CRPA and NRA File Joint-Opposition Letter Against Proposed California Regulations Regarding Magazines Capable of Holding More Than 10 Rounds (“Large-Capacity Magazines”)

On Wednesday, December 28, the CRPA and NRA submitted a joint-opposition letter to the California Department of Justice and the Office of Administrative Law opposing the proposed “emergency” regulations relating to magazines capable of holding more than 10 rounds (so-called “large-capacity magazines”) and “large capacity magazine conversion kits.” If enacted, the regulations would: change the requirements for obtaining and maintaining a “large-capacity magazine permit;” add new regulations addressing “large capacity magazine conversion kits;” add new regulations on how individuals must “permanently alter” a magazine to accept no more than 10 rounds; and add new regulations concerning multi-tube shotguns.

The letter highlights why the Office of Administrative Law, the California agency tasked with overseeing the rule making process, should reject DOJ’s proposed emergency regulations. For one, the laws covering so-called “large-capacity magazines” in California have been around for 17 years without DOJ feeling it necessary to provide clarification of the law’s terms. Even so, DOJ failed to present any evidence that an emergency exists to implement these regulations immediately. Thus, DOJ should be forced to follow the typical rule making process that would allow ample time for public participation and comment. What’s more, there is no immediate need to clarify either the existing law or the new restriction on the possession of “large-capacity magazines” set to take effect on July 1, 2017.

As was previously reported, these regulations were thrust upon unsuspecting California gun owners just days before the holidays under California’s “emergency” rule making process, limiting the time frame for public participation to just 5 days. To assist gun owners and other law-abiding citizens, NRA and CRPA’s team of attorneys crafted a detailed analysis of their potential impact and why they should be opposed.

Following the close of the public comment period today, DOJ has the option to file a rebuttal to any of the comments made by the public. DOJ may file this rebuttal on or before December 31. This includes rebutting the arguments raised in NRA and CRPA’s joint-opposition letter. The Office of Administrative Law will make a final decision on the proposal no later than January 2, 2017. If OAL approves the regulations, the regulations will be sent to the California Secretary of State and will become law for a limited time until the permanent regulations are proposed and adopted. If OAL rejects the emergency regulations, we expect DOJ to resubmit the regulations for consideration through the standard rule making process. Information concerning the regulatory rule making process may be found at OAL’s website:

Regardless of the outcome we will keep you informed as to the status of these and any other regulations DOJ may be rolling out over the next couple of months.
Keep up to date on any future developments by subscribing to CRPA alerts here.

2 responses to “CRPA and NRA File Joint-Opposition Letter Against Proposed California Regulations Regarding Magazines Capable of Holding More Than 10 Rounds (“Large-Capacity Magazines”)

  1. Just another gun/magazine grab by the liberal/socialists in Sacramento. These laws do not protect the law abiding public. The “bad guys” will still do what they have to do to get what they want and no law/laws will stop them. You are intentional making the law abide gun owner a Kalifornia Felon.

    Bob Caughey
    Retired w/28 years of honorable service as a federal law enforcement supervising special agent with the US SECRET SERVICE

  2. I agree with Bob Caughey’s opinion entirely! Making high capacity magazines illegal in order to “save lives” and stop gun violence is like changing the air in your tires when your car battery goes dead. How stupid is that?!! Like 10 rounds will kill you any less dead than 30…..
    How can the state pass laws that will make so many life-long law abiding people instant criminals?

Leave a Reply

Your email address will not be published. Required fields are marked *