Having gone through the whole process, I can tell you that manufacturing a firearm for personal use, no matter what the firearm is made from, is considered acquiring a firearm.
A 12" Chromium-Molybdium steel rod is just as much of a firearm as is a 4"×9"x2" block of aluminum. They fall into the same category as the 80%, not a firearm. I call them raw materials.
When the firearm is manufactured, it is by definition, a firearm, not "something-or-other" or "legal jargon excepting it from what it really is" but a firearm. Make no mistake, a felon in posession of a firearm manufactured by a non-manufacturer is indeed a felon in posession of a firearm.
Loking at the argument that manufacturing a firearm does not constitute acquisition of a firearm because raw materials were originally acquired, how then did the non-manufacturer procure the firearm?
No matter what the firearm was manufactured from, the end result is it becomes a firearm. The non-manufacturer did not have a firearm originally, but raw material. Somewhere in this process, the non-manufacturer must procure a firearm.
While one may argue that posession through manufacturing is not considerd acquiring because there was no transfer, to manufacture a firearm requires real intent. It would be near impossible to argue manufacture by accident or impulse, especially with an 80%.
With the intent that the final product of the raw material is a firearm, the non-manufacturer will be procuring in the State a firearm in a manner other than by purchase, gift, inheritance, or bequest.
You're not understanding what I said.
The word "acquire" has the meaning of "to gain ownership of [something]" You are not acquiring ownership of a firearm. If you were, then ATF rules would apply.
You are manufacturing a firearm from things you already own [ <== key word]. How can you acquire ownership of a firearm unless it was owned by someone else prior to milling it? It's basic logic. "To acquire" requires a transaction. You even listed a bunch of examples: "purchase, gift, inheritance, or bequest." Those are transactions that involve transferring ownership.
You don't "acquire ownership" in and of itself. Ownership is not a thing. You acquire ownership of a firearm. Therefore, the entire thing rests on whether it was a firearm when you first acquired ownership of the blank.
Requiring a permit to acquire is just a workaround by HPD to force a background check for anyone completing an 80% lower. Period. It's not required by the letter of the law.
To answer the question of "how did the non-manufacturer procure the firearm," the answer is in the ATF rules: an unlicensed person can manufacture a firearm with no restrictions as long as the person is not prohibited from possessing a firearm under the GCA. He procured the blank, and milled it into a firearm. The material was owned already. There was no procurement of the firearm -- it was made, milled, assembled, created, produced, but not acquired.
It's Hawaii police that want to apply "acquisition/procurement" rules to a manufactured firearm for personal use, not the ATF.
Intent is irrelevant. Federal law specifies you can manufacture a firearm with no restrictions, without serial numbers, background checks, etc. Period.