded similarly when as an accessory either can greatly increase control and accuracy!
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