M855 Letter

First, M855 and other SS109 variants aren't armor piercing ammunition by bullet construction under 18 U.S.C. §§ 921(a)(17) (B) (i) because the bullet core is not constructed entirely of steel. It is lead and steel.
Second, it's not covered by 18 U.S.C. §§ 921(a)(17) (B) (ii) because it is literally .22 caliber not larger; also the jacket does not consist of 25% of the total projectile weight.
Third, target shooting is sporting purpose and a change in the legal status of this ammunition creates an undue burden on the private citizen by eliminating a large supply chain of readily affordable ammunition.
Fourth, this ammunition is in "common use", (see Heller vs DC for definitions) and as the courts continue to expand on the meaning of that term it will expose this reclassification as a waste of taxpayer money and agency effort.
Fifth, because this ammunition is in widespread common use, if there were a marked tendency for it to be used against the police or for other nefarious purposes, there would be abundant stories and cases to cite pointing to the misuse of it.
Thank you for your time.
Angus McThagSuncoast, FL

This is my second attempt to send this.  The email address for ATF appears to be bad.