Archers Rifle 2.0 - Or Not (TIS291)

Interesting to think about, semiauto open bolt guns are considered readily convertible and hence machine guns. As a manually operated gun I'm not so sure, if you used an otherwise off the shelf bcg they could consider adding a gas system to be simple enough, if you welded up the gas key maybe not, I expect you would have to go to great lengths to ensure that bolt group could not drop into any other ar and function.