AOW Shotgun

[Capybara]

Updating this thread. I submitted my Form 1 to convert my AR pistol into an AOW on April 7th, 2025. Have not heard anything in 8 months. Then today, New Years Eve, they finally responded with, "Returned without action. Due to statutory changes in the making/transfer tax and forms effective January 1, this application could not be approved. Refund has been requested (if applicable). New form can be submitted with all required information and attachments as of January 1.

So I guess I have to go through the hassle and expense of getting re-fingerprinted as the encoded fingerprint file I submitted I believe expires or is taken off of the fingerprint company's servers. Ridiculous that I had to wait eight months to hear that they are refunding my $200 and I have to re-submit, I don't know why they stopped approvals before the new ruling went into effect. Sigh. Wonder how long it will take them this time?

*Update 01/05/2026
I discovered that the fingerprint files I had didn't expire so I was able to re-apply the E Form 1 to manufacture my AR pistol into an AOW. Once you go through the process, it is much faster from memory than it was doing it last year and they do have the form defaults now to a $0 charge. Beware if you submit an E Form 1 to make an AOW because of the Gold Rush of people doing silencers in America, the ATF's E Form server is massively overloaded. The first day I tried to submit my form about 40 times with no luck, You can save the draft so I tried again yesterday and it accepted my application after only 11 tries. I checked a bunch of Reddit boards about E Form submissions and some people had to try to submit over 100 times. Because ATF is absolutely flooded with E Forms, for SBS/SBRs and silencers, I anticipate a long wait but I'll report back when I hear something. I already wasted 8 months waiting last year for them to return without action so what's a few more months?

For those in America, you still have to pay the illegal and Unconstitutional $200 tax on transferring machine guns and destructive devices. But Silencers, SBS/SBRs and AOWs are all free now.

[Silence Dogood]

. . .
Examples of Title 2 AOW...
A handgun with a smoothbore barrel.
A handgun with a vertical forward grip.
A firearm, that is not a handgun, that does not have a shoulder stock and has a less than 16" barrel length and less than 26" overall length.

On firearms with a folding pistol brace, is the OAL measured in the shortest or longest configuration, per federal law?

[Capybara]

On firearms with a folding pistol brace, is the OAL measured in the shortest or longest configuration, per federal law?

A folding brace is considered an accessory and not part of the firearm so OAL is not including the brace is what I came up with after hours of research. Because the ATF hands down opinions like toilet paper, constantly updating and changing their mind, it's a maze of superseded
previous rulings so therefore, very confusing to determine things like this. I researched all of this last year so I deleted the bookmarks after I submitted my E Form 1.

[Silence Dogood]

A folding brace is considered an accessory and not part of the firearm so OAL is not including the brace is what I came up with after hours of research. Because the ATF hands down opinions like toilet paper, constantly updating and changing their mind, it's a maze of superseded
previous rulings so therefore, very confusing to determine things like this. I researched all of this last year so I deleted the bookmarks after I submitted my E Form 1.

I framed the question as I did because my bookmarks from before the server migration don’t work and I vaguely I recall that CA uses a different metric than ATF, probably to suit control laws (i.e. telescoping stocks). Again, purely from vague recollection but, I was thinking OAL per feds was shortest and per CA was in the longest configuration. As you stated, it’s a maze.

[Capybara]

I framed the question as I did because my bookmarks from before the server migration don’t work and I vaguely I recall that CA uses a different metric than ATF, probably to suit control laws (i.e. telescoping stocks). Again, purely from vague recollection but, I was thinking OAL per feds was shortest and per CA was in the longest configuration. As you stated, it’s a maze.

I don't think CADOJ acknowledges that braces exist as an accessory, they like to classify them as stocks so they can bust us for having an SBR. Seems like two separate issues, OAL and whether CADOJ equates having one as a stock? What is your concern with OAL?
We do know that having the gun as an AOW exempts it from Commifornia's SBR laws legally, but a lot of law enforcement will just arrest you for it even though its legal because it looks like an SBR.

And yes, massively confusing trying to figure out Federal law and how that intersects with California law.

[Capybara]

Re-submitted E Form 1 to convert my AR pistol into an AOW on January 3. Received E Form back disapproved on January 20th.

Reason for disapproval listed as: State Law

This a obviously incorrect, there is no PC that forbids AOWs, I have two more AOWs already here in Commifornia. I can re-submit and hope that I get a smarter
examiner that knows Commifornia laws or I can appeal to the ATF Office of Chief Counsel Litigation Division, which takes up to six months. I have read some Reddit reports
of Californians having to submit 4-5 times to finally get approved. Now that it's $0 to do so, that is likely what I will do.

[monkey]

I also had my eForm 1 denied today for a 870 AOW due to “State law”. Wondering if there’s a way to discuss with examiner or provide the relevant CA code?

Very frustrating.

[Capybara]

I also had my eForm 1 denied today for a 870 AOW due to “State law”. Wondering if there’s a way to discuss with examiner or provide the relevant CA code?

Very frustrating.

Based upon my research, no. You can re-submit, plan on up to half a dozen times possibly in the hopes of getting your paperwork reviewed by a more educated examiner or you can appeal it to the ATF Office of Chief Counsel Litigation Division, which takes up to six months.
Since my turnaround was only about two weeks on getting the rejection, logically makes sense to re-file even multiple times. I own two AOWs in Commifornia so their assertion that State Law precludes this is ignorant, and is demonstrably false, but yes, it would be great if we could simply have an email or phone conversation with the
uninformed examiner. Like all things with a Dinosaur-like, outdated and uninformed bureaucracy, you have to stand in line and deal with stupid people who have power over you.

[Silence Dogood]

I don't think CADOJ acknowledges that braces exist as an accessory, they like to classify them as stocks so they can bust us for having an SBR. Seems like two separate issues, OAL and whether CADOJ equates having one as a stock? What is your concern with OAL?
We do know that having the gun as an AOW exempts it from Commifornia's SBR laws legally, but a lot of law enforcement will just arrest you for it even though its legal because it looks like an SBR.

And yes, massively confusing trying to figure out Federal law and how that intersects with California law.

I’ve recently been toying with the idea of getting a FFL07 and producing a firearm that could be configured in multiple forms per the applicable laws.

[Silence Dogood]

I also had my eForm 1 denied today for a 870 AOW due to “State law”. Wondering if there’s a way to discuss with examiner or provide the relevant CA code?

Very frustrating.

Based upon my research, no. You can re-submit, plan on up to half a dozen times possibly in the hopes of getting your paperwork reviewed by a more educated examiner or you can appeal it to the ATF Office of Chief Counsel Litigation Division, which takes up to six months.
Since my turnaround was only about two weeks on getting the rejection, logically makes sense to re-file even multiple times. I own two AOWs in Commifornia so their assertion that State Law precludes this is ignorant, and is demonstrably false, but yes, it would be great if we could simply have an email or phone conversation with the
uninformed examiner. Like all things with a Dinosaur-like, outdated and uninformed bureaucracy, you have to stand in line and deal with stupid people who have power over you.

Separately, I have also been following this thread due to my desire to file a form 1 on a pistol lower I purchased. I’ve yet to acquire an upper but I want a folding pistol brace with the <16” upper so AOW is the avenue ahead of me.

Question to both of you: with the rush of applications due to the BBB & resultant $0.00 tax, (considering the high rate of return) I would expect the bureau to have put a bunch of new people—if not an algorithm—on the processing duties. Given the nature is CA’s “interpretation” of the 2A, it might be prudent for one of you to send your application to the ATF Office of Chief Counsel Litigation Division for all or our sakes. And it DOGE has truly made its way through the executive branch, it may no longer take six months to receive a just reply. ¯\_(ツ)_/¯ That’s the optimist in me talking.

Thanks for your postings here and attempts on behalf of all of us.

[monkey]

I actually resubmitted mine yesterday and included a cover letter politely pointing them CA PC 12020 (b)(8). We’ll see if any difference is made….

[Capybara]

I can find PC17710 listed on the California website that reads, "17710 (a) The provisions listed in Section 16590 do not apply to “any other weapon” as defined in subsection (e) of Section 5845 of Title 26 of the United States Code, which is in the possession of a person permitted to possess the weapons under the federal Gun Control Act of 1968 (Public Law 90-618), as amended, and the regulations issued pursuant thereto."

The PC12020 (b)(8) reads, "(8) Any other weapon as defined in subsection (e) of Section 5845 of Title 26 of the United States Code and which is in the possession of a person permitted to possess the weapons pursuant to the federal Gun Control Act of 1968 (Public Law 90-618), as amended, and the regulations issued pursuant thereto. Any person prohibited by Section 12021, 12021.1, or 12101 of this code or Section 8100 or 8103 of the Welfare and Institutions Code from possessing these weapons who obtains title to these weapons by bequest or intestate succession may retain title for not more than one year, but actual possession of these weapons at any time is punishable pursuant to Section 12021, 12021.1, or 12101 of this code or Section 8100 or 8103 of the Welfare and Institutions Code. Within the year, the person shall transfer title to the weapons by sale, gift, or other disposition. Any person who violates this paragraph is in violation of subdivision (a). The exemption provided in this subdivision does not apply to pen guns."

So we have at least two or three different PCs that imply AOWs are legal. I wonder if PC12020 is an updated re-listing/number change of PC 17710 since they kind of say the same thing? PC 170710 was effective as of Jan 1, 2012. Weird that I can only find a listing of PC 12020 on the ABC (Alcoholic Board of Control) website? I cannot find it on the California Legislative website after a direct search?

Probably won't do any good, I think it's up to whichever examiner you get. Reno May has filed for two AOWs, one AR pistol based and one shotgun based in the last year and received both so we know it is possible and I own two AOWs so I know it is possible. We are just getting an uninformed examiner.

[W.R.Buchanan]

I do realize that there is interest in this type of weapon. However I personally see no "Practical Use" for a weapon like this. Plus looking at the Political BS associated with acquiring a gun like this makes it a non Starter for me Personally,

My first question to a person showing interest is to ask them "Have you ever Fired a Weapon like this?" To say it is an "Eyeopener" is a gross understatement.

I have, and even with some significant Shotgun Training I couldn't control the thing. (with Birdshot) It is something that if you intended to use it for Home Defense (which is the only use I can see for the gun) would require a few hundred rounds to get the hang of so you might be able to hit something with it when the chips were down. It is hard enough to hit any target inside of 10 yards with a Regular Shotgun fired from the hip without regular practice. Also there is a BIG Difference firing one with High Base Buckshot as opposed to #8 Birdshot?

I want a buttstock on the gun so I can fire it from the shoulder, or tucked under my Arm. And I want Open Sights or a Red Dot or Laser to facilitate directing the weapon to a given target accurately.

At that point the length of the barrel becomes insignificant other than the fact that the Mag Tube becomes shorter and thus less rounds on the gun. But the fact that a SBS becomes more useful as an HD weapon due to it's length and Increased Mobility indoors, makes it way ahead of a Gun with a Pistol Grip or one of those "Other Grips." It is simply "More Controllable!!!"

I could easily cut 3 " off my 18" bbl. and shorten my HD gun. But I fail to see how losing 3" off an 18" bbl. will benefit me in any way?

Which gets me back to" Why" in the first place.

I realize that the topic of this thread is dealing with CA BS, but I felt compelled to insert my .02 into the conversation in the hopes that It would save someone the headaches of dealing with this FU States Hierarchy . Hopefully this will change in the future, but unless we get the voting laws fixed I'm not holding my breath.

Here's a pIc of my HD gun with a Streamlight with Laser in it. This is what you get a taste of if you came visiting after dark.

Randy
100465115.jpg

[Capybara]

As an AOW owner, I agree, nearly useless, I only bought mine because I could, one of the new NFA weapons one can own in Commifornia. It is interesting that one can add a brace, even a folding brace to an AOW though and an AOW is immune from Commifornia's SBS and SBR regulations.
A brace isn't as good as a stock but it's a lot better than PGO. Of course, in many areas of Commifornia, law enforcement will seize an AOW with a brace, and arrest the owner, thinking it's an illegal SBS or SBR, when legally, it's not.