Comment on FR Doc # 2026-08914

RIN 1140-AA97 | Docket No. ATF-2026-0071 | FR Doc 2026-08914 Position: Support — and ATF should delete, not expand, its regulatory definition of "ammunition" I support clarifying that inert training rounds are not "ammunition" under the Gun Control Act and are not regulated under the Arms Export Control Act. The right to keep and bear arms includes the right to learn how to use them safely; the GCA's text addresses functional ammunition, not inert training devices. But the cleaner approach is to delete the regulatory gloss on the term "ammunition" in 27 CFR 478.11 and let the statutory definition govern on its own terms. ATF added regulatory text to interpret "ammunition"; that text is precisely the kind of agency interpretive layer Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), now subjects to de novo judicial review. Adding more regulatory text — even text that narrows ATF's reach — invites further interpretive disputes and gives future ATF leadership a hook to expand the definition by the same regulatory process. If ATF will not delete the regulatory definition, it should at minimum (1) make the carve-out for inert training rounds as broad and objective as possible, (2) include explicit examples in the regulatory text, and (3) confirm in the preamble that nothing in the rule is intended to expand the regulatory definition of "ammunition" beyond the statutory text. Recommendation: Delete the regulatory definition of "ammunition" and rely on the statutory definition. In the alternative, finalize the narrowest possible carve-out for inert training devices.