No one is saying that one should drop the mag on declaration and receiving registration.
We are just saying this is eminently challengeable on multiple fronts and it is and will be challenged - first informally, "Hey guys, you gotta be kidding - here's what we're gonna do if you go thru with this" then formally, seeking injunctive relief.
In addition, the exact wording of the memo would make it appear that one has to dismantle the rifle, as it confuses features listed 12276.1 with 12276.1 features used in combination w/semiauto rifle w/detachable magazine.
As of now, this is just a memo, and a mere statement of possible intent, a "trial balloon".
It could well be created just in an attempt to thwart people from buying more lowers. I think 8000+ Stoner-style lowers have made it into CA now.
You should not let this memo dissuade you from buying off-list lowers, either: the upside is just too great.
Bill Wiese
San Jose