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In discussing the forward pistol grip, the 2011 report noted that the feature allowed for
“continued accuracy during sustained shooting over long periods of time.” The report concluded
that this was not particularly advantageous for recognized sporting purposes based upon the fact
that, in such activities, a few well-aimed shots are paramount. However, there is a convincing
argument that this feature is generally recognized as particularly suitable for or readily adaptable
to sporting purposes because it permits accuracy and maneuverability even for activities such as
bird hunting or skeet shooting. The forward pistol grip permits a shooter to grip a shotgun at a
more natural angle in that the shooter is not required to rotate the forward hand and cradle the
firearm during firing. This ergonomic design provides for added comfort and more accurate
engagement of fast-moving targets. Therefore, the 2011 report will be amended and this feature
removed as a nonsporting feature.
Forward pistol grips are often attached to the underside of firearms through the use of an
integrated rail system—another feature that the 2011 report addressed. As noted in the report, an
integrated rail system, which includes rails on the side and bottom planes of the firearm, permits
a shooter to add several features to include flashlights, lasers or other items that are not
particularly suitable for or readily adaptable to sporting purposes. However, recognition of the
forward pistol grip as sporting would have little effect if integrated rails systems remain a
nonsporting feature. Therefore, because of the use of the forward pistol grip, it necessarily
follows that the integrated rail system is generally recognized as particularly suitable for or
readily adaptable to sporting purposes.

ATF received approximately 21,000 individual comments on the 2011 report. Many of the commenters argued, in effect, that 18 U.S.C. 925(d)(3) was unconstitutional and that the sporting purposes test was invalid, or questioned ATF’s interpretation of the sporting purposes test as it was applied to shotguns. Several commenters argued that although the report stated that certain features were not particularly suitable for or readily adaptable to sporting purposes, the features allowed disabled sporting enthusiasts to use shotguns. Principally, the commenters noted that forward pistol grips are an essential feature for this group of sporting enthusiasts.
Approximately 15,000 commenters addressed one or more of three points in opposing the 2011 report. First, the commenters focused on the impact upon an individual’s Second Amendment rights. Second, the commenters questioned whether some shotguns could be more dangerous than others and argued that all shotguns are appropriate for home defense. Finally, many commenters questioned the validity of the sporting purposes test as required by the GCA


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