Note: I am not a lawyer, and I have never been qualified to testify as a firearms expert. However, I'm better than average at reading and writing English and have studied the questions I discuss here extensively for my own purposes. This post is merely me sharing my findings as I understand them. This post is in no way legal advice. Do your own research and consult your own attorney if you care to before acting.
I've generally advocated a strict interpretation of 922(r) compliance when the question has come up in this thread. I've pretty much covered my opinions on that elsewhere. Here's the language, as I've sourced it, for those who haven't read it lately:
There are a couple other documents in the chain, but at the end of the day, the BATFE has decided that a semiautomatic shotgun with a magazine capacity (even tubular mag) of more than five rounds is not "particularly suitable for or readily adaptable to sporting purposes." Some may argue that, but we're stuck with it until Congress and the President do something about it.
All this matters, because I'd really like to add a couple rounds of capacity to the mag tube and maybe get a place to mount some Pic rail and/or a sling on a 1301T without performing an act that many people understand to violate the Federal law above.
The rest of this post is just nuts and bolts of it, as well as an option I recently discovered that I believe is the first commercially available solution to get the "parts count" to ten or lower, thereby allowing the legal installation of a mag extension.
The following table is my assessment of the Beretta 1301 Tactical's parts count versus the list that is relevant to 922(r). The columns are:
|
922(r) Parts List |
OEM |
A |
B |
ATF letter posted on P-F |
Note |
1 |
Frames, receivers, receiver castings, forgings or stampings |
1 |
1 |
1 |
1 |
|
2 |
Barrels |
1 |
1 |
1 |
1 |
|
3 |
Barrel extensions |
1 |
1 |
1 |
X |
a |
4 |
Mounting blocks (trunions) |
|
|
|
|
|
5 |
Muzzle attachments |
|
|
|
|
f |
6 |
Bolts |
1 |
1 |
1 |
1 |
|
7 |
Bolt carriers |
1 |
1 |
1 |
1 |
|
8 |
Operating rods |
|
|
|
|
e |
9 |
Gas pistons |
1 |
1 |
1 |
X |
b |
10 |
Trigger housings |
1 |
1 |
1 |
1 |
|
11 |
Triggers |
1 |
Briley |
1 |
1 |
|
12 |
Hammers |
1 |
Briley |
1 |
1 |
|
13 |
Sears |
|
|
|
|
c |
14 |
Disconnectors |
1 |
Briley |
1 |
1 |
d |
15 |
Buttstocks |
1 |
1 |
Aridus |
1 |
|
16 |
Pistol grips |
|
|
|
|
|
17 |
Forearms, handguards |
1 |
1 |
Aridus |
1 |
|
18 |
Magazine bodies |
1 |
1 |
1 |
1 |
|
19 |
Followers |
1 |
Nordic |
Nordic |
1 |
|
20 |
Floorplates |
|
|
|
|
|
|
Sum: |
14 |
10 |
11 |
12 |
|
(Sweet, that table thing worked...)
Notes:
- Stainless barrel extension is exactly analogous to the part called a "barrel extension" on an AR-15. Beretta exploded parts view shows it as a separate piece that is threaded on. It may be sold as a unit with the barrel, but AR-15 barrels are sold that way, too.
- It is inarguable that there is a gas piston in the gun. Beretta exploded parts view on Brownell's calls it that.
- The 1301 trigger is similar to the AR-15 trigger. The "sear" feature that hooks and releases the hammer is integral to the trigger, so cannot be counted as a separate part.
- There is a part that operates exactly as the "disconnector" in the AR-15 trigger system.
- Welded to bolt carrier, making them one part.
- Note that on the Comp and the new version Tactical launched at SHOT, unless the chokes are sourced from a US supplier, they will add a count on this line. Fortunately, it's not hard to replace them with US chokes, or add an Aridus Magpul buttstock conversion.
So even if you do the Aridus buttstock and Zhukov forend conversion, and add a Nordic follower, you won't get there. Maybe if there was a US-made copy of the magazine tube or something, but there's been no discussion I've seen of such a thing yet.
I've presumed the use of the Nordic follower because it's generally reported to work well and is affordable and readily available.
So, what's all this about Briley? A couple years ago, I hit up all the usual suspects for triggers and none of them indicated any interest in the 1301. Then, a few weeks back, someone in this thread mentioned the idea of sending their barrel to Briley to get it machined for chokes. I went to their web site to learn more, and realized they are about 20 minutes from my office in Houston. They have a match trigger for the A400. If you go to the linked page, you'll see one note all the way at the bottom that it also works with the 1301. All the parts are made here in Houston, Texas, USA. So that gets you down to 11. Add the Nordic follower or the Aridus/Magpul buttstock, and you're under the wire.
The trigger is adjustable, so it can be set up to match the original pull weight of the 1301T, in spite of being a "match" trigger. It's an all-or-nothing deal; all three parts are required for the system. You have to deliver your trigger group to them (ship it or drop it off if you're local). Turnaround is about two weeks. They fit the parts and test fire it, and they may even do a little bit of deburring on the sharp edges of the lifter. It's not inexpensive, but it's less than an hour of a really good lawyer's time.
http://www.briley.com/p-58887-berett...-triggers.aspx
Attachment 23790
(Grabbed Briley's image, but I figure this wholly positive discussion of it falls under "fair use.")
My trigger finger is under medical care at the moment, so I can't comment on performance or feel, but the parts do look nice. The trigger has the yellow-orange color of TiN, fairly close to the CAD rendering in the image above.
Have fun with your guns.