DOJ Issues Emergency Regs and CRPA Needs Your Comments

December 13, 2023

CRPA and GOC are working hard on a formal response to a Friday release from the Department of Justice announcing emergency regulations regarding SB 2 and California’s attempts at making the CCW process more arduous.

As you know, CRPA and GOC have already challenged several of the provisions on the “sensitive places” issues within SB 2 that was passed last year. Once the other provisions on issuing CCWs (provisions that these emergency regulations cover) go into effect in January 2024, you can bet there will be more litigation against these unconstitutional laws.

These new proposed emergency regulations strictly limit which instructors can provide CCW training in a system that already has a heavy load of too many students and not enough classes. This move seems like a move to limit and slow the processing of CCWs in the state, which is problematic given that CCW applications have increased significantly since the Bruen decision. Under the emergency regulations, the only groups or individuals who can provide CCW training are:

1) Bureau of Security and Investigative Services, Department of Consumer Affairs, State of California-Firearm Training Instructor;

(2) Commission on Peace Officer Standards and Training (POST), State of California Firearms Instructor or Rangemaster; or

(3) Authorization from a State of California accredited school to teach a firearm training course.

Because of the state’s underhanded attempts to slow or stop the issuance of CCWs to law-abiding citizens, we need your help submitting comments by the deadline.

Please click here to submit comments by the deadline.

Make sure to follow the instructions to make sure your comments are heard and speak out in opposition to the emergency regs.The Department plans to file the emergency rulemaking package with OAL at least five working days from the date provided at the top of this notice. If you would like to comment on the Finding of Emergency or the proposed text, those comments must be made in writing only, must contain a notation that identifies the emergency regulation to which they relate, and must be received by both the Department and OAL within five calendar days of the Department’s filing with OAL. The Department may respond to comments at its discretion.

Because of the timing, CRPA is encouraging all to submit comments of opposition immediately.

Send comments simultaneously to:

Quentin Farris
Department of Justice
P.O. Box 160487
Sacramento, CA 95816
(916) 210-2377


Office of Administrative Law
300 Capitol Mall, Suite 1250

The proposed text of the emergency regulation and the Findings of Emergency are posted on the department’s website at https://oag.ca.gov/regulations.

This date for comments is subject to change, depending on when DOJ  actually submits the proposed emergency regulatory action to OAL. The public may monitor the OAL website to determine the precise date OAL receives the emergency regulations.