BILL ANALYSIS                                                                                                                                                                                                    







                          SENATE COMMITTEE ON Public Safety
                             Senator Bruce McPherson, Chair     A
                                2003-2004 Regular Session       B

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          AB 161 (Steinberg)                                    
          As Amended June 30, 2003 
          Hearing date:  July 8, 2003
          Penal Code
          SH:mc

                       DEALERS RECORD OF SALE SPECIAL ACCOUNT  -  
                             EXPANDING AUTHORIZED USE  -  
            APPROPRIATION TO FUND FIREARMS TRAFFICKING PREVENTION ACT OF  
                                        2002
                                          
                                       HISTORY

          Source:  Department of Justice

          Prior Legislation: AB 2080 (Steinberg) - Chapter 909, Statutes  
          of 2002
                            SB 670 (Lewis) - Chapter 901, Statutes of 1995
               
          Support: Women Against Gun Violence; Legal Community Against  
          Violence

          Opposition:NRA; California Rifle and Pistol Association 

          Assembly Floor Vote:  No longer relevant

                                           
                                     KEY ISSUES
           
          SHOULD THE EXISTING SPECIFIC LIMITATIONS ON THE USE OF THE FUNDS  
          IN THE DEALERS' RECORD OF SALE SPECIAL ACCOUNT OF THE GENERAL  
          FUND BE EXPANDED BY ADDING USE BY THE DEPARTMENT OF JUSTICE "FOR  
          THE COSTS ASSOCIATED WITH FUNDING DEPARTMENT OF JUSTICE  




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          FIREARMS-RELATED REGULATORY AND ENFORCEMENT ACTIVITIES RELATED  
          TO THE SALE, PURCHASE, LOAN, OR TRANSFER OF FIREARMS PURSUANT  
          TO" CHAPTER 1 OF THE DANGEROUS WEAPONS CONTROL LAW?

                                                                (CONTINUED)



          SHOULD $548,000 BE APPROPRIATED FROM THE DEALERS' RECORD OF SALE  
          SPECIAL ACCOUNT TO THE DEPARTMENT OF JUSTICE TO IMPLEMENT THE  
          FIREARMS TRAFFICKING PREVENTION ACT OF 2002?

          SHOULD RELATED CHANGES IN LAW BE MADE?



                                       PURPOSE
          
          The purpose of this bill is (1) to expand the existing specific  
          limitations on the use of the funds in the Dealers' Record of  
          Sale Special Account of the General Fund by adding use by the  
          Department of Justice "for the costs associated with funding  
          Department of Justice firearms-related regulatory and  
          enforcement activities related to the sale, purchase, loan, or  
          transfer of firearms pursuant to" Chapter 1 of the Dangerous  
          Weapons Control Law; (2) to appropriate $548,000 from the  
          Dealers' Record of Sale Special Account to the Department of  
          Justice to implement the Firearms Trafficking Prevention Act of  
          2002; and (3) to make related changes in law. 
          
           Existing law  does the following:

           Requires all sales, loans, and transfers of firearms -  
            including private party transfers - to be processed through or  
            by a state-licensed firearms dealer or a local law enforcement  
            agency.  (Penal Code  12072(d).)

           Provides that there is a 10-day waiting period when purchasing  
            a firearm - or effecting a private party transfer - through a  
            firearm dealer, during which time a background check is  




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            conducted - and a handgun safety certificate is required for  
            handguns - prior to delivery of the firearm.  The licensed  
            deal shall submit purchaser information to the Department of  
            Justice (DOJ), as prescribed, to enable the DOJ to complete  
            background checks.  (Penal Code  12071, 12072, and 12076.) 

           Requires that the Department of Justice determine whether  
            the purchaser or transferee is among a specified category of  
            persons who are prohibited to possess firearms; the  
            department is required to immediately notify the dealer and  
            local law enforcement upon ascertaining that fact.  In  
            addition, the department is authorized to charge the dealer  
            a fee sufficient to reimburse specified costs, including,  
            but not limited to, the costs of furnishing this  
            information.  (Penal Code  12076.)

           The Dealers Record of Sale (DROS) fee is charged by the  
            Department of Justice to dealers; the dealers in turn charge  
            that fee to purchasers.

           Provides that the Department of Justice may require the dealer  
            to charge each firearm purchaser a fee not to exceed $14,  
            except that the fee may be increased at a rate not to exceed  
            any increase in the California Consumer Price Index as  
            compiled and reported by the California Department of  
            Industrial Relations.  The fee shall be no more than is  
            sufficient to reimburse all of the following, and is not to be  
            used to directly fund or as a loan to fund any other program  
            (Penal Code  12076(e).):

               (1) (A) The department for the cost of furnishing this  
               information. 
               (B) The department for the cost of meeting its obligations  
               under paragraph (2) of subdivision (b) of Section 8100 of  
               the Welfare and Institutions Code [regarding mental health  
               issues].
               (2) Local mental health facilities for state-mandated local  
               costs resulting from the reporting requirements imposed by  
               Section 8103 of the Welfare and Institutions Code.
               (3) The State Department of Mental Health for the costs  




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               resulting from the requirements imposed by Section 8104 of  
               the Welfare and Institutions Code.
               (4) Local mental hospitals, sanitariums, and institutions  
               for state-mandated local costs resulting from the reporting  
               requirements imposed by Section 8105 of the Welfare and  
               Institutions Code.
               (5) Local law enforcement agencies for state-mandated local  
               costs resulting from the notification requirements set  
               forth in subdivision (a) of Section 6385 of the Family Code  
               [protective orders].
               (6) Local law enforcement agencies for state-mandated local  
               costs resulting from the notification requirements set  
               forth in subdivision (c) of Section 8105 of the Welfare and  
               Institutions Code.
               (7) For the actual costs associated with the electronic or  
               telephonic transfer of information pursuant to subdivision  
               (c) [regarding the purchaser/transferee background  
               information].
               (8) The Department of Food and Agriculture for the costs  
               resulting from the notification provisions set forth in  
               Section 5343.5 of the Food and Agricultural Code [personal  
               handgun importers moving into California].
               (9) The department for the costs associated with  
               subparagraph (D) of paragraph (2) of subdivision (f) of  
               Section 12072 [personal handgun importers].  
               The fee established pursuant to Penal Code section 12076(e)  
               shall not exceed the sum of the actual processing costs of  
               the department and the estimated reasonable costs for the  
               other items identified, as specified.

           Provides that the DOJ may charge a fee sufficient to reimburse  
            the DOJ for each of the following but not to exceed $14,  
            except that the fee may be increased at a rate not to exceed  
            any increase in the California Consumer Price Index as  
            compiled and reported by the California Department of  
            Industrial Relations (Penal Code  12076(f)):

               (A) For the actual costs associated with the preparation,  
               sale, processing, and filing of forms or reports required  
               or utilized pursuant to Section 12078 if neither a dealer  




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               nor a law enforcement agency acting pursuant to Section  
               12084 is filing the form or report.
               (B) For the actual processing costs associated with the  
               submission of a Dealers' Record of Sale to the department  
               by a dealer or of the submission of a LEFT [Law Enforcement  
               Firearms Transfer Form] to the department by a law  
               enforcement agency acting pursuant to Section 12084 if the  
               waiting period described in Sections 12071, 12072, and  
               12084 does not apply.
               (C) For the actual costs associated with the preparation,  
               sale, processing, and filing of reports utilized pursuant  
               to subdivision (l) of Section 12078 or paragraph (18) of  
               subdivision (b) of Section 12071, or clause (i) of  
               subparagraph (A) of paragraph (2) of subdivision (f) of  
               Section 12072, or paragraph (3) of subdivision (f) of  
               Section 12072.
               (D) For the actual costs associated with the electronic or  
               telephonic transfer of information pursuant to subdivision  
               (c).

           Provides that if the DOJ charges a DROS/LEFT fee, it shall be  
            charged in the same amount to all categories of transaction  
            that are within that subparagraph; that any costs incurred by  
            the DOJ to implement the DROS fee shall be reimbursed from  
            fees collected and charged pursuant to that authorization; and  
            provides that no fees shall be charged to the dealer or a law  
            enforcement agency for costs incurred for implementing the  
            system.

           Provides that all money received by the DOJ pursuant to this  
            section shall be deposited in the Dealers' Record of Sale  
            Special Account of the General Fund, which is hereby created,  
            to be available, upon appropriation by the Legislature, for  
            expenditure by the department to offset specified costs.   
            (Penal Code  12076(g).)

           Existing law  - the Firearms Trafficking Prevention Act of 2002 -  
          requires California firearms dealers provide specified  
          information to the DOJ and that a new program be implemented, as  
          specified, requiring that out of state Federal Firearms License  




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          holder shipping firearms to California firearms dealers obtain  
          confirmation that the California dealer does have a valid  
          license in this state, as prescribed.  (Enacted in AB 2080  
          (Steinberg) - Chapter 909, Statutes of 2002.)  Those provisions  
          are effective, as follows:

          1.Any costs incurred by the DOJ to implement the new  
            requirements for out-of-state firearms dealers section shall  
            be funded from the Dealers' Record of Sale Special Account, as  
            set forth in subdivision (g) of Section 12076, upon  
            appropriation by the Legislature.

          2.The Firearms Trafficking Prevention Act of 2002 shall become  
            operative on January 1, 2004, if the actual reserve balance in  
            the Dealers' Record of Sale Special Account is $1,000,000 or  
            more on January 1, 2004, as determined by the DOJ.  If the  
            reserve balance is not equal to $1,000,000 or more on January  
            1, 2004, as determined by the DOJ, specified provisions shall  
            become operative when the DOJ determines that the actual  
            reserve balance in the Dealers' Record of Sale Special Account  
            equals $1,000,000 or more.
           



           This bill  does the following:

           Expands the existing specific limitations on the use of the  
            DROS fees in the Dealers' Record of Sale Special Account of  
            the General Fund by adding use by the Department of Justice  
            "for the costs associated with funding Department of Justice  
            firearms-related regulatory and enforcement activities related  
            to the sale, purchase, loan, or transfer of firearms pursuant  
            to" Chapter 1 of the Dangerous Weapons Control Law.

           Adds to the limit on the DROS fee inclusion of estimated costs  
            "the estimated reasonable costs of department firearms-related  
            regulatory and enforcement activities related to the sale,  
            purchase, loan, or transfer of firearms pursuant to" Chapter 1  
            of the Dangerous Weapons Control Law. 




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           Appropriate $548,000 from the Dealers' Record of Sale Special  
            Account to the Department of Justice to implement the Firearms  
            Trafficking Prevention Act of 2002.

           Makes related changes in law. 


                                      COMMENTS

          1.   Need for This Bill  

          The sponsor indicates the following (emphasis by the sponsor):

               Because of enforcement activities  funded by the state  
               legislature  from the Dealers' Record of Sale Special  
               Account (DROS), and funding sources added over the last 24  
               months, California has gone from almost no enforcement of  
               firearms laws relating to sales, transfers, purchase or  
               loans of firearms to having investigated a wide number of  
               firearm dealers, criminally prohibited individuals and  
               illegal firearm possessors and sellers. 

               The Department of Justice has identified more than 1000 law  
               violations by firearm dealers and investigated more 500  
               illegal firearm possessions by individuals who have  
               purchased guns in CA but fell into prohibited category.  In  
               addition, we have discovered 2,500 illegally prohibited  
               firearm and other dangerous weapons transactions and seized  
               those weapons as a result.  Unfortunately, because of a  
               recent legislative counsel opinion, the Department of  
               Justice feels strongly that clarification of enforcement  
               activity and the use of the DROS account to fund it is of  
               extreme importance.  At issue is whether or not the DROS  
               fee (which makes up more than 80% of the DROS Fund) can be  
               used to fund DOJ enforcement of the gun laws.  

               Over last ten years, California's firearm laws have changed  
               substantially with new bills being enacted almost every  
               year including:




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               Assault Weapons and Magazines ban (Perata, 1999)
               Handgun Safety Standards (Polanco, 1999)
               One Handgun a Month (Knox, 1999)
               Child Safety Locks (Scott, 1999)
               Gun Show Enforcement (Corbett, 1999)
               Penalty Increase for Carrying a Concealed Weapon (Scott,  
               1999)
               Gun Ownership Prohibitions for Domestic Violence  
               Perpetrators (Various bills)
               Prohibition of Gun Ownership for Individuals who are  
               Subject to WIC 5150 (Scott, 1999)
               Armed and Prohibited (Brulte, 2001)
               Handgun Safety Training (Scott, 2001)
               Gun Dealer License Verification (Steinberg, 2002)
               Retest Handguns (Koretz, 2002)

               Most of these bills came with no funding for enforcement,  
               however,  some identified the DROS fund  as a funding source  
               for enactment, i.e.,  Assault Weapons Public Education  
               Campaign, Handgun Retesting, and Gun Dealer License  
               Verification.
                
               Attorney General Lockyer feels it is of utmost importance  
               that the Department of Justice work to enforce California's  
               landmark firearms laws to ensure that those who are  
               prohibited from possessing or purchasing firearms do not  
               gain illegal access to guns.  Furthermore, he believes, as  
               the code states, that the Department must monitor gun  
               commerce in the state to ensure that all laws relating to  
               firearms sales, gun standards and prohibitions be strictly  
               enforced.  Finally, he feels that it is important that  
               those laws be enforced by fees paid directly by those who  
               engage in gun commerce in California (gun dealers,  
               purchasers and transferees) under the 12000 series of the  
               Penal Code.

               From the continuing mantra of "enforce the current gun  
               laws" by the National Rifle Association to the call for  
               preventing illegal gun sales and trafficking by the gun  




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               safety community, every statewide, indeed national,  
               organization concerned with guns desires that the  
               Department put significant effort into enforcement of gun  
               laws.  The Department's activities,  as approved in the  
               Budget Act over the last 2 years,  have been exactly that.

               When the legislature identifies a firearm program that they  
               would like to fund and when they specify that the funding  
               shall be from DROS, of course the legislature is talking  
               about the fees with background check fees that make up more  
               than 80% of the DROS account rather than taking from  
               specific items that fund other activities such as dangerous  
               weapon explosive permit inspections, handgun safety  
               certificates testing and the one dollar firearm safety  
               device development/monitoring. 

               Current state enforcement of alcohol, tobacco, hunting,  
               fishing and prescription drug laws are just a few of the  
               state enforcement areas where users/purchasers fund state  
               regulatory and enforcement activity.  In fact, 33% of fish  
               and game licensing fees (or $31.4 million) go towards  
               conservation education and enforcement.  Although the  
               Department of Justice believes it currently uses the DROS  
               fund and fees appropriately, we wish to clarify how the  
               DROS fee may be used to avoid further debate as raised in  
               the legislative counsel's opinion of August 28, 2002.

          2.   Expansion on Use of the Dealers' Record of Sale Fees  

          As noted in the author's background and the Purpose section,  
          above, there is a Dealers Record of Sale Fee and there is a  
          Dealers' Record of Sale Special Account in the General Fund for  
          appropriation by the Legislature.  However, while the DROS fee  
          is deposited in that account, the account contains other fees as  
          well.

          Committee staff's general impression is that this bill in  
          intended to resolve two issues, at least.  The first is that  
          funding for last year's AB 2080 - the Firearms Trafficking  
          Prevention Act of 2002 - may not be funded under the current law  




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          and that the creative drafting of the funding for that bill is  
          problematic.

          Therefore, this bill could have simply added that act to the  
          authorized uses of the DROS fee and made the appropriation also  
          included in this bill.

          However, this bill also changes the authorized use of the DROS  
          fee by adding a new general authorization for:

               costs associated with funding Department of Justice  
               firearms-related regulatory and enforcement activities  
               related to the sale, purchase, loan, or transfer of  
               firearms [pursuant to Chapter 1 of the Dangerous Weapons  
               Control Law].   

          That more general authority appears to be designed to allow the  
          DOJ the kind of "flexibility" in using DROS fees than exists  
          under current law, including funding AB 2080.

          The sponsor argues that this bill will not expand the use of  
          DROS fees, but clarify their use, and asserts that:

               The Legislature has historically appropriated DROS funds  
               for purposes that include regulatory and enforcement  
               activities related to the sale, purchase, loan, or transfer  
               of firearms.  This bill will not authorize DOJ to spend  
               DROS fees for purposes other than what the Legislature has  
               already approved through Budget Act appropriations.   
               Additionally, two other 2002 bills specified that they be  
               funded by DROS (AB 2580 [note: contingent on specific  
               conditions of the fund] and AB 2902).  As of right now, the  
               Legislature has included funding from DROS for these two  
               bills in the 03-04 Budget Bill.  

          The sponsor further asserts that that without the broader change  
          proposed by this bill, the DOJ would - If the Legislative  
          Counsel's opinion were strictly followed - have to stop or  
          curtail a number of activities.  The sponsor has provided a  
          two-page list of 24 such activities which are listed in their  




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          entirety in the last comment to this analysis.

          SHOULD THAT NEW "GENERAL" AUTHORITY FOR THE USE OF DROS FEES BE  
          ADDED TO LAW?

          WOULD IT INSTEAD BE APPROPRIATE TO ONLY ADD AUTHORITY TO USE THE  
          DROS FEES FOR AB 2080?

          In addition, the Chapter referred to includes Penal Code section  
          12000 through 12101.  All of those sections pertain to dangerous  
          weapons, including firearms.  Firearms are defined in several  
          subdivisions of Penal Code section 12001.  This bill's limiting  
          language added does include "sale, purchase, loan, or transfer"  
          so the DOJ has placed some limits on the new broader authority  
          for use of the DROS fee.

          ARE THE "LIMITATIONS" INCLUDED IN THIS BILL APPROPRIATE AND  
          SUFFICIENT?

          In addition, this bill does not authorize the DOJ to increase  
          DROS fees beyond the current authority in law.

          3.   Appropriation of $548,000 in This Bill
           
          The sponsor indicates the following about the appropriation in  
          this bill:

               The Legislature funded the implementation of three bills  
               from the DROS fund last year:  AB 2080, AB 2902 and AB  
               2580.  

               Assembly Bill 2080 (Steinberg, 2002) required DOJ to  
               establish a process to ensure that FFL's in California who  
               accept guns are also licensed under California law.  The  
               costs for AB 2080 are one-time and AB 161 (Steinberg, 2003)  
               would appropriate the funds from the DROS account to DOJ  
               for implementation.  

               Assembly Bill 2580 (Simitian, 2002) required annual  
               inspections of Dangerous Weapons Permit Holders, (except if  




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               they have fewer than five devices, then inspections would  
               only be required every five years).  Senate Bill 1312  
               required DOJ to establish a fee schedule to pay for these  
               costs ($165,000 approx annually) by January 1, 2006.   
               Dangerous Weapons permit fees are also deposited into and  
               paid from the DROS fund.

               Assembly Bill 2902 (Koretz) was permissive.  It authorized  
               DOJ to retest up to 5% of handguns on the Roster of  
               approved handguns for sale.  If fully implemented, ongoing  
               costs will be $120,000 annually.  First year costs would  
               include another $30k for regulations.  Manufacturers would  
               be required to reimburse DROS for reinstatement testing  
               ($30k approx).

               The DROS fund is healthy.  The Department has not raised  
               fees in 10 yrs.  Assembly Bill 161 would only clarify DOJ's  
               authority to use the fund for the activities it is already  
               budgeted for, which include enforcement and regulatory  
               activities specified in AB 161.  According to the DROS Fund  
               Condition Statement contained in the 03 Governor's Budget  
               (page LJE 76), a reserve of $3.1M is projected for the DROS  
               fund in 02-03 and a reserve of $1.7M is projected in 03-04.  
                 However, more recent Department calculations project a  
               reserve of $4.0 M in 02-03 and $3.2M in 03-04.
           
          4.   Further Information About the DROS Fee
           
          The previous comment contains information from the DOJ about the  
          condition of the DROS
          Fund in general.  In addition, the DOJ has provided the  
          following from the November 1, 2002, report to the Legislative  
          Analyst's Office "Supplemental Report of the 2002 Budget Act": 

               Local law enforcement agencies in California began  
               conducting background checks for firearm purchasers  
               approximately 80 years ago.  This responsibility shifted to  
               the Department of Justice approximately 50 years ago.   
               Through the years, firearm background checks have changed  
               from a manual process to a complex and comprehensive  




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               electronic background check.  The background check has  
               expanded from relatively few prohibiting categories to  
               today where the check is a comprehensive screening of  
               prohibiting felony, violent misdemeanor, mental health,  
               restraining order, and federal violation prohibitions.   
               Many of these changes resulted from 1991 legislation.   
               Other changes are the result of more recent legislation.   
               Some of the post-1991 changes include reducing processing  
               time so that the waiting period could be reduced from 15  
               days down to 10, expanding prohibiting violent misdemeanor  
               categories to include crimes such as stalking, carrying a  
               firearm on school grounds, threatening witnesses and other  
               firearm related prohibitions.  Also, since 1991 the  
               screening has been broadened to include additional  
               categories of restraining orders, civil, criminal and  
               work-place protective orders as well as increasing the  
               number of states participating in the background check  
               process from 22 states to over 37 states to determine  
               whether or not the purchaser may be prohibited due to a  
               criminal conviction resulting in another state.  

               Additionally in 1996, the National Instant Criminal  
               Background Check System (NICS) was incorporated into the  
               California background check process to identify federal  
               firearm prohibitions.  These changes, along with  
               improvements in validating purchaser information and in  
               limiting handgun purchasers to one gun a month, occurred  
               while the prohibiting databases including criminal, mental  
               health and restraining orders grew in size.  Consequently,  
               the background check carried out today is much more  
               expansive, comprehensive, and thorough while the time  
               allowed for processing has been reduced by 1/3.  Even with  
               these dramatic changes post-1991, the cost associated with  
               carrying out this check has remained constant for more than  
               a decade.

               The Department of Justice has been able to successfully  
               accomplish these changes while maintaining firearm  
               purchaser costs by streamlining processes, incorporating  
               data processing solutions, and combining like processes.   




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               These like processes are the firearm purchaser eligibility  
               checks performed for prospective firearm purchasers (DROS  
               checks) and the background check carried out for peace  
               officers, armed security guards, assault weapon  
               registrants, concealed weapon permittees, voluntary firearm  
               registrants, etc.  Rather than setting up unique programs  
               for each of these categories, the background check process,  
               which is identical for each of these categories, is carried  
               out by a pool of staff that can shift the workload to meet  
               fluctuating volumes associated with each of these  
               categories. It is the economies of scale, the shifting of  
               background check personnel, and employing improvements in  
               technology that has enabled the department to keep the DROS  
               fee as well as the fee charged to others needing a firearm  
               eligibility check at $14.00.  

               The department believes that the pooling of resources and  
               sharing of equipment and supervision is consistent with  
               California law and as required by PC section 12076(f)(1).   
               The department only charges a fee sufficient to reimburse  
               for the PC section 12076 process, and all DROS monies  
               deposited into the DROS account are used only by the  
               Department to offset the costs incurred pursuant to this  
               section.  

          5.   Legislative Counsel Opinion  

          The Legislative Counsel did prepare an opinion at the request of  
          Senator Morrow that asked the following questions:

               You have asked whether Assembly Bill No. 2080, as amended  
               August 26, 2002, [final amended version] (hereafter A.B.  
               2080), if enacted, would authorize the use of revenues from  
               the fees currently paid to dealers by the purchasers of  
               firearms for the new purposes proposed in the bill.  You  
               have also asked whether the expenditure of those revenues,  
               without authorization, for the purposes proposed by A.B.  
               2080 would convert the fee imposed to a tax. 

          The opinion, dated August 28, 2002 - delivered to Assemblymember  




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          Steinberg as well pursuant to Joint Rule 34 - concludes:

               ? A.B. 2080 would not authorize the expenditure of these  
               DROS fees for the new purposes proposed in A.B. 2080 and,  
               consequently, A.B. 2080 would make no change that would  
               raise the issue of whether the DROS fee should be  
               recharacterized as a tax.  That conclusion would not be  
               changed by an unauthorized expenditure of those funds for   
               the new purposes proposed by A.B. 2080.  We perceive no  
               basis upon which an unauthorized expenditure of these funds  
               would be deemed to cause the DROS fee to be considered a  
               tax. 

          That opinion discusses the specific nature of the provisions of  
          Penal Code section 12076(e), (f), and (g) - see Purpose section  
          of this analysis, above - and discusses the appropriate  
          construction of section (g) and the fact that the DOJ deposits  
          funds from 12 other sources in the DROS account, for example  
          fees for assault weapon registration (Penal Code section  
          12285(a)) and Commission on Peace Officer Standards and Training  
          fees collected pursuant to Penal Code section 13511.5.  Thus the  
          opinion also concludes that:

               ? it is our view that the appropriate construction of  
               subdivision (g) of Section 12076 is that the phrase "to be  
               available, upon appropriation" refers generally to money in  
               the DROS account, rather than specifically to the revenue  
               from the DROS fee pursuant to subdivision (e) of Section  
               12076.  ? Under existing law, the purposes in subdivision  
               (g) for which DROS account funds may be expended include  
               purposes not listed in subdivision (e) of Section 12076.   
               For example, Section 12289 requires that department to  
               conduct a public education program regarding the  
               registration of assault weapons.  However, because the DROS  
               account contains funds in addition to the funds obtained  
               pursuant to subdivision (e) of section 12076, the purposes  
               to which funds are directed pursuant to subdivisions (g)  
               may be accomplished with the use of subdivisions (e) funds,  
               and there without conflict with the provisions of  
               subdivisions (e).  




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          6.   Implementing the Firearms Trafficking Prevention Act of 2002
           
          As noted in the Purpose section, above, AB 2080 contained the  
          following language:

               SEC. 9.  Notwithstanding subdivision (c) of Section 12083,  
               Section 12083 of the Penal Code, and the amendments made to  
               Section 12071 of the Penal Code by this act shall become  
               operative on January 1, 2004, if the actual reserve balance  
               in the Dealers' Record of Sale Special Account is one  
               million dollars ($1,000,000) or more on January 1, 2004, as  
               determined by the department.  If the reserve balance is  
               not equal to one million dollars ($1,000,000) or more on  
               January 1, 2004, as determined by the department, those  
               provisions shall become operative when the department  
               determines that the actual reserve balance in the Dealers'  
               Record of Sale Special Account equals one million dollars  
               ($1,000,000) or more.

          7.   Elimination of the "ghost" Version of Penal Code Section  
          12071 in Section 1 of This Bill  

          This bill does delete a non-operative version of Penal Code  
          section 12071 created by AB 2793 (Pescetti) - Chapter 911,  
          Statutes of 2002 - that was created in a flurry of  
          double-jointing amends last year involving section 12071.   
          However, this bill does not delete the operative section 12071  
          otherwise created in law. 

          8.   Support for This Bill
           
          The letter in support of this bill from Women Against Gun  
          Violence includes:

               The Department of Justice has made great strides these past  
               few years in the enforcement of important firearms  
               legislation and we believe that such momentum must continue  
               and increase.  Given that these funds are already allocated  
               to and used by the DOJ, that a budget reserve is projected  




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               for this fiscal year and that the DROS fees have not been  
               raised in ten years, we believe that the fiscal  
               implications of AB 161 passage are negligible to all sides,  
               and that this bill makes sense. 

           9.   Opposition to this bill
            
            The NRA letter in opposition includes the following:

               The proposed changes to the Penal Code in AB161 would  
               change a long 
               established policy for the use of the Dealer Record of Sale  
               (DROS) fees collected for 
               the background checks on firearms transferees.

               The proposed language would allow the Department of Justice  
               (DOJ) to use the 
               DROS fees collected for DOJ Firearms Division programs that  
               are not related to 
               conducting and administering the backgrounds checks for the  
               transfer of 
               firearms.

               We understand that their are difficulties for the DOJ  
               Firearms Division in 
               funding some of their programs, the solution would be for  
               the legislature to 
               appropriate the funds necessary for the DOJ to do their  
               work.

          10.  List of Activities the Sponsor States Would Have to be  
             Curtailed or Stopped if the Legislative Counsel's Opinion was  
             Strictly Followed
           
          As noted in Comment #2, above, the DOJ asserts that without the  
          broader change proposed by this bill, the DOJ would - if the  
          Legislative Counsel's opinion were strictly followed - have to  
          stop or curtail a number of activities.  First the DOJ indicates  
          that approximately 75% of DOJ's Firearms Division (75 of 105  
          positions) is budgeted from DROS.  Second, the DOJ indicates  




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          that many of the following Division functions would either have  
          to cease operation or function without enforcement or  
          administrative oversight if the Legislative Counsel opinion were  
          strictly enforced:
           
            Dealers' Record of Sale (DROS).  Gun buyers firearms  
            eligibility background checks.

           Peace Officer Standard Training (POST).  Firearms eligibility  
            background check to allow non-sponsored individuals to attend  
            a peace officer training academy.

           Peace Officer Firearms Eligibility.  Firearms eligibility  
            background check for peace officer applicants.

           Security Guard Firearm Eligibility.  Firearms eligibility  
            background check for armed security guards.

           Handgun Reporting (Voluntary Registrations, Operation of Law,  
            New Resident Report of Handguns, Curio/Relic).  All require  
            firearms eligibility background checks.

           Law Enforcement Assault Weapon Registration.  Firearms  
            eligibility background check and gun registration process for  
            persons who possess assault weapons as defined by state law.

           Certificate of Eligibility.  Fingerprint based firearms  
            eligibility background check required on gun dealers, gun show  
            promoters and persons applying for local explosive permits  
            used for construction, employees of gun manufacturers, etc.

           Carry Concealed Weapon Licenses.  State required fingerprint  
            based firearms eligibility background check on citizens  
            authorized to carry a concealed handgun on their person.

           Centralized List of Gun Dealers/Dealer Inspection.  Gun dealer  
            registration licensure tracking and inspection program used to  
            ensure that only duly licensed dealers sell firearms and that  
            they comply with all applicable laws.





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           Dangerous Weapons Licenses and Permits.  State required  
            fingerprint based firearms eligibility background check on  
            persons authorized to possess dangerous weapons (e.g., machine  
            guns, assault weapons grenades, etc.)








































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           Gun Manufacturers License.  Licensing and inspection program  
            for statewide firearms manufacturers.

           Gun Show Promoter's License.  Licensing/tracking program for  
            gun show promoters.

           Safe Handgun/Laboratory Testing.  DOJ administered laboratory  
            certification and handgun testing program to ensure that  
            unsafe handguns are not manufactured/sold in the state.

           Mental Health Firearms Prohibition Reports.  Database entry,  
            verification and maintenance of mental health reports  
            submitted to DOJ by public/private statewide mental health  
            facilities.

           Superior Court Reports of Firearms Prohibition.  Database  
            entry, verification, and maintenance of superior court reports  
            of mentally prohibited persons.

           Law Enforcement Agency Tarasoff Reports of Firearms  
            Prohibition.  Database entry, verification, and maintenance of  
            reports of persons who communicated to their psychotherapist a  
            threat against themselves or others.

           Juvenile Courts Reports of Firearms Prohibition.  Database  
            entry, verification and maintenance of juvenile courts reports  
            of violent firearms prohibited juvenile offenders.

           Law Enforcement Gun Releases.  Conduct firearms eligibility  
            background checks on civilians on behalf of law enforcement  
            agencies returning previously confiscated/stolen/lost firearms  
            back to these individuals.

           Firearms Dealer Acquisition Reports.  AFS database update of  
            mandatory reports submitted by gun dealers acknowledging the  
            purchase/acquisition/receipt of a handgun from a private  
            citizen.

           Reports of No Longer in Possession of Firearms.  AFS database  




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            update of reports submitted by private citizens noticing DOJ  
            that they are no longer in possession of a firearm(s) that was  
            previously registered with the Department.

           Automated Firearms System.  Maintain and conduct quality  
            control of the statewide firearms of records entered into the  
            system by local law enforcement agencies and the DOJ CJIS  
            system.  AFS is directly linked to the NCIC Gun File  
            maintained by the FBY.  AFS is available to law enforcement 24  
            hours a day, 7 days a week.

           Database Audits Section.  Conduct on-site audits on law  
            enforcement agencies regarding the use of AFS and the Domestic  
            Violence Restraining Order System.

           Domestic Violence Restraining Order System (DVROS).  Maintain  
            and conduct quality control of  DVROS; train law enforcement  
            and criminal justice agencies on DVROS, restraining orders and  
            the firearm prohibitions associated with each type of order;  
            and monitor the forwarding of restraining order information  
            tot NCIS's Protection Order File.

           Field Operations Section.  Functions as liaison to California  
            law enforcement agencies; conduct onsite training on  
            information contained in AFS and DVROS; conducts terminal  
            inspections.  
           


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