The DOJ is tyring to confuse things but this is pretty simple legal interpretation.
Ultimately all magazines are "detachable" from the weapon (and I have the tools to prove it)
SO under the existing law and regulations,
When looking at the same two weapons with the same qualifying evil features:
if the weapon is configured so that magazine is detachable WITHOUT TOOLS its an AW
if the weapon is configured so that magazine is detachable only WITH TOOLS its NOT an AW
Am I missing something?