MSR Pistol Designation In Doubt?

[grayfox]

I don't think politics or emails will help, unfortunately. We need some conservative activist lawyers to file suit that such letters violate the APA and therefore need to be nullified. APA (Administrative Procedures Act) governs rulemaking, it is not legal to pose as a rule without going through the entire rulemaking process, and making a "rule" that is vague and undefined also is in violation of the APA.
Guidance or "letters" are not enforceable as law. This has been proved many times for other agencies.
Liberal activists have used this approach for years, it's time we did the same.