Is there a list of "good" pistol lower/brace setups?

[lsudave]

So, I have 1 AR pistol, and I'm just curious about this new proposed ATF brace rule. I know they have the form available, but I was wondering if anyone has started grouping potential combos and giving the "starting points".

For example, mine is a pistol lower from Palmetto State Armory, with a 6-position milspec buffer tube, and Mission First Tactical brace (fin). I'm really not sure how to score that, because while the tube is adjustable technically (has 6 holes), the brace requires a hex key to loosen and move. In my mind, that's fixed, not adjustable. Is that correct?

And where they score "length of pull", do you measure from where you set the brace up, or from the longest possible setup?

Anyone have a clearer understanding on this?

 

[WestKentucky]

It’s clear as mud by design. It all depends upon specific interpretations and even then it will be a tightrope walk. My take on it is that it’s best to just remove the brace and use other devices like cheek rest kits or similar. I think I will remove my brace once all the mess settles down to become law. It’s not worth the headache to me.

 

[reddog81]

It’s clear as mud by design. It all depends upon specific interpretations and even then it will be a tightrope walk. My take on it is that it’s best to just remove the brace and use other devices like cheek rest kits or similar. I think I will remove my brace once all the mess settles down to become law. It’s not worth the headache to me.

It's not a very good answer, but that basically mirrors my thought on the subject. I would assume the ATF will try and interpret the rules as aggressively as possible and I have no desire to be a test case.. I'll probably just take my 300 BLK pistol and buy the parts to turn it into a 450 BM rifle if new rules get by.

 

[hso]

Mission First Tactical brace

Yeah, that's going to fail.

 

[lsudave]

Yeah, that's going to fail.

Length of pull?

So, what theoretical options are there, in this case? I have a 10.5" barrel upper, that's a no-no if all my lowers are considered "rifles".

If I just ditch the brace entirely, it should be safe at that point (safe as can be expected), right?

 

[Zerodefect]

The shark fin has been largely ignored by all of this. And is a darn good option.

Although, I've ditched my ar pistols. With a little extra training, my 14.5's fit the same task perfectly well.

And clearing my house with a huge Mossberg JM Pro is also no issue.

 

[DoubleMag]

My take on it is that it’s best to just remove the brace and use other devices like...

Which, if the pistol lower was purchased complete with a brace ''from the factory'', is NOT an option. Many PSA (and other companies) pistol lowers / complete pistols where shipped this way.

I read it ?? somewhere (sorry legal, can't remember) but this Senator obviously read the same portion of the proposal...
https://www.kennedy.senate.gov/publ...to-ag-and-acting-dirctor-of-atf-6.24.2021.pdf

From 2nd page 4th paragraph is the relevant portion...
''ATF seems to believe that re-characterizing millions of pistols as SBRs is no big deal because the agency
kindly offers gun owners what it deems to be plenty of means of complying. They can surrender their
firearm to ATF. 10 Or, for gun owners who purchased firearms without stabilizing braces and later added
one, ATF will permit them to destroy their pistol braces (but not if the gun owners purchased the firearms
already equipped with braces). Or they can spend more than $400 to convert a brace-equipped pistol to a
long-barreled rifle ...''

FRIENDS... the comment period is still open and is the first step in significantly changing or even defeating this proposed rule.

 

[F-111 John]

So, I have 1 AR pistol, and I'm just curious about this new proposed ATF brace rule. I know they have the form available, but I was wondering if anyone has started grouping potential combos and giving the "starting points".

For example, mine is a pistol lower from Palmetto State Armory, with a 6-position milspec buffer tube, and Mission First Tactical brace (fin). I'm really not sure how to score that, because while the tube is adjustable technically (has 6 holes), the brace requires a hex key to loosen and move. In my mind, that's fixed, not adjustable. Is that correct?

And where they score "length of pull", do you measure from where you set the brace up, or from the longest possible setup?

Anyone have a clearer understanding on this?

Just going by the sample ATF Worksheet 4999 (here), the criteria under Section II of Adjustability is adjustable or telescoping attachment. The accompanying 26 page Supplementary Information submitted by the ATF (here) includes elaboration on how to interpret each line of the ATF Worksheet 4999. The narrative for the adjustability criteria (on page 7 of the pdf) says:

Adjustability. When ATF was first asked to classify an adjustable ‘‘stabilizing brace,’’ it responded that adjustability is ‘‘a feature commonly associated with butt stocks/shoulder stocks as well as firearms designed and intended to be fired from the shoulder.’’ 17 Although ATF ultimately determined that adjustability, in and of itself, is not determinative of a ‘‘stabilizing brace’s’’ design function on a firearm, it remains a significant indicator that the device is designed and intended to be shouldered. Weapons that do not incorporate an adjustable ‘‘stabilizing brace’’ will accrue zero points, while ‘‘stabilizing brace’’ designs that are adjustable will accrue 2 points.
​

The referenced footnote 17 reads:

17See FTISB Letter 303984, at 3 (Nov. 30, 2015).​

The ATF does not specify if adjustable designs that require a tool qualify as 'adjustable' for purposes of scoring on ATF Worksheet 4999.

The Supplementary Information narrative for ATF Worksheet 4999 Section III Length of Pull (pdf page 8) states:

Length of Pull. Length of pull is a common measurement of firearms that describes the distance between the trigger and the center of the shoulder stock. This is a measurement that may be used to fit a firearm to a particular shooter. Generally, taller shooters require a longer length of pull and shorter shooters require a shorter length of pull. Adjustable shoulder stocks are commonly available. Patents, advertising material, and other resources make clear that adjustability is meant to facilitate changing the length of pull.20 Such length of pull measurements are far less relevant when a pistol is involved because a shooter merely requires a device that reaches from the back of the firearm to the forearm. Far less variation exists between shooters in this way. A firearm with a ‘‘stabilizing brace’’ will accrue more points the further it is positioned rearward, indicating that it is intended for use as a shouldering device. Firearms with ‘‘stabilizing braces’’ that incorporate a length of pull of less than 10 1⁄2 inches will not accrue any points (zero). However, a length of pull that is between 10 1⁄2 but under 11 1⁄2 inches will accrue 1 point, while 11 1⁄2 but under 12 1⁄2 will accrue 2 points, 12 1⁄2 but under 13 1⁄2 will accrue 3 points, and a length of pull of 13 1⁄2 inches or more will accrue 4 points as this is a standard length of pull for rifles and is a decisive indicator that the firearm is intended to be fired from the shoulder.​

The referenced footnote 20 reads:

20See, e.g., U.S. Patent 7,762,018 B1 (July 27, 2010) (in which invention ‘‘provides structure for mounting the stock body and contains structure for the pre-set system utilized by stock bodies which are adjustable for length. The length of pull system comprises a series of pre-drilled threaded holes 56, which are off-set from a center axis. . . .’’).​

The ATF does not specify if an adjustable stabilizing brace is to be measured when in it's longest configuration.

Given the information that the ATF has provided, your questions are not answerable.

 

[Tirod]

Correct me If I'm wrong, I haven't read the proposed 4999 thoroughly, but can't you simply take off the brace?

I decided I was not going to convert it to something else, and I'm enjoying building a different new rifle instead. If it requires disassembling the old pistol and removing the short barrel, then I can forecast that barrels will suddenly go out of stock, so, I'm building ahead while I can and leaving the pistol as is until I can't.

We don't have a straight wall requirement, so .375 SOCOM master race checking in. Flatter trajectory to 300m. A near miss should knock down a deer.

 

[DoubleMag]

Correct me If I'm wrong, I haven't read the proposed 4999 thoroughly, but can't you simply take off the brace?

Yes it would appear so. After all, at that juncture of the worksheet ATF would determine you effectively have a ...STOCK style device. Just remember though, even though they claim under the points criteria its a ''stock'', you need to destroy it...not....put the ''stock'' on another rifle...

So convoluted !

 

[lsudave]

So, looking at form 4999, first page, it appears that if I were to add straps (it has slots for that), the MFT brace would pass Section 2.
SECTION II - Accessory Characteristics

• ACCESSORY DESIGN Not based on a known shoulder stock design 0
  
• REAR SURFACE AREA Minimized Rear Surface lacking features to discourage shouldering 1
  
• ADJUSTABILITY Adjustable or telescoping attachment designed for shouldering 2
• STABILIZING SUPPORT Counterbalance Design - Non-Folding 0
  
• “Fin- type” design WITH Arm Strap 0

As stated, I'm uncertain if "adjustable" by requiring an Allen wrench is actually adjustable, since the brace itself does not telescope or have a spring-loaded retainer. But that's ok, take the points and go on. With a strap, it proceeds. I will go find a strap.

Now, Section 3 is where I get uncertain.
SECTION III - Configuration of Weapon

• LENGTH OF PULL - w/Accessory in Rear most “Locked Position” * Measured from the center of the trigger to the center of the Less than 10-1/2 Inches 0 shoulder device / “stabilizing brace” 10-1/2 but under 11-1/2 Inches 1 11-1/2 but under 12-1/2 Inches 2 12-1/2 but under 13-1/2 Inches 3 13-1/2 Inches and Over 4

That's where I get hung up...
the rest

• ATTACHMENT METHOD Adjustable Rifle Buffer Tube 1
  
• “STABILIZING BRACE" MODIFICATIONS / CONFIGURATION ***with the strap, this should be a zero***
  • “Cuff-type” or “fin-type” design with strap too short to function 2
  • “Cuff-type” or “fin-type” design with strap made out of elastic material 2
  • “Fin-type” lacking an arm strap 2
• PERIPHERAL ACCESSORIES *** irrelevant, I can pick up a set of fixed iron sights, and that should drop this section to zero***
  • Presence of a Hand Stop 2
  • Presence of a Secondary Grip (indicating two-handed fire) 4
  • Presence of Rifle-type Back-up / Flip-up Sights / Or no sights 1
  • Presence of Reflex Sight with FTS Magnifier w/ Limited Eye-Relief 2
  • Presence of a Sight/Scope with Eye Relief Incompatible with one-handed fire 4
  • Presence of a bipod / monopod 2
  • Weapon as configured weighing more than 120 ounces 4

 

[Sistema1927]

I hope that everyone recognizes that the proposed rule, as written, is deliberately ambiguous. By design, this proposal is intended to scare gun owners away from AR pistols with stabilizing braces.

And heaven help the poor gun owner who purchased a pistol with a brace already installed. It appears that he doesn't have the option of removing the brace, and will either need to register as an SBR or forfeit the pistol. Those who built their own will be able to discard the brace and keep the pistol. Not all gun owners are on these types of forums, and I am afraid that many will unknowingly become felons if and when this is implemented.

It's by design folks, another in the ever growing list of infringements designed to disarm the populace.

 

[lsudave]

I am posting this separately since I didn't want the last post to get too long or cluttered.

I'm finding myself with a series of questions regarding all this;

1. Need clarification on "device adjustability". If it requires a tool, is it "adjustable"? Or are we talking a springloaded device, like seen on actual rifle stocks? Or a collapsible/telescoping device itself (NOT the attachment, but the actual device)?
2. LENGTH OF PULL - w/Accessory in Rear most “Locked Position”.... this seems to be the damning point on this fin. When coupled with the buffer, the length can be brought far enough back to get a 4.

 

[lsudave]

And heaven help the poor gun owner who purchased a pistol with a brace already installed. It appears that he doesn't have the option of removing the brace, and will either need to register as an SBR or forfeit the pistol.

So, help me out with this here-

If the brace is considered a STOCK, is not one of the options to pair it with a 16" barrel? Thus, making it a rifle? At that point, you're no longer in the SBR territory.

The question then becomes, what to do with the pistol barrel? I could always use another cheater bar to work on things, but I'd prefer it didn't cost $100.

 

[DoubleMag]

So, help me out with this here-

If the brace is considered a STOCK, is not one of the options to pair it with a 16" barrel? Thus, making it a rifle? At that point, you're no longer in the SBR territory.

Covered (kinda) in post#10. Unless, the Feds want it both ways; purposefully ambiguous until necessity gives rise i.e. prosecution; wave it in left hand it's Ok, but, in right hand it is not. If you have not submitted your comment yet perhaps this would be appropriate and OF COURSE, within the comment, always place ''please respond'' to each point.

The question then becomes, what to do with the pistol barrel? I could always use another cheater bar to work on things, but I'd prefer it didn't cost $100.

Build a virgin pistol upper! 1/3rd to 1/2 of the cost is the barrel, all that's left is the upper receiver, hand guard and BCG. But...if you are thinking of doing this you may want to purchase NOW, as ''another proposal'' wants to serialize at least one group of those items (that proposal comment period ends in less than 3 weeks)

 

[herrwalther]

The ATF points sheet is intentionally confusing with vague interpretations. If the new ruling passes, I fully expect to strip my AR pistol apart for a legal rebuild.

 

[once0217]

The check off sheet doesn't matter anyway, as it states the AFT can decide if it's a pistol or an SBR, based off how their feelin that day.

 

[lsudave]

The check off sheet doesn't matter anyway, as it states the AFT can decide if it's a pistol or an SBR, based off how their feelin that day

Yeah, I get all that; but nonetheless I'd like to at least start off with a shot at passing.

Hso stated the one I mentioned, wouldn't

Yeah, that's going to fail.

Which means, if I'm worried about it, I need to do something with this before it all goes down. Get a different brace, one that meets minimal criteria, and move/lose the one currently attached.

 

[hso]

one that meets minimal criteria

In my opinion, no one is likely to notice anything that isn't a blade type brace if a change occurs. Almost anything that might fit around your forearm is probably going to go unnoticed (unless they make easy adaptability a failing criteria then that would be easily seen).

So, no, we can't know yet what they'll fail if they get the changes through since we can only guess what they'll be able to get through. But, by reading the proposed changes we can expect anything that doesn't wrap around the arm to fail.

 

[lsudave]

In my opinion, no one is likely to notice anything that isn't a blade type brace if a change occurs.

Seems like a blade/fin with a strap would be good, as long as it isn't too long.

 

[hso]

Seems like a blade/fin with a strap would be good

I think that's wishful thinking. I expect the ATF will settle on something like the SB Tactical that structurally wraps much of the arm and secures with a strap and they won't want anything like the blades or fins.

 

[P Flados]

The proposed rule as written describes that blades can pass.

The adjustability and length of pull questions are one of the tricky details. A good argument would be to set the gun up to the desired length, tighten down the setscrew and fill the hole with epoxy. Alternately, get a standard buffer tube, drill one set screw detent at the correct location and you no longer meet their definition of "adjustable'.

 

[Frank Ettin]

… A good argument would be to set the gun up to the desired length, tighten down the setscrew and fill the hole with epoxy…..

Why is that a good argument? Would a regulator or a court be likely to accept that argument? Why? Is there legal authority (case law, statute, or regulation) to support it? Citations?

The point is that folks are always coming up with “good arguments.” But just because someone thinks his argument is good doesn’t mean that a regulator or court is likely to agree.

What makes an argument a good argument is supporting legal authority. No regulator or court will accept an argument without adequate, supporting legal authority.

So outlining a “good argument” isn’t really helpful without some discussion about how applicable, legal authority can support that argument.

 

[danez71]

Why is that a good argument? Would a regulator or a court be likely to accept that argument? Why? Is there legal authority (case law, statute, or regulation) to support it? Citations?

The point is that folks are always coming up with “good arguments.” But just because someone thinks his argument is good doesn’t mean that a regulator or court is likely to agree.

What makes an argument a good argument is supporting legal authority. No regulator or court will accept an argument without adequate, supporting legal authority.

So outlining a “good argument” isn’t really helpful without some discussion about how applicable, legal authority can support that argument.

Totally agree.

I think there is some basis for the epoxy idea but I dont think enough to say it's a good argument, at all.

Why I think that....

CA allows epoxy to address certain issues related to specific threaded barrel attachments and mags.

But I don't think it's mentioned for adjustable stock issues.

Based on that, and that its a state rule and not a tangent federal rule, I think the epoxy idea should be excluded from assuming that it's a 'good argument'.

 

[lsudave]

The proposed rule as written describes that blades can pass.

As I read their comments on blades, you're golden if you put a strap... as long as it's not too long.

Alternately, get a standard buffer tube, drill one set screw detent at the correct location and you no longer meet their definition of "adjustable'.

This could be a viable answer. Like I said, strapped blades are ok (they get a 0 if the strap isn't elastic).

Buffer tube with 1 hole, that's not adjustable; that's a 0 too.
Put the hole in the right spot, so that 'length of pull' isn't an issue- do some measurements, put the hole wherever you feel you could accept the total points. You can keep it flush if you want to add points elsewhere, or I presume fixed sights would let you go longer.

Here's a rhetorical situation:
as of right now, there's no law or restriction in place. And the brace/fin is just a plastic 'accessory', not a controlled object. I'm a newbie to ARs, I've posted that here on this forum several times. I've also posted that my preference in handguns is the all-metal frame style, especially steel frames.

Let's say I employ a cleaning method I've used for decades for steel guns, without removing my brace. And the brace gets dissolved/melted beyond repair, due to my ignorance (hey, I didn't think to explore what THAT solvent does to plastics , as I've never had to do that before). Say this happened yesterday, or tomorrow.... before this proposed rule comes into effect. What, then?
Do I have to surrender a firearm that is physically fully in compliance with all laws, because it came with something that is now a lump of plastic?