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That excellent quote of the text you provided spells out that any modifications to a gun that allows any more than a single shot is to be prohibited.
Incorrect.
It prohibits any conversion to a machine gun. The previous sentence has just defined a machine gun. The “by a single function of the trigger” language is what’s critical to this case and you’re completely ignoring it. When reading laws, you use words however they’re explicitly defined if a definition is provided, not how you think they should be defined or would be used in common speech.
Like I said, Gatling guns are pretty highly analogous. They produce what most people would consider automatic fire. They’ve also consistently been ruled to not meet the definition of a machine gun going back to at least the 1950s because they don’t meet that single function of the trigger requirement.
The solution is to change the text of the law.
Nitpick: rule making power does belong to executive agencies (at least until this SCOTUS decides to reverse Chevron deference). Law-making power resides solely with Congress.
What this means, as you suggest, is that Congress sets up statutory bounds within law, then the responsible executive agencies create rules interpreting them and defining how they’ll be enforced. Where cases like this one go wrong is when the agency oversteps the bounds of the law as passed by Congress. At that point, the agency has engaged in creating new law rather than rules, which is why the courts swat them down.
I agree with your overall gist, just feel that’s an important distinction to understand the situation.