http://classicarms.us/ has Saiga 12's in stock currently for anyone who may care...
That is correct, so far. The larger question is -- since they surely must have realized that long before they put all the effort into this 'study' -- are they angling for something more sweeping with this, (like Zoogster suggested in Post 58) like a declaration that these guns are importable and "sporting" but any that are converted to the traditional AK pattern must be registered as Title II Destructive Devices.
8. excessive weight (greater than 10 pounds for 12 gauge or smaller);
Over at Saiga12.com we've one Importer that very recently had a FORM 6 returned as DISAPPROVED for the above reason, i.e. side rail scope mount = integrated rail system.Non-sporting features:
"Following this review, the working
group determined that certain shotgun features are not particularly suitable or readily adaptable
for sporting purposes. These features include:
(1) Folding, telescoping, or collapsible stocks;
(2) bayonet lugs;
(3) flash suppressors;
(4) magazines over 5 rounds, or a drum magazine;
(5) grenade-launcher mounts;
(6) integrated rail systems (other than on top of the receiver or barrel);
(7) light enhancing devices;
(8) excessive weight (greater than 10 pounds for 12 gauge or smaller);
(9) excessive bulk (greater than 3 inches in width and/or greater than 4 inches in depth);
(10) forward pistol grips or other protruding parts designed or used for gripping the
shotgun with the shooter’s extended hand."
Current factory S-12's _may_ have #6 if you count scope rail as such.
Given the feedback on #6, it may be a stretch but I'm still reading it literally where it states "other than on top of the receiver" whereas S-12 scope rail is on the side of the receiver. Also the document specifically illustrates an example of a drum magazine being MD Arms items for S-12, it may be just to show that you can't import S-12 with a magazine over 5 rounds but it's rather strange to point this out unless they are being pro-active to head any potential magazine importation.
Excerpts:
"(6) Integrated Rail Systems.42
This refers to a mounting rail system for small arms upon which firearm accessories and features
may be attached. This includes scopes, sights, and other features, but may also include
accessories or features with no sporting purpose, including flashlights, foregrips, and bipods.
Rails on the sides and underside of shotguns—including any accessory mount—facilitate
installation of certain features lacking any sporting purpose. However, receiver rails that are
installed on the top of the receiver and barrel are readily adaptable to sporting purposes because
this facilitates installation of optical or other sights."
Note that "Rails on the sides and underside of shotguns—including any accessory mount—facilitate
installation of certain features lacking any sporting purpose...However, receiver rails that are
installed on the top of the receiver and barrel are readily adaptable to sporting purposes"