Jump to content

Recommended Posts

012611-study-on-importality-of-certain-shotguns.pdf

 

Just posted.

 

Non-sporting features:

 

"Following this review, the working

group determined that certain shotgun features are not particularly suitable or readily adaptable

for sporting purposes. These features include:

(1) Folding, telescoping, or collapsible stocks;

(2) bayonet lugs;

(3) flash suppressors;

(4) magazines over 5 rounds, or a drum magazine;

(5) grenade-launcher mounts;

(6) integrated rail systems (other than on top of the receiver or barrel);

(7) light enhancing devices;

(8) excessive weight (greater than 10 pounds for 12 gauge or smaller);

(9) excessive bulk (greater than 3 inches in width and/or greater than 4 inches in depth);

(10) forward pistol grips or other protruding parts designed or used for gripping the

shotgun with the shooter’s extended hand."

 

Current factory S-12's _may_ have #6 if you count scope rail as such.

 

Given the feedback on #6, it may be a stretch but I'm still reading it literally where it states "other than on top of the receiver" whereas S-12 scope rail is on the side of the receiver. Also the document specifically illustrates an example of a drum magazine being MD Arms items for S-12, it may be just to show that you can't import S-12 with a magazine over 5 rounds but it's rather strange to point this out unless they are being pro-active to head any potential magazine importation.

 

Excerpts:

"(6) Integrated Rail Systems.42

This refers to a mounting rail system for small arms upon which firearm accessories and features

may be attached. This includes scopes, sights, and other features, but may also include

accessories or features with no sporting purpose, including flashlights, foregrips, and bipods.

Rails on the sides and underside of shotguns—including any accessory mount—facilitate

installation of certain features lacking any sporting purpose. However, receiver rails that are

installed on the top of the receiver and barrel are readily adaptable to sporting purposes because

this facilitates installation of optical or other sights."

 

Note that "Rails on the sides and underside of shotguns—including any accessory mount—facilitate

installation of certain features lacking any sporting purpose...However, receiver rails that are

installed on the top of the receiver and barrel are readily adaptable to sporting purposes"

 

S-12 rail is on a side of the receiver and not on top so may be Izhmash can start making them AK-100 style with the rail integrated into a hinged cover.

Edited by Inzami
  • Like 2
Link to post
Share on other sites

Since when did current factory S-12's have a rail system anywhere??

 

I don't think that's going to bite the Saiga community so much as the ability to accept a detachable box magazine, and by extension, a drum. The Saiga and Saiga 12 drums are pictured in the study.

 

Be ready for the public comment period... that's our best shot.

Link to post
Share on other sites

I think this is great. The "study" says that shotguns with a rear pistol grip are sporting (unlike what they found for rifles). So the Saiga-12 should be importable with the trigger group in the right place, and a pistol grip separate from the buttstock. The buttstock couldn't fold, as on a 12C though. This should make it possible for a version of the Vepr12 to be importable also, since I don't think they make a version without the pistol grip. Other features, such as rail on the underside of the gas block, the folding stock and the flash hider are not OK, but the core of the gun should be fine.

Link to post
Share on other sites

Since when did current factory S-12's have a rail system anywhere??

 

I don't think that's going to bite the Saiga community so much as the ability to accept a detachable box magazine, and by extension, a drum. The Saiga and Saiga 12 drums are pictured in the study.

 

Be ready for the public comment period... that's our best shot.

 

Its all about importation and how they are brought IN to this country.

  • Like 1
Link to post
Share on other sites

Scope rail on the receiver doesn't count as integrated rail system?

 

Please show me an S12 that is currently being imported that has any of the features you posted above!

Besides, the study specifically says (other than on top of the receiver or barrel).

Link to post
Share on other sites

I think this is great. The "study" says that shotguns with a rear pistol grip are sporting (unlike what they found for rifles). So the Saiga-12 should be importable with the trigger group in the right place, and a pistol grip separate from the buttstock. The buttstock couldn't fold, as on a 12C though. This should make it possible for a version of the Vepr12 to be importable also, since I don't think they make a version without the pistol grip. Other features, such as rail on the underside of the gas block, the folding stock and the flash hider are not OK, but the core of the gun should be fine.

 

It reads like it. :super:

We could see some very cool, currently hard to acquire, authentic Russian pieces on our shores if thats true.

Link to post
Share on other sites

I haven't read all the info on the gunleader site, but on the public comment, is there a specific path to follow to express our views?

 

I should have been a little more forthcoming, apologies... Public comment means a 'review' period in the federal register; something like we just went through with ATF's so called emergency request for information on multiple rifle sales (so they can start a registry). We OWNED them during the 2.5 weeks they gave us for comments, so we will need to come through on this as well.

 

There will be updates on gunleaders.com with suggested comments, where to go to comment, etc. We'll have several options, including snail mail, fax, call & submission via www.regulations.gov. The latter is the most practical for our community and we excel at this form of activism. During the comment period for the NPS weapons regulation - there were 2 if you remember, we owned the comments by a margin of roughly 3 to 1 in the first and official period. During the "Mulligan" comment period that congress imposed on NPS, we held a narrower 2 to 1 margin over the antis.

 

I just shot my personal saiga 12 Friday so I'd be happy to update the forum once we have some 'go forth and comment' material.

Link to post
Share on other sites

This just pertains to the importability of the gun???

 

So will we still be able to restore these once we buy them?

 

Will people be allowed to produce and sell large capacity mags and drums still be available

Nothing has been ruled on. This is just a study of what ATF "experts" determined to be evil features under the 1968 GCA sporting purposes clause.

 

Any ruling will unfortunately create another stir in a few months I am sure.

  • Like 2
Link to post
Share on other sites

During the comment period people should comment.

 

Below are my intial thoughts about their findings and why they are erroneous

 

"Following this review, the working

group determined that certain shotgun features are not particularly suitable or readily adaptable

for sporting purposes. These features include:

(1) Folding, telescoping, or collapsible stocks;

 

Potential sporting benefit, fitting LOP to various sized hunters who may use that gun (i.e. a 6’2 father and his 12 yeard 5’ son), particularly beneficial to young shooters who grow each year. A telescoping stock is beneficial because a guns” fit” is important to a hunter being abler shoot effectively and comfortably. A weapon with an adjustable length of pull is the most economical and practical choice for a gun that will be shot by different sized shooters, or one shooter who is still growing. Also an adjustable length stock is an ideal piece of equipment for a rifle hunter. Depending on the position one shoots from, and in the field one uses what is available and practicable when a shot presents itself, the ideal LOP changes and a collapsible/telescoping stock is the only equipment that allows rapid adjustment maximizing the shooters ability to make an ethical hunting shot. Nothing about them is inherently unsporting. Nothing about a collapsible stock makes it less well suited to hunting than a fixed stock, and the as discussed above the opposite is very often true, it is value added for a hunting gun.

 

Similarly a folding stock may be of significant benefit to a hunter in terms of storing and transport of the weapon while traveling via vehicle during a hunt or packing the weapon in or out of camp (including via foot, a pack animal, brush airplane etc). It is not unlike a takedown rifle. Again the fact that it folds has value added and there is nothing about it that makes it less well suited for hunting.

 

(2) bayonet lugs;

 

(3) flash suppressors;

This serves a sporting purpose in any low light situation 30 minutes after dawn or before dusk , times when animals are particularly active and many hunting shots are taken. The benefit is that the shooter is not moementarily blinded by muzzle flash. This has several important benefits for the sportsman. He can best see how an animal reacted to determine if his shot was true. If an animal is injured he can see the moment it flees to know which direction it traveled. Tracking wounded game is essential to ethical hunting and a flash suppressor better enables that. It also allows for a faster potential follow up shot on either wounded or missed game. It is of notable aid on a hunting rifle. Also in areas that allow the use of a suppressor it is a means to mount that piece of equipment to the weapon.

 

(4) magazines over 5 rounds, or a drum magazine;

 

For some types of hunting this is a very valuable feature, most notably in various types of varmint hunting. Also with the problems caused by soaring snow geese population there has been talk of eliminating magazine restrictions which would make guns with the above ideal to that hunting. Further even where magazine limitations exist that does not mean that a firearm that could accept a larger magazine cannot simply be used with one that meets the restriction. Thus even if the firearm could be fitted with a larger magazine that hardly indicates that the firearm its self is not suited to sporting use.

 

(5) grenade-launcher mounts;

 

IDK, maybe a 38mm flare to signal with in case of an emergency if one hunts remote areas

 

(6) integrated rail systems (other than on top of the receiver or barrel);

 

As the study seems to note a rail that allows for an optic is beyond question of extreme value in many types of hunting. The conclusion that a rail in another area is not is erroneous. A bottom rail is a very easy way to attach a bipod to a rifle. The benefit of a bi pod on a hunting rifle almost goes without saying. It better enables a hunter to make ethical shots on an animal. A side or bottom rail is also an ideal way to mount a sling. A sling has two very clear benefits to a hunter. First it allows for the rifle to be slung to be carried as a hunter walks or does any number of things that require the use of two hands. Second, a sling is a device used to aid a shooter in accurately shooting a firearm. The technique is a basic marksmanship technique and can greatly aid a hunter in making ethical shots on animals. Rail interfaces have become a standard for mounting a peletora of accessories which might be of use to a hunter. In addition to bipods, optics, sling mounting points, they can be used to mount ammunition carries (such as a two round shot shell holder) or …

 

 

(7) light enhancing devices;

 

I’m not sure what this means. Does it mean a fiber optic sight, benefits for hunting are obvious and the same benfit of that type of sight for any shooting. Is it an illuminated rectical? The benefits again almost go without saying. Is this a flashlight? Where legal and in some types of hunting flashlights are of great value if not essential gear. Varmint hunting and night predator hunting come to mind.

 

(8) excessive weight (greater than 10 pounds for 12 gauge or smaller);

 

For a recoil sensitive shooter (due to injury, age, disablility, inexperience) weight is the one sure weight to reduce recoil.

 

In any type of hunting that does not require lot of long walking, a heavier gun is of no detriment and can be of value.

 

(9) excessive bulk (greater than 3 inches in width and/or greater than 4 inches in depth);

 

Relevance to sporting use or not?

 

(10) forward pistol grips or other protruding parts designed or used for gripping the

shotgun with the shooter’s extended hand."

 

Different shooters have different shooting styles. Many people are changing over to an extended grip that allows better control of the weapon in terms of rapid target acquisition and recoil mitigation. People often index this grip off of a vertical for grip and the new Angled fore grips are starting to become very popular for allowing a shooter to have a more ergonomic grip on his firearm. The benefit for hunting. Many of the benefits that these provide in other types of shooting are directly applicable to hunting. These also allow for indexing to rapidly achieve a repeatable grip. A repeatable grip enhances ones shooting particular when one must rapidly shoulder a weapon such as in hunting.

Regarding the rails, Varmint hunting, which is not "regulated" the same as game, is often legally done at night. Feral Hogs and other unwanted critters that destroy crops and livestock is a legitimate sporting use that many hunters and probably most ranchers participate in.

 

Light enhancing sights and a rail for a flashlight would be necessary for hunting nocturnal animals like Coyotes, Jack Rabbits, Marmots, Rats, Opossums, Hogs, and many others. Just because you don't need to buy a tag for it doesn't mean millions of hunters don't hunt for these animals each year and the best time to hunt them is often at night where spotlighting is legal (only two counties in Nevada have prohibitions on spotlighting varmints).

 

Regarding Bayonet lugs, we need to invent a "sporting" attachment that clips onto these like a scent blocking system.

 

Edited to add on telescoping stocks that over-unders are often broken down due to the long barrel lengths (32"+ for some) for transportation and most factory supplied cases require it. A cool solution would be a quick remove stock, where it detaches completely instead of folding (at which point a pistol grip would definitely be necessary).

 

The ergonomics of the AFG are intended for carrying it on the ready (something hunters obviously never do) for an extended period of time and it requires a rail and is considered a "forward pistol grip".

Edited by BuffetDestroyer
Link to post
Share on other sites

Check out pg 13-

 

"The fact that a firearm or feature was initially designed for military or tactical applications, including offensive or defensive combat, may indicate that it is not a sporting firearm."

 

Saiga receivers are based on the AK-47 action. IMHO, "sporting purposes" acrobatic semantics aside, the stage is being set- At least for an edict on making the Saiga harder to convert.

  • Like 1
Link to post
Share on other sites

"Sporting purposes" WTF That is for $3000 POS sidelock toys. Most of us here have a 12ga tool. We need to go after that unfortunate language, there is no "sporting purpose" in the 2nd A - unless shooting tyrants is "sporting"!

  • Like 1
Link to post
Share on other sites

I predict they will claim that since extended magazines exist, the ability to accept detachable mags makes them non-sporting (see the bit where they gripe about rifles with extended mags being 'unsporting')

 

Then expect the grabbers to follow up with a "why do you need an "unsporting gun?" and try to ban them domestically.

 

The best bet might be to bitch like mad with a fallback that there should need to be two or three items on the list to count, not just one-- ATF is reasonably happy since they can claim to be doing work and defining eeeevil features while shooters are reasonably happy since not much gets banned from import in reality.

Link to post
Share on other sites

There is a grand canyon sized gap between their major premise and conclusion it the little bit of what I've read. Their basic premise is that these are feature we haven't seen used in sporting shotguns until now. Since they weren't used widely for on sproting guns a gun with them is per se not sporting. That premise premise to conclusion might get you a C on a high school paper. It is seriously flawed many of these features haven't really existed period for shotguns period until relatively recently so how could they have been used for that sporting purposes until recently. You need to look at the suitablity of each item for sporting use not if it has been traditionaly used at a time it didn't exist. Things like rail systems are a great example. They clearly have a lot of sporting application but they are simply relatively new for shotguns.

 

On an aside citing Dodd's comments on the bill as evidence of the definition of sporting purposes bugs me so much. One members floor comments are not an acceptable basis for determining legislative intent as to what a term means.

 

Also one of their minor premises that features found on "military style weapons" means such features are not sporting is bases an ignores the history of the cross over between sporting and military arms and equipment. Throughout our nations history people have been exposed to weapons in the military and then seen the merit of them for sporting use. It turns out many of the attributes that are desirable in one realm are often desirable in the other.

 

In the next couple weeks I want to write of full response piece to this. There arguments on many of the features are strawmen. Also an agency probably has to at least consider if not respond to counter arguments and contrary evidence. They seem not to have considered many things IMHO. They often simply state that some feature is present on a military style weapon give its purpose there and then simply conclude a priori there is no benefit to it on a sporting gun because the particular military benefit isn't applicable. Could there not be other benefits? Or they set up a very limited view of what is beneficial to sporting use and say it doesn't meet that. This thing offends as a gun owner but it really offends the academic in me.

 

ATF will classify the

shotgun as sporting only if there is evidence that its features or design characteristics are

generally recognized as particularly suitable for or readily adaptable to generally recognized

sporting purposes.

 

How could they have been if they are new on the scene as the study starts out saying? Well all this means is you need to get manufactures to advertise things as being for hunting, get hunting magazine to publish articles saying it is useful for hunting, etc. That is the evidence they rely on. That's what they say below

 

This may

be overcome by evidence that the particular shotgun or feature has been so regularly used by

sportsmen that it is generally recognized as particularly suitable for or readily adaptable to

sporting purposes. Such evidence may include marketing, industry literature and consumer

articles, scholarly and historical publications, military publications, the existence of State and

local statutes and regulations limiting use of the shotgun or features for sporting purposes, and

the overall use and the popularity of such features or designs for sporting purposes according to

hunting guides, shooting magazines, State game commissioners, organized competitive hunting

and shooting groups, law enforcement agencies or organizations, industry members and trade

associations, and interest and information groups.

 

As backwards as the logic of if it isn't currently being used for that it isn't suited for it is (how will we ever grow inovate or evolve?) it means you can also make any feature sporting just by making it widely accepted. This is something concerted effort and money could make happen to a much larger extent.

 

I have to work on a real work project now but this is interesting and as I have time over the next few weeks I want to delve into it deeper.

  • Like 1
Link to post
Share on other sites

The good news is sporter saigas as imported seem fine and arguably with their definitions a PG saiga from the factory could be sporting so long as it had a fixed stock. Availability of larger after market mags shouldn't take it out of sporting if not imported with them. If they use the contrary logic then any tube gun that an extension available for is not sporting.

Link to post
Share on other sites

The only one I am somewhat concerned by is

 

(9) excessive bulk (greater than 3 inches in width and/or greater than 4 inches in depth)

 

If they mean on average, no biggie. If they mean at the deepest point, well, using uncle batfuck logic, that takes an S-12 with a factory 5-round magazine inserted right out of the picture.

Link to post
Share on other sites

it still comes down to what there likely to do, my guess would be the end of all Saiga imports from Russia. remember you dealing with the BATF, these are useless govt turds who don't care what you think only what ( big brother )can do to save you from yourself.

people need to realize the Feds are not your friend.

 

look at all the people they ( saved ) at Ruby Ridge and Waco, remember to them we are the peasants that have to be kept in line. even if means burning you to death or shooting a unarmed woman with a baby in her arms.

Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Loading...
  • Chatbox

    Load More
    You don't have permission to chat.
×
×
  • Create New...