plr16 + sb15 = ?

So, what would happen if I took one of these


…replaced its existing pistol grip with one that could accept an AR-15 buffer tube


…inserted one of KAK’s pistol buffer tubes into it: 


… and then wrapped a Sig SB15 Arm Brace around it: 


My understanding of the BATFE compliance letter (IANAL and all that), the PLR-16 started out as a pistol, and neither attaching the AR-15 buffer tube nor the arm brace changed that, so one should still be in the clear.  Furthermore, “constructive intent” only seems to apply when you have no other purpose for the parts you have on-hand except violating the laws (IANAL again), so the fact that I happen to have a spare carbine buffer tube and stock is irrelevant on account of my still having the AR15 they came off of (they were replaced with a Magpul UBR). 

The question only comes up because my SB15 is winding its way towards me as we speak, as is one of KAK’s pistol buffer tubes, and I have been pricing out AR-type build options and prices once I have a steady stream of income again.  It appears that purchasing and kitting out a PLR-16 is marginally cheaper than using the bare, never-built AR-15 lower I have in my safe as a basis for an AR pistol, plus the PLR would not have the stupid-assed buffer tube hanging off its back end if/when the BATFE finally recants their approval of the SB15.  OTOH, it is a Kel-Tec, which can open up a whole ‘nother can of worms in and of itself. 

Anywise, just idle speculation. 

12 thoughts on “plr16 + sb15 = ?”

  1. Constructive intent will bite you if you can mount the stock on the PLR without tools – since the AR already has a stock installed, having a spare stock is a problem IF you have a pistol or AOW that also fits it. Now, if the “orphan” stock isn’t at the same location (store at another address), you had a virgin or rifle receiver that it could be fitted to, or you would need tools to install it on the PLR *as configured*, you’re golden.

  2. I am a great fan of SU16 and would like PLR16 as much if there was some way to stabilize it.

  3. @ Geodkyt: Hm. So my understanding of constructive intent basically boiled down to “you are in trouble iff you have no other legal use for the spare item(s)”. Basically, if you have a Charger, and a 10/22 stock, but no 10/22, you are hosed. But if you have a Charger, a 10/22, and a spare 10/22 stock, you are good to go.

    This is a great case for the topic, though the BATFE likes to make it clear that it only applies to TC rifles.

    In reality, it boils down to whatever the BATFE decides they want to prosecute you with, and I may just end up getting rid of the spare stock regardless.

    @ Oleg Volk: Well, it seems like this set-up might accomplish that, all without the cumbersome tax stamp… For now, at least.

  4. It seems to me that since the Buffer Tube needs to be attached with the Castle Nut, and that take a “Special Tool”, not to mention the Punches needed to move the roll pins, I think the “Tools Rule” should be covered. Plus, by adding the Tube and the SB15, aren’t you actually INCREASING the OAL of the Firearm, thus DECREASING its Concealability? Which sounds like a Plus in your favor.

    Hypothetically, I’d like to see how such a Firearm turns out in the Real World. But since it’s based on a Kel-Tec, well….

  5. I think the key to the issue is whether or not the tube is functionally necessary to the operation of the firearm:

    On the AR15, the buffer tube contains the recoiling bolt, along with the bolt buffer and action spring. Universally, regardless of configuration, every AR15 has some manner of buffer tube.

    Since AR pistols still need the buffer tube to be functional firearms, BATFE recognizes that it is not *designed* to be a stock… The Sig brace in turn is *designed* to mount to that tube, and strap to one’s wrist.

    That being said, attaching an AR15 buffer tube to the back of that Kel Tec pistol serves absolutely no functional purpose with regard to the operation of the pistol; It seems likely to me that such an installation would be ruled to be construction of an SBR, especially when combined with a Sig brace….

    Disclaimer: I’m not trying to be a wet blanket here, but all the talk I’ve seen recently surrounding the use of the Sig arm brace as a way to skirt the line between Title I/Title II firearms doesn’t sit well with me. I certainly don’t have any *moral* objections; Mine are more pragmatic: What happens when the media catches wind of this “loophole”? What happens when the BATFE reverses their prior letter on the subject? On the whole, I have a large degree of difficulty seeing the good in such a situation.

  6. @ Bubblehead Les: Amusingly, the PLR16 is one of the few KelTec things you can actually find for sale on GunBroker.

    @ HSR47: So I understand the rationale, but then there is this, which was being sold without a tax stamp or anything of the sort.

    In fact, I think, but do not quote me on this, that Sig used their P556 as the mule for asking the BATFE whether or not this was a legal thing to do for us little people who do not want to pay tax stamps.

    I am, obviously, all for using the SB15 for whatever interesting purposes people like, precisely because eventually someone will notice. This gives us a golden opportunity to literally point out how capricious and idiotic the BATFE is, in that they are permitting the use of a stock-like-but-not-really-stock item as a stock, but will not allow us to use actual stocks as stocks. Then, if/when the BATFE does change its mind, they are going to try banning/regulating an ADA-compliant device, which is just going to be hilarious in and of itself.

  7. @ Linoge:

    I certainly understand where you’re coming from, but:

    *This is the government we’re talking about, and these things don’t have to make sense.

    *BATFE opinion letters are typically extremely limited in scope. I’m lazy, and I haven’t actually read the one regarding use of the Sig brace as a “stock” on a Title I pistol, but I wouldn’t count on that letter applying to the use of the brace as a stock on the Kel-Tec pistol you reference. Refer to the point above this one, and also remember that the BATFE likes to use the letter writing process as a way to make “rules” without following the process for creating actual administrative rules (read: making decisions that they can enforce as rules without a public comment period, and that they can later rescind with no warning).

  8. So the relevant parts of the letter are:

    Thus configured, the device provides the shooter with additional support of a firearm while it is still held and operated with one hand. We find that the device is not designed or intended to fire a weapon from the shoulder.

    Based on our evaluation, FTB finds that the submitted forearm brace, when attached to a firearm, does not convert that weapon to be fired from the shoulder and would not alter the classification of a pistol or other firearm.

    Since the PLR16 started out as a pistol, nothing should change by attaching the SB15, and since attaching the SB15 necessitates the inclusion of a buffer tube… yeah.

    But, as you say, the BATFE is notorious about not making sense, and likewise about capriciously changing their minds when they realize how much of an ass they have made of themselves. I will probably stick with an AR build, but it is still an interesting question.

  9. Then there’s the same brace for the AK pistol, another pistol that does not need/have a buffer tube like object in back to function. In fact the pistol brace comes with hardware needed to mount it back there since there is nothing else. Wouldn’t the PLR16 fall into the same category?

  10. @ snoopycomputer: Oh, good call, I had forgotten about that. Given that, it seems the PLR would be as safe as anything until the BATFE changes its mind…

    @ Weer’d Beard: Eh. .300 BLK does nothing for me, especially since it’s (a) another caliber I would have to keep track of, and (2) more or less requires a suppressor for full utility. I have done the tax stamp tango once before, and have no real desire to repeat it.

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