It's a violation of the Adminstrative Procedures Act under California law for an administrative agency like DOJ BoF to try to reinterpret the law without going through a formal rulemaking process.
Alison is out there trying to cause confusion around the term "capacity to accept a detachable magazine." Her argument is specious
OAL will review such things, and if the petition has merit, rule on them in a way that gets considerable deference from California Courts.
The funny part about all this is we gave Alison two weeks to write a clarifying letter or ask for more time and she ignored us. Here is that letter: http://www.hoffmang.com/firearms/oal...2009-02-06.pdf
Chairman, The Calguns Foundation
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"The problem with being a gun rights supporter is that the left hates guns and the right hates rights." -Anon