here is the letter I sent to mossberg if anyone else would like to do the same:
"To Whom It May Concern in Management, O.F. Mossberg & Sons,
I am writing to you with concern about your new Duck Commander pistol and its magazine it shares with the 715T 22LR rifles.
As a Canadian firearm owner who is knowledgeable about Canadian firearms laws, I can tell you that 22LR rifles currently have no magazine limit and all handguns, including 22LR handguns, are limited to 10 rounds. This is as per Regulations Prescribing Certain Firearms and other Weapons, Components and Parts of Weapons, Accessories, Cartridge Magazines, Ammunition and Projectiles as Prohibited or Restricted - Part 4, PROHIBITED DEVICES, Former Prohibited Weapons Order No.9, Subsection 3:
• 3. (1) Any cartridge magazine
(b) that is capable of containing more than 10 cartridges of the type for which the magazine was originally designed and that is designed or manufactured for use in a semi-automatic handgun that is commonly available in Canada.
For your convenience, a copy of the entire document has been attached at the end of this letter.
It is a fairly accurate to say that most law abiding Canadian gun owners do not hold their RPAL license, which allows them to legally purchase restricted firearms in Canada. As you are most likely already aware, a non-restricted rifle can be used both in the bush and at a certified range, whereas a restricted firearm can only be used in a range certified for restricted use.
That being said, a small fraction of Canadian citizens hold their prohibited license, which restricts them to owning, but not legally using and enjoying their prohibited firearms. If Mossberg imports the Duck Commander Pistol into Canada advertising that they use the same magazine as the 715T 22LR rifle, the RCMP (Royal Canadian Mounted Police) firearms lab will classify the 715T 22LR rifle magazine as a prohibited device and both firearms will be limited to 10 rounds. This will effectively and immediately turn law abiding citizens into paperwork criminals for simply owning the 25 rounds magazine that by design, until the 715P was created, fit only into the 715T 22LR.
Offering a ten round replacement magazine to all current owners will not result in satisfied customers, as those that had originally purchased the firearm did so with the knowledge of its legal 25 round magazine. Giving these very same owners a replacement magazine following the reclassification of it 25 round predecessor will do little to alleviate the problems associated with the introduction of the 715P into the Canadian market, and may result in a direct loss of sales for the 715T 22LR, replacement magazines for the 715T 22LR, and above all ownership of the 715T 22LR in Canada.
The Duck Commander will only sell to a very small market in Canada where the 715T 22LR rifle sells to all licensed firearms owners (almost 2 million Canadians).
I would suggest not exporting any Duck Commander pistols to be sold to the Canadian market until Mossberg management has:
- Contacted the RCMP Firearms lab and confirmed my previously mentioned magazine classifications;
- Arrives at a sound conclusion to avoid reclassification of 715T 22LR rifle magazines.
The precedent with 22LR rifle magazine capacity and their ability to be interchanged between restricted firearms and non-restricted firearms has already been set in Canada with the Ruger BX-25 round magazine being advertised as fitting both the Ruger SR22 rifle and Charger pistol variant. As an owner of the 715T 22LR and several 25 round magazines, I will sell this rifle and switch to the Ruger 10/22 (which currently has legal 25 round magazine available) should the current 25 round magazine used in the 715T 22LR become a prohibited device in Canada.
Thank you for your time and I eagerly await your response.
Sincerely,
