The SCCY Firearms DVG-1 takes SCCY pistols to a place they have never been before. Featuring a proven rugged polymer frame, state-of-the-art manufacturing, cutting-edge materials science, groundbreaking design and a name that has become synonymous with both reliability and value, the DVG-1 incorporates all that is righteous and wholesome about the storied CPX line of pistols into something even better. Now, the new DVG-1 adds an Information Age striker-fired trigger to the mix as well.

Like any deep cover revolver, the previous CPX pistol used a long, heavy double action trigger as its primary safety mechanism. This system worked well, but it was designed for down-in-the-dirt combat, not target shooting on the range. Whenever I exercised my CPX I would generally get a couple dozen rounds through it and be ready to take a break. The new DVG-1, however, has a markedly more refined comportment. How SCCY got to this point is indeed a fascinating tale.

Ballistic Ethos

Most gun companies offer a wide variety of handguns in a wide variety of calibers. Some even offer .22 Rimfire up to .500 S&W Magnum with everything in between. They say variety is the spice of life, and most manufacturers of firearms remain quite spicy. There is, however, a gleaming exception.

SCCY makes one single chassis very, very well. In 1998 Joe Roebuck, the human nuclear reactor behind SCCY Firearms, saw a need for a reasonably-priced, top-quality defensive handgun. The marketplace was littered with rarefied iron that might cost a working man a week’s pay. On the other end of the spectrum were pot metal death traps that would render only marginal service as paperweights. What American shooters needed was a quality defensive pistol that was dead nuts reliable but would still leave enough left over at the end of the month for diapers and baby formula.

Joe and Company succeeded beyond their wildest dreams. When I toured the SCCY plant several years ago they were the fifth largest producer of handguns in America—and they only made that one gun. In 2016, in the midst of the Trump-induced handgun slump, they still sold 160,000 firearms.

The original 9mm CPX could be had either with or without a manual safety in at least ten different colors. The subsequent CPX-3 and -4 were the same guns chambered in .380 ACP. All four models come with two 10-round magazines and interchangeable floorplates, both flat and extended.

Joe Roebuck might have trust issues. People’s lives ride on the reliability of these guns and the SCCY crew takes what they do very seriously. In the case of these handguns, every single component is made in-house, including the magazines. SCCY cuts and rifles their own barrels, mills their own slides and fire controls and presses out their own magazine bodies. That way Joe’s mob retains complete control of every aspect of the manufacturing process.

The heart of SCCY is actually the tool room. SCCY makes the tools that make their parts. Joe’s people keep their fingers on every single piece of this pistol. If something goes wrong, they don’t have to go looking around for someone else to blame. It is simply that nothing ever seems to go wrong.  

DVG-1 Origins

To understand the mindset behind this new gun we need to roll the way-back meter some 3,000 years to a verdant part of Israel called the Valley of Elah. The Army of Israel under King Saul was encamped on one side of the valley. The hosts of the Philistines occupied the opposite ridge. There resided in between the very real prospect of an epic bloodbath.

While both armies were formidable, the Philistines possessed a secret weapon. Towering above their armored warriors stood a legitimate giant. According to some period texts the giant Goliath stood nine feet, nine inches tall. In the context of the day he was considered invincible.

For obvious reasons, the Philistines felt it might be a good idea to decide the outcome of the conflict via single combat. They suggested that the Israelites should field a champion to engage the brute Goliath mano-a-mano, winner take all. To this end, they occupied themselves shouting epithets and curses at both the Israelites and their ethereal, invisible God.

No one among the armies of Israel felt up to the challenge save a ruddy teenager named David. Thin, young and rangy, David was a shepherd by trade and knew self-reliance. When first David volunteered to fight Goliath, King Saul was amused. Saul offered the child his heavy armor, but David demurred. He was a woodsman and would face the giant with nothing but his shepherd’s sling.

David retired to a small creek and selected five smooth stones of appropriate caliber. When eventually he faced the giant, his first shot sunk deep into the leviathan’s forehead, dropping him where he stood. David then retrieved Goliath’s heavy sword and relieved the fallen giant of his head. The fact that David took five stones into the fight does not imply a lack of faith. We find in 2 Samuel 21 that Goliath actually had four brothers.

The epic battle between David and Goliath has been immortalized as one of the greatest examples of martial prowess in military history. The details are chronicled in both the Old Testament scriptures and the Quran. When Joe Roebuck was looking for a novel name for his new, inexpensive striker-fired defensive gun, he chose DVG-1. DVG stands for David Versus Goliath.

Details

The beating heart of the DVG-1 is the tested, proven and patented Roebuck Quad-Lock System. This operating system guarantees reliable function with a variety of ammo types under any and all reasonable conditions. The basic recoil-operated action is adapted from the apparently perfect design John Moses Browning and Dieudonné Saive built into that first Browning Hi-Power pistol.

The polymer grip module is impervious to sweat and corrosion and features finger grooves that interface perfectly with the human form. The magazine release and slide stop are both located in the expected spots on the left side of the gun. The slide has aggressive gripping grooves, both front and rear.

The striker-fired trigger has a flat face for enhanced leverage. This makes the 5.5-pound pull weight seem all the more comfortable. The initial take-up is quite smooth and the reset is delightfully short. At first the break was a bit gritty. However, I cleared the gun three times, verified that there was no ammo within fifty feet of where I sat, pulled up Netflix and pointed my DVG-1 in a safe direction. About one hundred trigger manipulations later, it had smoothed out quite nicely. While the trigger’s personality was initially a wee bit crunchier than that of a comparable Glock or HK VP9, the gun costs literally half as much. Play with it once over a movie and the DVG-1 trigger will love you for it.

Sights are steel and indestructible. For an extra C-note you can get the gun equipped with a splendid Crimson Trace™ CTS-1500 Red Dot sight. The whole pistol breaks down with either a case rim or a healthy fingernail. You’ll legitimately not find better value anywhere.

Trigger Time

The DVG-1 feels oddly different from other, more expensive guns. For starters, it’s nice and short. The frame is just long enough to fit the human hand without protruding unduly. The finger rest magazine floorplate accommodates my fifth finger beautifully. The gun comes with two 10-round magazines and interchangeable floorplates, both flat and extended.

The 3.1-inch barrel is perfect for easy concealment and near-range engagements. If you want to ring steel a kilometer distant you need a different tool. If you want an utterly reliable defensive gun that packs eleven rounds onboard while remaining sufficiently small as to hide in a proper pocket, this is your iron.

As the point of this exercise is to prove that a guy on a budget can remain just as prickly as his wealthy counterpart, I landed a no-frills polymer IWB (Inside the Waistband) holster off of Amazon for $20. The holster hood is too high to accommodate the red dot sight, but that is an easy enough fix. I marked out the material that needed to be removed with a Sharpie and then carefully cut it out with a fiber-reinforced cutoff wheel on my Dremel tool. I then touched up the area with a sanding drum. The end result works perfectly and looks factory.

The DVG-1 is one of the easiest serious guns in the world to pack. Little .25 ACP mouse pistols might be easier to hide, but this thing offers proper 9mm pain on tap. Stoke it with some serious social bullets and the DVG-1 should be able to address any reasonable threats, along with most of the unreasonable sorts as well.

Like most all striker-fired guns, there are no external manual safeties on the DVG-1. Keep your finger clear of the trigger until you are ready to shoot and you will be fine. The DVG-1 carries and presents like a gun costing hundreds more.

The DVG-1 trigger is a delightful improvement over the long double action sort. The predictable take-up and benign break actually conspire to offer some exceptional accuracy. The DVG-1 was naturally reliable with everything we fed it, from lightweight 65-grain polymer Inceptor® rounds all the way up to heavy 147-grain ball.

This is a tiny gun firing a serious round, so it has some recoil. However, the broad back end of the frame distributes the chaos nicely. Magazines fall away freely when the catch is stroked. I found that I could actually make fast combat reloads with this compact gun as well, something that is fairly rare in the world of true deep carry defensive pistols. Unlike most pocket guns designed for deep concealment, shooting the DVG-1 is actually fun.

If I took my time, I could keep my rounds inside of a juice can lid at twelve meters. Moving with a purpose, I could still keep everything inside a standard silhouette out to twenty or so. If that kind of performance won’t solve your problems, you need some different problems.

Denouement

The SCCY DVG-1 is the little gun with a big heart. Joe Roebuck and his crew set out to do this one thing very well and they have pulled it off with the DVG-1. This well-executed deep carry pistol will do everything the Big Guys’ guns will at literally half the price.

You may have more money than you could ever spend. You might bind your cash up in bricks and use it to form a stable for your modest herd of albino unicorns. For the rest of us, however, money is something that reflects toil, sacrifice and pain. I want mine to go as far as possible. In the DVG-1 from SCCY you get reliability you can bet your life on, along with truly exceptional value.

SCCY DVG-1 SPECIFICATIONS

• CALIBER                              9mm Parabellum
• BARREL LENGTH              3.1in
• OVERALL LENGTH           6.01in
• WIDTH                                   1.0in
• WEIGHT                                15.5oz
• MAGAZINE CAPACITY     10+1
• COATING                              H&M Black Nitride
• MSRP                                     $299.99 / $399.99 with Crimson Trace CTS-1500 Red Dot Sight

SCCY DVG-1 PERFORMANCE SPECIFICATIONS

• Load                                                              Group Size (Inches)          Velocity (fps)
• ARX Inceptor 65gr Polymer                       0.75                                        1,664
• Black Hills 100gr Honeybadger                 0.8                                          1,142
• Winchester 115gr FMJ Active Duty          2.0                                          1,172
• SIG 115gr JHP V-Crown                            1.5                                          1,077

Group Size is best four of five rounds fired from a simple rest at 12 meters. Velocity is the average of three rounds fired across a Caldwell Ballistic Chronograph oriented ten feet from the muzzle.

War Story

The kid had never before touched a firearm. He was a responsible young man who held down a job as a clerk at a local convenience store. For his 21st birthday his dad bought him a SCCY CPX 9mm pistol. His application for a concealed carry permit was pending and he had not yet had time to complete the required training.

The young man dropped the gun in its original container along with an unopened box of ammo into his book bag before reporting to work. Once at the store, he stashed the bag in the break room. He and his partner were facing a long shift.

The armed robber surprised the young man and his terrified comrade, marching them both back to the break room and binding them up with duct tape. The thug explained in no uncertain terms that he was going to go clean out the register and then come back and tidy up the loose ends. The kid realized he had just minutes left to live.

The clerk worked feverishly to get his arms free from his bindings. Rushing to his bag he took the NIB SCCY pistol out and thumbed a handful of 9mm rounds into the magazine. He then stepped back into the store to confront the aspiring killer.

In the gunfight that followed the young man fired four rounds, the first four of his life. Two of them connected. When the cops arrived moments later, this awesome kid was doing CPR on the murderous thug who had just tried to kill him.

As is always the case in situations like this, the police took the young man’s gun as evidence. When the dust settled, the kid’s dad contacted SCCY to thank them for saving his son’s life. When the dad told them the cops took his son’s pistol, Joe flew the two of them out to Daytona Beach, FL, to meet his employees and take a factory tour. The kid left with a brand new pistol, free of charge. If you ever wondered why we take concealed carry so seriously, that’s the reason.

Joe Roebuck

Joe Roebuck is a mechanical savant. He was an introverted only child whose parents were well-educated immigrants. They inculcated into him at a young age a refined sense of hard work. By his 13th birthday, they had equipped a modest machine shop back behind the house. Joe toiled out there every evening and every Saturday producing parts for contracts his mom drummed up for him with local customers. He never saw a dime of the proceeds.

Joe learned to fly an airplane at age fifteen. By the time he graduated from high school (a year early at seventeen) he had earned about a quarter of a million dollars in his little shop. His parents presented this to him when he left home. A self-taught engineer, Joe eventually became head die maker for Schrade Cutlery. Using that cool quarter mill as seed, he then branched out a bit.

Joe designed the device used to emplace cardiac stents. Anyone who has ever had eyeglass lenses ground while they waited had them done on a machine Joe designed as well. After starting, growing and then selling several different companies, Joe Roebuck threw himself into designing and producing the best value-priced handgun on the planet. The end result is the new SCCY DVG-1. This gun is the culmination of Joe’s remarkable vision. sccy.com

This article first appeared in Small Arms Review V25N7 (August-September 2021)

There is no ammo available where I live. No 9mm, .38 Special, .223 or .308. Occasionally, if you are lucky and happen to be in a store just as the truck arrives, you may get a box or two of whatever brand or bullet weight they just received. But it is unlikely to be the brand and bullet weight you know to be accurate in your pistol or rifle. How can you maintain your skillset with this inaccurate combination? Clearly, you cannot shoot up your hoard of “the good stuff” in practice and have nothing left for your hunt, competition or saving your life!

Shooting skills are perishable skills, just like any other. If you need to practice, how can you measure your abilities when your firearm will not hold your usual group with the ammo you can get?

The author was taught to never present a problem without a possible solution. This solution may not work, but if you do not try you will never know. Here is a solution that may work.

Minimize the Variables

You are dealing with three variable sets:

1. Your firearm. In this case, a rifle.
2. Your ammo. In this instance, it’s not your known, preferred choice for accuracy.
3. And you.

The first thing is to control the controllable inputs. You know that this rifle, with “Brand A” ammo, shoots 1/2 Minute of Angle (1/2 inch at 100 yards) from the bench. How can you maintain your skills?

The author has the good fortune of having three levels of ammo for his preferred rifle: a very limited quantity of Match grade ammo (or “the good stuff”); a fair amount of okay ammo for informal matches “Grade B”; and a goodly supply of bulk-loaded bargain ammo (“Blaster” grade). This is the ammo for position practice—kneeling, sitting and offhand. It is not “bad ammo,” it is just not tuned to this particular rifle.

Take your rifle and the ammo you can get, which we will call “Blaster brand,” and go to the range. Sandbag your rifle to eliminate (or at least minimize) the effect of your shooting skills and shoot a group. Not a 3-shot group, but a 5- or even 10-shot group, with all the skill you can apply. The larger the number of rounds you fire, the greater confidence you can have that the minimum group size you have fired is truly the best this “Blaster brand” ammo can do from your rifle. Let us say you shoot a 2-inch group at 100 yards—certainly not something to be proud of, but the best you can manage with this ammo. Now you have established your accuracy potential with “Blaster brand”—2 inches, or 2 MOA.

Perfect Practice

Since 2 MOA is the best you can do, start your practice session. Since you know the best you can do is 2 inches, you also know that every shot outside of 2 inches from your point of aim is due to your skill (or lack of skill) for that shot or shots. Now you can work on perfecting your skill so your practice targets have 2-inch groups, the maximum accuracy your rifle and ammo can achieve. You can work on things like the position of your rest if you use one, or sling tension, or any of the other possible variables in your hunt/match/self-defense.

Along the way, do not change the zero of your scope or iron sights. After all, you want to keep your rifle (or pistol) set up for the big hunt or competition. If you absolutely must change your zero, be sure to write down exactly how many clicks and in what direction you changed it. Make two copies, one you keep with your rig, the other in a safe place, just in case a gust of wind blows your note away. That way, if your hunt or competition comes up before you can obtain more of your preferred ammo, you know precisely how many clicks in which direction to get back to zero.

And maintain your regular cleaning regimen, so the only thing you change is the ammo (and sights, if you must). If you intend to hunt with a cold, clean bore, make sure you know where that round will hit. Same thing if you will hunt with a cold, dirty bore. In fact, some very elite law enforcement snipers prefer a cold, dirty bore. Meanwhile, a high speed, low drag rifle instructor and graduate of several sniper schools insists students run a dry patch through their bores every morning just before opening fire, as he believes any trace of moisture in the bore causes an errant first shot. Whatever you decide, stick with it. Cold clean, cold dirty, dry patch first—consistency is more important than which method you choose.

All is not lost just because you have a limited supply of “the good stuff.” Dry fire (any modern gun except a .22) as if you are in a match or on a hunt. Same clothing, same holster/sling, etc. Learn more about your target. I asked a client heading for a safari in Africa, “What is minute of Elephant?” He had no idea, and did some research. So your question may be, “What is minute of Whitetail Deer?” You still need to know. And get to the range for some live fire with whatever ammo you can get—and practice!

And when the ammo shortage abates, slowly build up your supply of “the good stuff.” Not hoarding, but a supply to last you through the next “emergency.” When the author has enough for one match, he starts to buy smaller quantities, leaving “some for the other guy/gal.” Otherwise, the shortage will never end.

This article first appeared in Small Arms Review V25N7 (August-September 2021)

The post-World War II French program of infantry small arms included a light machine gun. Several models were developed.

Automatic Rifle

Châtellerault Model 1924 M 29

Based on an instruction dated October 17, 1951, the Manufacture d’Armes de Châtellerault (or MAC) small arms factory was to develop a Model 1924 M 29 LMG for the 7.62mm T65 cartridge. The barrel was replaced and a new extractor and magazine were fitted. The cost was about 10 600 French francs. A conversion was developed by their chief engineer, Lecuiller. Several prototypes were tested in 1957.

Another variation included a belt-fed weapon. Several pictures of it can be found, but they may be fake. The conversion seemed difficult to manufacture and no trial report could be found.

Heavy Assault Rifles

Several variations of assault rifles with heavy barrels were made:

• MAS 53 received a heavy barrel, a bipod, a flash suppressor and a short forearm. The stock received a rear monopod and a folding butt plate. The rifle could launch a grenade and did not have a bayonet.
• MAS 54 developed from the MAS 54 C, but was improved with a carrying handle. It was tested by the Section Technique de l’Armée (or STA) in October of 1954 at the French Army Proving Ground at Satory (near Versailles). They shot 44,000 cartridges with only 44 malfunctions.
• MAS A.P. 1959 received a quick-change barrel and was developed in three versions: standard (rifle), short (SMG) and LMG.

Light Machine Gun

Despite the condition of the “poor” Army of the Vichy Government, a project was developed to reach the best performance of a new automatic rifle/light machine gun.

A technical report from October 11, 1941 describes the project:

• Caliber: 7.5mm
• Light and short
• Easy to handle
• Able to shoot at aircraft at low altitude
• Able to shoot at light armored vehicles
• Simple design
• Easy to produce
• Easy field stripping
• Complete disassembly can be done by any soldier, with only a screwdriver
• Easy handling and instruction
• Protected against mud and dust

It had to include:

• Locked bolt
• Gas action or recoil
• Air cooled
• Loading with metallic disintegrating or articulated links
• Ejection on the right side, or under
• Two rates of automatic fire: 600rpm against a ground target and 900rpm against an aircraft
• Cocking lever on the right
• Barrel fitted with a flash hider and a carrying handle
• No safety lever was needed

Specifications of the automatic rifle:

• Barrel: 0.50m (19.68in)
• Weight: 7kg (15.4lbs)
• Stock with folding butt plate
• Rear monopod and folding bipod; and a light tripod (like a photograph tripod) to shoot against aircraft

Specifications of the light machine gun:

• Barrel: 0.75m (29.53in)
• Weight: 13kg (28.7lbs)
• Removable stock
• Two-position tripod (high and low) to shoot at ground targets and a special device to shoot at aircraft
• Tripod Weight: 15kg (33lbs)

This program seemed to learn lessons from the combat in May and June of 1940 and acknowledges (without saying it) the qualities of the German MG34 light machine gun. Strangely, on May 12, 1942, the German Armistice Commission allowed the conversion of 2,021 aircraft belt-fed machine guns (MAS 34 M 39) for ground use. The conversion would be made by MAS with tools, parts and plans furnished by the MAC factory. After an examination of the French request, the Germans also allowed the manufacture of 2,700 aircraft MAC 34 M 39 machine guns, out of which 679 came from captured stocks and 700 20mm H aircraft cannons (the amount was reduced later to 500) and another order would be given later for 200 more.

The machine guns had fluted chambers and the piston was removed. The MAS also proposed a conversion for ground use: 1) put it on the M 1915 tripod and 2) add rear monopod and bipod like the Châtellerault automatic rifle.

After Germany invaded the South of France in November of 1942, all of these projects were discarded.

After the 1941 program, in 1945 the DEFA (French Army Ordnance Organisation) started a new project for the development of small arms. The universal machine gun program was very similar to the previous ones.

The specifications of the May 25, 1945 project were:

• Cartridge: 7.5mm Model 1933 D (heavy bullet)
• Weight: 7kg (15.4lbs) with bipod
• Barrel: 235mm (9.25in) rifled, length 0.60m (23.62in), easy to change without a tool
• Action: At the choice of the designer
• Feeding: 50 magazine or belt-fed cartridges or 30-round magazine
• Lateral ejection
• Cyclic Rate: Between 500-900rpm
• Sights: Rear sight and rectangular front sight
• Air cooling
• Accessories: flash hider, silencer, muzzle brake, sling, carrying handle, tools
• Easy to produce

This program had to take into account the shortage of industrial equipment and the reduced production capacities during this period of reconstruction. Most of the parts needed to be made by stamping, sintering or casting, if possible. Raw material could be found in the country, in case of war. Disassembly was to be as easy as the Châtellerault automatic rifle and shouldn’t require any tools.

The light machine gun would need a rear monopod, a stock with stock folding butt plate and a bipod. The machine gun would use a 13kg (28.7lbs) tripod.

Between 1948 and 1953, several prototypes were developed by the Mulhouse research center and the Châtellerault and Saint-Étienne small arms factories.

Mulhouse Prototypes

In 1950, the CEAM manufactured a light machine gun, very similar to the MG42. It was developed as an automatic rifle, with a vertical magazine and a bipod. A heavier variation, fed with links and using a tripod, was also made. Both shot the 7.5mm M1929 or .30-06 cartridges. But the guns were too heavy and many malfunctions were noted during the testing, so the CEAM weapons were not selected.

MAS Prototypes

The machine guns developed by the MAS were very similar to the MAS 36 and MAS 38 prototypes with gas tubes (without piston) were presented: A light machine gun with a short barrel and a magazine or a machine gun with a long barrel, link-fed, both in 7.5mm and .30-06. The barrel could be easily replaced. It had a gas tube, a carrying handle and a flash hider. The frame was of rectangular shape. It received a bolt carrier, a bolt and its lock. The pistol grip included a selector and a safety lever.

Feeding could be done with a magazine or a belt, after an exchange of the bolt cover.

The gun works by gas action, without a piston. The light machine gun had a bipod and received a stock. The heavy model had a tripod MAS M 1950. The MAS 50 prototypes with a gas tube worked correctly but they were too heavy and the cyclic rate was too slow.

A MAS 53 was also made, lighter, with a sheet cover around the gas tube.

Châtellerault Machine Gun

The Châtellerault factory developed a blowback machine gun, with a two-part bolt and an inertia lever. Two variations were made: one magazine-fed, one belt-fed. To make production easier, an MG42 pistol grip was used. During the tests, some specifications of the guns were modified by the DEFA on March 30, 1951: the barrel had to be easily exchanged, feeding used disintegrating links and the caliber was to be 7.62mm T65. None of the factories could manufacture models in 7.62mm quickly, therefore production would be delayed. After the tests, the CEAM and MAS prototypes were rejected and the MAC model was selected, with a short barrel and a bipod to replace the F.-M. M 1924-M 29. A heavy barrel was selected for the machine gun.

A.A. 52

A.A. 52 and its variations were manufactured with modern techniques using many sheet metal parts. Only the barrel and the bolts were machined. The weapon worked with semi-rigid locking, the opening is delayed by an inertia-amplifying lever. The receiver is of rectangular section, with a cover receiving the feeding device at the top. The cocking lever with slide is on the right. The trigger mechanism and the pistol grip are under the frame.

The ejection port is under the frame and it has a folding cover. The bolt is made of a bolt carrier with a mobile head and an inertia-amplifying lever. The weapon received a telescopic stock with an articulated butt plate. The dismountable and interchangeable barrel was fitted with a handle also used for transport of the weapon. The barrel had a fluted chamber. The barrel has four right-hand grooves with a 240mm twist rate. The 7.62mm barrel has the same groves but with a 300mm twist rate.

A push-button safety is inserted on the trigger mechanism. There is no selector. The sights are made of a folding front sight and a U-notch rear sight, adjustable from 200 to 2,000 meters. After 1962, they receive phosphorescent pellets for night shooting.

Feeding can be made with German Gurt 34 links, or French-designed detachable links (several models exist). The feeding mechanism, trigger device and pistol grip are copies of the MG42.

The first machine guns were delivered in February of 1956 and 35,000 A.A. 52 in 7.5mm were made.

A.A. 7.62mm N – F 1

Development began in 1954 and was finished in 1962. After the MAC factory was shut down, the production was transferred to the MAS in 1964 and later to Tulle in 1967-68. Production of A.A. 7.62mm N-F 1 was 17,000 weapons.

.50 Caliber Machine Guns

Several prototypes of a .50 caliber heavy machine guns were developed to replace the .50 M2HB machine gun.

AME 12.7mm

Developed in Mulhouse, it could be tested by the French but was presented to the German Bundeswehr in 1963, without any success.

MAC 56 and MAC 58

Made in Châtellerault by a team (MM. Davail, Martin, Nardin and Rabbe), it was an enlarged version of the A.A. 52. The frame has no rear block and the dismounting of the gun is slightly different. The rear sights are scaled in hectometers from 0 to 30, the front sight can be folded down.

The feeding is carried out with metallic links:

• American detachable links,
• French-designed detachable links, similar but larger than those used with the A.A. 52,
• French-designed non-detachable links, an enlarged copy of the Gurt 34.

The barrel can be easily replaced; it has no water jacket or carrying handle. The 12.7mm automatic weapon has a particular trigger mechanism and several variations exist.

On the MAC 56, two rear handles are fixed to the frame with an axial trigger pushed by the thumbs, firing like the Browning U.S. M2HB machine guns. The barrel has a truncated, forked flash hider.

On the MAC 58, the trigger mechanism is completed by a conventional pistol grip. The safety is set by a lever on the left side. The barrel has a cylindrical flash hider with lateral holes. Both weapons are fitted with a recoil absorber. A French-designed mount, with a recoil-absorbing device, allowed the use of the U.S. M3 tripod on any vehicle mount initially intended to receive the American weapon.

Tested during a short time, this model was not selected because it did not show particular improvements compared to weapons of the same caliber already in use. In addition, there was interest in the 20mm automatic guns for the armament of armored vehicles.

Other Machine Guns

MAC 31

After 1945, the MAC 31 tank machine guns were converted for infantry use:

• MAS 31 A1, fed by a drum, mounted on vehicles or on a MAS 1945 tripod.
• MAC 31 A2, fed by a flat, curved, horizontal 35-round magazine, mounted on a modified U.S. M2 light tripod.

Newly-manufactured MAC 31 E weapons with a short barrel were used on the AMX 13 light tank or on the EBR armored vehicle.

MGD

The MGD prototype was developed by Merlin Gerin Company, which also produced a light machine gun with the same mechanism. The machine gun was presented in 1946, but was not adopted.

This article first appeared in Small Arms Review V25N7 (August-September 2021)

PRIMARY ARMS OPTICS

GLx Microdot Riser Mounts

Primary Arms Optics announced the release of its new GLx Microdot Riser Mounts. GLx products bring premium technology and materials into an approachable price point, and these mounts stand out with exceptional material quality and engineering at an affordable value. Out of the box, GLx mounts come with an added spacer, providing the user two separate mounting heights (1.41/1.535 and 1.64/1.765) to match their preference.

The durable 6061-T6 aluminum main body and keeper are enhanced by two sets of oversized, hardened-steel hardware, featuring a black zinc phosphate coating for added resistance to corrosion. In addition to the cross bolts which act as recoil lugs, the mount base also includes a machined recoil lug to retain zero through repeated impact. When torqued to 55-65in-lbs the cross bolts provide over 3800lbs of clamping force ensuring zero retention through even the harshest abuse.

Both absolute and lower 1/3 co-witness models are priced at $49.99, making them a great choice on any budget.

primaryarms.com

PULSAR

Thermion XM30 Thermal Riflescope

Pulsar has unveiled its next iteration of the Thermion product family—the Thermion XM30 3.5-14x Thermal Riflescope (PL76524). This elite thermal scope boasts 12 µm pixel pitch with 320×240 resolution, so users can see the heat signatures of adult-sized objects up to 1,400 yards away, day or night. Whether you’re hog, predator or varmint hunting, the XM30 gives you the imaging you need. The fixed-focus Thermion XM30 features built-in recording with sound, Picture-in-Picture mode, Wi-Fi connectivity and Stream Vision app compatibility so you can capture and preserve every hunting memory.

Remarkably rugged, the XM30 is housed in a metal body with IP67 dust- and waterproof rating, operating temperatures from -13F to 122F and can withstand recoil up to .375 H&H. The XM30 is powered by a B-Pack Mini Li-Ion battery with up to 5 hours of life.

Other features include an 8x digital zoom (continuous and stepped zoom), 3.5-14x magnification, external power supply adaptable, 5 rifle profiles with 50 zero saves, 13 variable electronic reticles, one-shot zeroing with freeze function, high resolution AMOLED display, stadiametric rangefinder, defective pixel repair feature and more.

pulsar-nv.com

STREAMLIGHT INC.

TLR-7 Sub Ultra-Compact Tactical Gun Light

Streamlight introduced the ultra-compact and low profile TLR-7 Sub Ultra-Compact Tactical Gun Light, a weapon-mounted tactical light with an ergonomic on/off position rear switch. It is available to fit select GLOCK, SIG SAUER, Smith & Wesson, Beretta, Springfield Armory and Heckler & Koch railed subcompact handguns.

The TLR-7 features an LED that delivers 5,000 candela and 500 lumens over a beam distance of 141 meters. Custom TIR optic produces a concentrated beam that provides both extensive range as well as optimized peripheral coverage. It offers two lighting modes, LED only or LED strobe, each with a run time of 1.5 hours. The light is energized by a single 3 Volt CR123A lithium battery.

It features a one-handed, “snap on and tighten” interface that keeps hands away from gun muzzles when attaching or detaching them, a safe off feature and a specialized clamp system for mounting to rails (using the provided key kit). It weighs 2.39oz and measures 2.51in in length. It features an IPX7-rated design, making it waterproof to one meter for 30 minutes, as well as impact-resistant construction. The MSRP is $225.75.

streamlight.com

GUNEYE

HD360 IR Smart HD Gun Camera

The GunEye HD360 IR Smart HD Gun Camera has broken boundaries by combining a camera, night vision and video/audio recording (with the GunEye’s patented Secondary Sighting System S3 Technology) into a single, mountable module. GunEye will keep you and your loved ones out of harms’ way, both in the home and in the courts. Its S3 Technology minimizes your exposure, keeping vital organs safely behind cover. The platform allows you to keep a low profile, optimizing your chances to see the target before they see you, day or night! 

GunEye’s metal housing, combined with its shock absorbing mounting system allows the user to stay out of harm’s way even in high impact situations. Under high stress conditions like a home invasion, it is common for people to suffer memory blanks and even distortion of events. GunEye’s video and audio features will have your back by providing a record of the engagement for any legal issues that may arise post conflict.

GunEye is a minority, veteran owned company focused on the development of secondary remote optics solutions. Founders Celeste Zotto and Steve Kraft created GunEye to provide people in life-threatening situations the ability to minimize the risk of serious injury to them and their loved ones.

guneye.com

OTIS

Professional Pistol Cleaning Kit for Glocks

Otis announced its newest addition to their family of cleaning kits geared toward pistol shooters—the Professional Pistol Cleaning Kit for Glocks. This kit is a must-have for any Glock owner.

This new kit cleans and maintains 9mm, .40 caliber and .45 caliber Glock pistols and takes firearm maintenance to the next level. Featuring Otis’s Breech-to-Muzzle technology, the Professional Pistol Cleaning Kit for Glocks boasts three bronze and three nylon bore brushes, Memory-Flex cables and three caliber-specific Ripcords (9mm/.40 cal/.45 cal). Also included is a steel pistol loop rod and Otis’s 8-in-1 pistol T-Tool for pushing and resetting pins, front site adjustment and more. Additionally, this kit comes with a magazine plate removal tool and a patriotic slide back plate to customize your Glock.

Otis offers a number of pistol cleaning systems, but this is the first one to offer magazine removal tools and customizable accessories. The product retails for $99.99 and the included back plate has a retail value of $24.99.

otistec.com

TALON GRIPS

1911 Modular Grip System

TALON Grips launched a revolutionary new 1911 Modular Grip System. It is a four-piece modular system (left side panel, right side panel, frontstrap and backstrap) that collectively gives each user their own custom grip preference on their favorite 1911.

The TALON Grips 1911 Modular Grip System gives their customers the ability to mix and match TALON grip materials for the very first time! This four-piece design fits most MIL-SPEC 1911 frames, with little to no trimming. Made from the same tried and true TALON materials, you can expect these grips to last 1-3 years with heavy use. Backed by their outstanding warranty and customer service, this new modular grip system will be a great addition to the TALON Grips line.

talongungrips.com

This article first appeared in Small Arms Review V25N7 (August-September 2021)

Hiding Hilda LLC

Rhonda Concealed Carry Mini Backpack

Hiding Hilda is excited to introduce Rhonda—our new Concealed Carry Mini Backpack! Rhonda is made in America and perfect when you’re on the go! Plenty of room for full-sized wallets. Lots of outside pockets make finding your essentials easy. Lightweight and machine washable, with the ability to lock concealment pocket (locks not included). Includes removable leather holster. Fits most firearms.

MSRP $109.00

hidinghilda.com

Jessie & James Handbags

Hannah Concealed Carry Lock and Key Crossbody

The Hannah Crossbody is made with faux leather and features an adjustable shoulder strap. A separate concealed compartment is on the back to store your weapon and includes a lock and key feature for extra safety. This purse also includes an exterior zipper pocket, central divider and a matching removable holster. 

MSRP $ 49.99

jessiejameshandbags.com

Jessie & James Handbags

Brooklyn Concealed Carry Lock and Key Crossbody

The Brooklyn Crossbody is made with faux leather and features an adjustable shoulder strap and RFID protection. A separate concealed compartment is on the side with a zipper to store your weapon that includes a lock and key feature for extra safety. This purse also includes a matching removable holster and 5 exterior pockets for extra storage.

MSRP $ 59.99

jessiejameshandbags.com

Sentry Products Group

Sentinel Range Bag – Pistol

Perfect for a trip to the range. The pistol range bag features a dual zipper panel for easy access to 1,020 cubic inches of storage space, two external pockets for storage of cleaning supplies and accessories, YKK Coil zippers with accent pull tabs for ease of use with gloved hands. The outer shell includes our patented 1080-2 technology mounting panel on the front pocket to securely mount pouches, tools, or accessories.

MSRP $89.99

SentryTactical.com

CLOTHING

Tactica Defense Fashion

Concealed Carry Leggings

The Athletic Concealed Carry Leggings from Tactica Defense Fashion aren’t just leggings with pockets; they’re leggings with built-in concealed carry pockets front and back. Available in 5 different color options, they also feature a side pocket great for cellphones and other incidentals. The leggings are made with a spandex/nylon blend to be fashionable and comfortable in any setting from the gym to a casual night out.

MSRP $69.99

tacticafashion.com

HOLSTERS & BELTS

Alien Gear Holsters

Low Pro Belly Band

The new Low-Pro Belly Band is the latest innovation in concealed carry from Alien Gear. A vented neoprene padded backing secured with a durable hook and loop closure combines with their proven thermoplastic holster shell and spring-steel core base for a natural draw angle. The Low-Pro Belly Band Holster is very slim and comfortable.

MSRP $67.88

aliengearholsters.com

Alien Gear Holsters

ShapeShift Core Carry Pack

The ShapeShift Core Carry Pack is what you need when you need it. The ShapeShift system features an injection molded holster shell that converts across different carrying platforms without requiring tools. The Core Carry Pack features IWB, appendix, paddle, belt slide configurations as well as mounting bracket. Additional options such as MOLLE and drop leg options are also available, making this an extremely modular holster system.

MSRP $99.88

aliengearholsters.com

Bigfoot Gunbelts

Standard Gun Belt

Bigfoot may be hard to find, but a good leather belt isn’t when it’s a Bigfoot Gun Belt. All of their leather belts are made with two strips of top-quality English bridle leather stitched together with heavy-duty polyester thread, a steel roller buckle and a triple-edge finish. These are belts are 100% manufactured in the U.S.A. and are designed to last a lifetime.

MSRP $68.88

gunbelts.com

Bigfoot Gunbelts

Tactical Rigger’s Belt

Bigfoot Gun Belts took the tactical community’s favorite belt, the rigger’s belt, and their own spring-steel core technology which makes their leather belts so amazing and combined the two. The Bigfoot Tactical Rigger’s Belt features a dual spring-steel core stitched between durable nylon webbing, as well as a triangular forged steel D-ring, and fastened with a genuine AustriAlpin COBRA buckle for maximum security and durability.

MSRP $89.88

gunbelts.com

Galco Holsters

Corvus Belt/IWB Holster

With an open top for fast draw, adjustment for ride height and cant, virtually maintenance-free Kydex construction and comfortable forward molding, Galco’s versatile Corvus is a superior defensive holster choice. Packaged set up for belt carry, the Corvus is swiftly and easily convertible to a highly-concealable IWB holster. The modern layout is designed to accommodate most carry-style optical sights, while the deep sight rail accommodates most suppressor-height sights.

MSRP $86.00

galcoholsters.com

Galco Holsters

KingTuk Cloud IWB Holster

The KingTuk Cloud IWB combines extremely comfortable carry with superior concealment. Its outstanding comfort comes from the innovative backing plate, with a ballistic nylon over closed cell foam, and lined with breathable, moisture-wicking Comfort Cloth. The rigid Kydex holster pocket provides fast draw and easy holstering while facilitating a full firing grip. The KingTuk Cloud uses Galco’s patent-pending, tuckable polymer UniClips for excellent concealment, stability and easy on-off capability. MSRP $89.00

galcoholsters.com

Hiding Hilda LLC

Pistol Wear

Pistol Wear—Hiding Hilda’s favorite, most comfortable holster! This unisex versatile holster was designed for casual, athletic or professional dress attire. It has a soft, cushioned holster designed for under arm, IWB or OWB carry. Great with yoga pants! Pistol Wear concealment holsters are comfortable and include an adjustable support strap that can be placed anywhere to achieve the most comfortable fit.

MSRP $50.00

hidinghilda.com

Sentry Products Group

Ultra Carry Inside the Pant/Tuckable Holster

Injection molded soft polymer blend concealed carry holster providing low profile with comfort and flexibility. The Level 1 retention Tuckable holster with the Drop Retention Safety Device and the STR System allow a retention screw operating on the weapon’s slide to adjust for a smooth draw and re-holstering. The Ultra Carry also features an angle adjustable clip attachment system.

MSRP $34.99

SentryTactical.com

StealthGearUSA

Ventcore IWB Mini Holster

The Ventcore IWB Mini is StealthGearUSA’s best-selling holster. Many concealed carry users across the globe have praised its rock solid retention, discreet profile and all-day comfort. The foundation of the design lies in Ventcore Technology. Using a proprietary blend of synthetic layers, ports are laser cut at specific intervals to provide maximum breathability and comfort—while remaining rugged enough to endure hard use. Come see what Ventcore can do for you.

MSRP: $99.00

stealthgearusa.com

StealthGearUSA

Ventcore Single Standard Mag Carrier

When it comes to preparedness, the Navy SEALs have a maxim, “two is one and one is none.” If you support this line of thinking, then a Ventcore Single Standard IWB Mag Carrier from StealthGearUSA may be for you. Crafted from the same Ventcore Technology that goes into their holsters, these mag carriers allow you to securely pack an extra magazine for your handgun in covert comfort that goes as long as you do.

MSRP: $49.00

stealthgearusa.com

Tactica Defense Fashion

Corset Holster

The Corset Holster from Tactica Defense Fashion features a slim and comfort-fit design made of an elastane blended material. The two front holster pockets are designed to make the Corset Holster ambidextrous and provide a place to hold a spare magazine. The Corset Holster is available in three different color options and provides a method of concealed carry with a wider variety of clothing options.

MSRP $89.99

tacticafashion.com

Walther

Walther EDC Belt

The Walther EDC belt is a collaboration with Tacbeltz, a classic double layer is the perfect EDC (everyday carry) belt. The two layers make it great for any firearm IWB or OWB. If you appendix carry, this belt will be your best friend—no more fighting with a buckle trying to get that perfect placement. Give it a try, you won’t be disappointed. The Boss Double is made of two 1.5” wide nylon layers. The buckle is made of 2″ nylon.

MSRP: $49.99

waltherarms.com

Warcat Tactical

Warcat Appendix (AIWB) Holster

The Warcat Appendix Carry Holster is designed and manufactured to be slim, compact and durable. Warcat holsters are injection-molded polymer holsters, stronger and more heat resistant than Kydex. In addition, Warcat holsters have an optional red dot optic shroud, as well as a holster claw, available.

MSRP $17.76

warcat.com

Warcat Tactical

Warcat OWB Holster

The Warcat OWB Holster is a compact, injection-molded polymer holster, stronger and more durable than Kydex. The Warcat OWB Holster is designed with their “slim paddle” to allow for greater concealability than other OWB holsters and the addition of an optional optic shroud to protect your weapon’s sights, makes it unique among other compact OWB holsters. Only available for purchase as an addition to the Warcat Appendix (AIWB) Holster.

MSRP $5.00

warcat.com

The Wilderness

Ankle IFAK/Cargo Cuff

The Wilderness Ankle IFAK/Cargo Cuff packs a micro trauma kit or EDC loadout into a concealable carrier that is at home on the ankle, in a car door cubby or backpack. Made of ruggedized elastic with optional retention straps, six cells will store anything from tourniquets and pressure bandages, to basic first-aid, emergency cash, I.D. or flash drives. Pair with their Renegade Ankle Holster for a complete peace-of-mind duo.

MSRP: $40.00 and up

thewilderness.com

The Wilderness

Renegade Ankle Holster

The low-profile Wilderness Renegade Ankle Holster is comfortable, secure, accessible and easy to put on or take off, even when seated in a vehicle. Available for many small and medium-sized autos and revolvers, it adds security and confidence to your daily life without taking it over. Built in Phoenix, Arizona with 40 years of experience and the best materials, the Renegade will provide years of service to keep you and your family safe.

MSRP: $69.95 and up

thewilderness.com

This article first appeared in Small Arms Review V25N7 (August-September 2021)

ATF’s Proposed Rulemaking Will Expand Scope of Federal Firearm Controls—Part II

As promised in Part I of this series (published in Small Arms Review Vol. 25, No. 6), we now take a look at the proposed revisions to the firearm marking requirements and the impact on privately made firearms. As you may recall, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) drafted the Notice of Proposed Rulemaking (NPRM) with two primary objectives. One is to update the term “frame or receiver” into a living definition capable of capturing modern firearms technology and changes in terminology. In Part I, we reviewed ATF’s proposed changes to the term “frame or receiver” that would move away from the rigid definition of specifying three specific fire control components (the hammer, bolt or breechblock, and firing mechanism) and replace it with language general enough to capture changes in technology.

In this article we will focus on ATF’s other objective, which is to revise the regulations to specify at what point an unregulated article becomes a “firearm” subject to the Gun Control Act of 1968 (“GCA”). As drafted, the NPRM would expand GCA controls to partially machined bodies and parts kits that have reached a certain stage they may “readily” be completed, assembled, converted, or restored to a functional state. The proposed rule adds that “partially complete” will mean a forging, casting, printing, extrusion, machined body, or similar article that has reached a stage in manufacture where it is clearly identifiable as an unfinished component part of a weapon.

As a quick refresher, the GCA defines “firearm” to mean (A) any weapon (including a starter gun) which will or is designed to or may readily be converted to expel a projectile by the action of an explosive; (B) the frame or receiver of any such weapon; (C) any firearm muffler or firearm silencer; or (D) any destructive device. Such term does not include an antique firearm. 18 U.S.C. § 922(a)(3) (emphasis added).

Pursuant to this statutory definition, a device is a controlled firearm if it is either designed to or can readily be converted into a device that expels a projectile by the action of an explosive, or it is a frame or receiver of such a device. However, neither the GCA nor the current regulations identify at what point an article becomes subject to the GCA controls. With this NPRM, ATF is attempting to remedy this, but a key question may be whether the proposed fixes exceed the scope of the statute.

“Readily”

The term “readily” is used in the GCA in several contexts, including interstate transportation of firearms at 18 U.S.C. 926A (allowing interstate transport of a firearm if it is unloaded and not readily accessible) and importability of firearms generally recognized as particularly suitable for or readily adaptable to sporting purposes (18 U.S.C. 925(d)(3)).

As we discussed above, the term is also in the definition of “firearm” and is the key qualifier by which the statute controls not just those weapons that function as firearms, or are designed to function as firearms, (expel a projectile by the action of an explosive) but also weapons which may be readily converted into a firearm. The statute, however, does not define “readily.”

As a result of the statute’s silence on the term, ATF’s current regulations also do not define “readily.” And this is becoming increasingly important. Determining when something becomes a firearm is at the heart of the GCA, it is the foundation upon which most controls are based. Because the concept of something being readily convertible into a firearm affects partially machined bodies and parts kits, just how ATF interprets “readily” is of critical importance and has been for some time.

For example, ATF is often asked whether a partially machined block of metal or plastic is a “blank” or a “firearm.” This is important because as soon as a that blank is a “firearm” it is subject to the GCA and that statute’s interstate controls over transfer and possession, the qualifications to engage in the business, and marking and recordkeeping requirements.

For manufacturers, identifying when something becomes a firearm impacts supply chains and how business is conducted with vendors. Important operational questions must be considered, such as whether the vendor needs a license from ATF to manufacture firearms, or whether a marking variance is needed. For importers, if that blank coming in is in fact a “firearm,” the GCA restrictions on firearm imports will apply.  

Also impacted by the concept of “readily” and ATF’s interpretation of the term is the market for so-called “80% receivers.” The term “80% receiver” (and similar language such as “80% finished,” “80% complete,” and “unfinished receiver”) is often used to identify an item some believe is not a controlled “firearm” under the GCA because it is only partially machined. However, none of these phrases are used in the statute or in ATF regulations, and ATF has not endorsed any of these terms. So, how ATF will interpret and apply “readily” will have a significant impact on this market that has exploded in recent years.

This brings us to the new definition of the term “readily,” which ATF proposes to add to its regulations at 27 C.F.R. § 478.11 and § 479.11. As proposed in the NPRM at 27747, the definition is as follows:

Readily: A process that is fairly or reasonably efficient, quick, and easy, but not necessarily the most efficient, speedy, or easy process. Factors relevant in making this determination, with no single one controlling, include the following:

• (a) Time, i.e., how long it takes to finish the process;
• (b) Ease, i.e., how difficult it is to do so;
• (c) Expertise, i.e., what knowledge and skills are required;
• (d) Equipment, i.e., what tools are required;
• (e) Availability, i.e., whether additional parts are required, and how easily they can be obtained;
• (f) Expense, i.e., how much it costs;
• (g) Scope, i.e., the extent to which the subject of the process must be changed to finish it; and
• (h) Feasibility, i.e., whether the process would damage or destroy the subject of the process, or cause it to malfunction.* * * * *

In addition to defining the term “readily,” ATF proposes to revise the existing definitions of “frame or receiver” and “firearm” by using “readily” to capture partially made, disassembled, or inoperable frames or receivers as well as parts kits that may be readily assembled, completed, converted or restored to expel a projectile by the action of an explosive.

Partially Complete, Disassembled, or Inoperable Frame or Receiver

As we’ve discussed, under the current regulations, there is little to no guidance on when an unregulated piece of metal or plastic becomes a controlled “firearm” under the GCA. According to ATF, “[c]larifying this issue is needed to deter the increased sale or distribution of unlicensed and unregulated partially complete or unassembled frames or receivers often sold within parts kits that can readily be completed or assembled to a functional state.” NPRM at 27729.

In the NPRM, ATF explains that its longstanding approach is to examine the degree of completeness in determining whether the item is a firearm subject to the GCA controls. Of course, this will vary depending on the model of the firearm, but the rule, ATF explains, is that an unregulated piece of metal, plastic, or other material becomes a regulated frame or receiver when it has “reached a critical stage of manufacture.” NPRM at 27729.

Understandably, there has been a lot of confusion and uncertainty in industry and elsewhere about where this critical line is drawn, and until now ATF has not published a standard to aid industry and the public, other than private classification rulings. So, with this NPRM, ATF aims to clarify when the “critical stage of manufacture” occurs making the article a regulated “frame or receiver.”

Recall from Part I of this series, ATF’s proposed revisions to the definition of “frame or receiver” include four “supplements” (labeled as paragraphs (a), (b), (c), and (d) within the definition). Each of these “supplements” is intended to further explain the meaning of the term for certain firearm designs and configurations. Supplement (c) was drafted for “partially complete, disassembled, or inoperable frame or receiver,” and explains that a controlled “frame or receiver” includes one that “has reached a stage in manufacture where it may readily be completed, assembled, converted, or restored to a functional state.”

To determine this status, “the Director may consider any available instructions, guides, templates, jigs, equipment, tools, or marketing materials.” The draft regulation goes on to state that the phrase “partially complete” as it modifies “frame or receiver” means “a forging, casting, printing, extrusion, machined body, or similar article that has reached a stage in manufacture where it is clearly identifiable as an unfinished component part of a weapon.” NPRM at 27746.

But this is not the only definition to contain “readily.” ATF also proposes revising the regulatory definition of “firearm” and broadening the scope of that term to include certain parts kits.

“Firearm”

Currently, the regulatory definition of “firearm” at 27 C.F.R. § 478.11 mirrors the statutory definition:

“Firearm. Any weapon, including a starter gun, which will or is designed to or may readily be converted to expel a projectile by the action of an explosive; the frame or receiver of any such weapon; any firearm muffler or firearm silencer; or any destructive device; but the term shall not include an antique firearm. In the case of a licensed collector, the term shall mean only curios and relics.”

In the NPRM, ATF proposes adding the following language at the end of the definition: “The term shall include a weapon parts kit that is designed to or may readily be assembled, completed, converted, or restored to expel a projectile by the action of an explosive. The term shall not include a weapon, including a weapon parts kit, in which each part defined as a frame or receiver of such weapon is destroyed.” NPRM at 27741 (emphasis added). Note that ATF’s fourth proposed supplement (supplement (d)) to the definition “frame or receiver” addresses what constitutes a “destroyed frame or receiver,” and this also incorporates “readily” (“the term ‘destroyed’ means permanently altered and “may not readily be assembled, completed, converted, or restored to a functional state.”). NPRM at 27746.

Readily and the NFA

In addition to all the impacts “readily” will bring under the GCA, the term will also be incorporated into the National Firearms Act (NFA) implementing regulations at 27 CFR Part 479. The term “frame or receiver” will also be updated in Part 479 to mirror that of Part 478. Under the NFA, the definition of “machinegun” includes any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger, as well as any “frame or receiver” of any such weapon.

As with the GCA, because of the concept of something being readily restored to be a machinegun under the NFA, how ATF interprets “readily” is of critical importance.

As the statutory definition of “firearm” necessarily remains unchanged without congressional action, ATF’s justification and reasoning for expanding the regulatory definition hinges on “readily” and the case law interpreting the terms “may readily be converted to expel a projectile” in 18 U.S.C. 921(a)(3)(A) and “can be readily restored to shoot” in 26 U.S.C. 5845(b). NPRM at 27730 and n. 58.

The Problem of Ghost Guns

The term “ghost guns,” or privately made firearms (‘‘PMFs’’) as the NPRM calls them, refers to the firearms unlicensed individuals make that are not serialized or marked with any identifying information, either from kits, 3D printers or other standalone parts. The NPRM addresses these firearms by revising the definition of “frame or receiver” (see above, primarily the supplement for partially complete, disassembled, or inoperable frame or receiver) and revising the regulatory definition of “firearm” to include a weapon parts kit that is designed to or may readily be assembled, completed, converted, or restored to expel a projectile by the action of an explosive.

A key part of the NPRM in addition to the definition changes is the prosed new marking requirements that would revise 27 C.F.R. § 478.92. Specifically, this rule proposes to amend § 478.92 to require FFLs acquiring PMFs to mark, or supervise the marking of, the same serial number on each frame or receiver (as defined in the proposed rule) of a weapon that begins with the FFL’s abbreviated license number (first three and last five digits) as a prefix followed by a hyphen on any ‘‘privately made firearm’’ (as defined) that the licensee acquired (e.g., ‘‘12345678–[number]’’).

The NPRM explains that “PMFs acquired by licensees on or after the effective date of the rule would need to be marked in this manner within seven days of receipt or other acquisition (including from a personal collection), or before the date of disposition (including to a personal collection), whichever is sooner. For PMFs acquired by licensees before the effective date of the rule, licensees would be required to mark or cause them to be marked by another licensee either within 60 days from that date, or before the date of final disposition (including to a personal collection), whichever is sooner. With respect to polymer firearms, including those that are produced using additive manufacturing (also known as ‘‘3D printing’’), the method of marking would typically require the licensee to embed (or use pre-existing) metal serial number plates within the plastic to ensure they cannot be worn away during normal use.” NPRM at 27732.

ATF argues that this is necessary to allow ATF to trace all firearms acquired and disposed of by licensees, prevent illicit firearms trafficking, and provide guidance to FFLs and the public with respect to PMF transactions with the licensed community. ATF goes on to cite as support for the need to mark PMFs the advances in technology that allow unlicensed persons easily to produce firearms at home from parts ordered online, or by using 3D printers or personally owned or leased equipment.

ATF does note that nothing in this rule would restrict persons not otherwise prohibited from possessing firearms from making their own firearms at home—without markings—solely for personal use (not for sale or distribution) in accordance with Federal, State, and local law. The new proposed marking requirements would only be triggered if the firearm was transferred to an FFL, for whatever reason. So, there will still remain a subset of PMFs that will go unmarked.

It is important to remember that this is a proposed rulemaking, and ATF will accept public comments through August 19, 2021. By the time the comment period closes, it is quite likely more than 100,000 will be submitted (as of the date of this writing (June 18, 2021), more than 61,000 comments have been submitted). In addition, ATF has another NPRM that was recently released addressing the factoring criteria for classifying pistols with stabilizing arm braces. I will address this other NPRM in my next article. While an agency is not required to finalize a proposed rulemaking, given the current administration and the prevailing political winds in Washington, I expect ATF will finalize both NPRMs in short order. As always, I will keep you posted.

The information contained in this article is for general informational and educational purposes only and is not intended to be construed or used as legal advice or as legal opinion. You should not rely or act on any information contained in this article without first seeking the advice of an attorney. Receipt of this article does not establish an attorney-client relationship.

ABOUT THE AUTHOR Johanna Reeves is the founding partner of the law firm Reeves & Dola, LLP in Washington, D.C. (reevesdola.com). For more than 17 years she has dedicated her practice to advising and representing U.S. companies on compliance matters arising under the federal firearms laws and U.S. export controls. Since 2016, Johanna has served as a member of the U.S. Department of State’s Defense Trade Advisory Group (DTAG). From 2011 through 2020, Johanna served as Executive Director for the Firearms and Ammunition Import/Export Roundtable (F.A.I.R.) Trade Group (http://fairtradegroup.org). Johanna can be reached at jreeves@reevesdola.com or 202-715-9941.

This article first appeared in Small Arms Review V25N7 (August-September 2021)

Knob Creek Machine Gun Shoot—The End of an Era

To say that we live in interesting times would be an understatement. Things do change and we all are faced with adapting to those changes.

Those lyrics (penned by The Buggles, if you are curious) were part of the very first music video that was broadcast by MTV on August 1, 1981. The words boldly stated what the music world already knew—things were changing. And boy, did they! Interestingly, it’s somewhat difficult to find a music video on MTV these days, but I digress.

By now you have heard the news that the Fall Shoot at Knob Creek (in Kentucky) will be the last shoot. The range is staying open, but the twice-yearly festival known as the Knob Creek Machine Gun Shoot is ending. After many decades of what many felt was a rite of passage, the end is in sight. To quote another band (The Talking Heads), “Well… how did [we] get here?”

It would be easy to say that we are all getting older, that the grind is getting too hard or that business is down. Sure, those are valid components. Knob Creek began as the destination for the so-called Class 3 world. Twice a year you could head to Kentucky … and overdose on all that is NFA. Lots of stuff to look at, lots of stuff to sell, to buy, to shoot. And the line was pretty much always a grand spectacle. You could see and be seen. You could start, augment or complete a collection. You could laugh with friends and get caught up. Whether it was hot or cold, raining or dry, snowing or muddy (sometimes all in one day)—you could get your machine gun on.

And then things started to change. Just like new modes and technology changed the vision of the radio star. The internet, forums and social media have changed the world of NFA. The old timers still value the up-close and personal way. But the old timers are not the majority of the community these days. If you want to shop for a transferable HK MP5, there are quite literally hundreds to choose from on the screen of your smart phone. If you want to learn how to take apart that MP5’s bolt assembly, head on over to YouTube for dozens of video lessons on how to do just that. Want to see all those wonderful machine guns going off? No need to brave the elements when there is an unlimited supply of entertainment that is just a few clicks away. For the Knob Creek vets, “pictures came and broke your heart.”

Is it a bad thing? Maybe not so much bad … rather, it is sad. Things change. Knob Creek changed. The world of NFA continues to change. The NFATCA is determined to ride the wave of that change and not get overwhelmed by it. We have a presence on Facebook, Instagram (the pictures!) and other venues. We still do shows, too. For almost 20 years we have aimed to represent the interests of the entire NFA community in ways that elevate everyone. To make more NFA opportunities available to more people, more often and more equitably. We have accomplished many great achievements. We know that there is more work to do, though. If you would like to assist us with the important work (that Robert Segel found so valuable), please consider joining or renewing today. nfatca.org | info@nfatca.org

This article first appeared in Small Arms Review V25N7 (August-September 2021)