HomeMy WebLinkAboutItem 7.1 Regulation of Firearm Retailers and Indoor Shooting Ranges Agenda Item 7.1
STAFF REPORT
CITY COUNCIL
Page 1 of 7
DATE: September 1, 2026
TO: Honorable Mayor and City Councilmembers
FROM: Colleen Tribby, City Manager
SUBJECT:
Regulation of Firearm Retailers and Indoor Shooting Ranges
Prepared by: Jennifer Byous, Planning Manager
EXECUTIVE SUMMARY:
The City Council will receive a report on potential land use regulations for firearm retailers and
indoor shooting ranges. In January 2026, the City Council adopted an Urgency Interim
Ordinance establishing a temporary moratorium on the establishment, expansion, and
relocation of firearm related businesses and indoor shooting ranges. The urgency ordinance
allows time for the City to complete a comprehensive review of the land use and re gulatory
frameworks governing such uses. In response, Staff evaluated existing federal and state
regulations, Second Amendment case law, and regulations adopted by other jurisdictions. The
City Council will receive the report and is requested to provide direction to Staff regarding the
future regulation of firearm dealers and indoor shooting ranges .
STAFF RECOMMENDATION:
Receive the report and direct Staff to prepare amendments to the Dublin Municipal Code
establishing a 1,000-foot separation between firearm related uses and public and private K–12
schools and evaluate the feasibility of requiring documentation of compliance with federal and
state workplace safety and environmental regulations during the building permit review for
indoor shooting ranges.
FINANCIAL IMPACT:
Implementation of any of the recommended changes to the Dublin Municipal Code (DMC) is
anticipated to have minimal fiscal impact. Modifications to the DMC and supportive
administrative work would require Staff and City Attorney time associated with community
outreach, ordinance preparation, Planning Commission review, and City Council consideration.
These activities are expected to be completed within existing departmental resources.
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Page 2 of 7
DESCRIPTION:
Background
The Dublin Municipal Code (DMC) regulates firearm sales related businesses as retail uses
and such uses are permitted in zoning districts where retail uses are allowed. Indoor shooting
ranges are regulated as Recreational Facility/Indoor uses. For purposes of this Staff Report,
firearm retailers and indoor shooting ranges are collectively referred to as “firearm related
uses” unless otherwise specified.
The City received an inquiry regarding a proposed firearm retailer and indoor shooting range
adjacent to BASIS Independent School in Downtown Dublin. Although the proposed use is
permitted under the existing zoning regulations, the inquiry raised questions regarding land
use compatibility and whether additional zoning standards should be considered.
On January 20, 2026, the City Council adopted Urgency Interim Ordinance No. 01-26
establishing a 45-day moratorium on the establishment, expansion, and relocation of firearm
related businesses and indoor shooting ranges. On March 3, 2026, the City Council extended
the moratorium through January 27, 2027 (Ordinance No. 02 -26). The moratorium was
adopted to allow the City time to complete a comprehensive review of land use and regulatory
frameworks governing such uses, and to protect the public health, safety, and welfare during
the review period.
Staff evaluated existing federal and state regulations, Second Amendment case law,
regulations adopted by other jurisdictions, and separation standards. The City Council will
receive the report and is requested to provide direction regarding the future regulation of
firearm dealers and indoor shooting ranges.
Existing Regulatory Framework
Firearm related businesses are regulated through a combination of federal and state laws.
These laws establish licensing requirements, regulate firearm sales and transfers, impose
background checks and recordkeeping requirements, and establish workplace safety and
environmental standards. Local governments retain authority to regulate the location of firearm
related uses through zoning and land use regulations.
Firearm retailers. Firearm dealers are subject to federal and state licensing
requirements administered by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
and the California Department of Justice (DOJ)1. These agencies regulate dealer licensing,
background checks, waiting periods, recordkeeping, secure firearm storage, inspections, and
enforcement2. Dealers must comply with both federal and state requirements before engaging
in firearm sales.
1 18 U.S.C. § 923; Cal. Penal Code §§ 26700–26915.
2 18 U.S.C. Chapter 44; California dealer licensing (Penal Code §§ 26700–26915)
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Federal and state law also establishes Gun-Free School Zones that generally prohibit the
possession of a firearm within 1,000 feet of schools, subject to specified statutory exemptions3.
While these laws regulate firearm possession rather than land use, they reflect state and
federal policy recognizing schools as sensitive environments. This policy provides context for
local governments when evaluating land use compatibility between firearm related businesses
and schools.
Indoor shooting ranges. Indoor shooting ranges are subject to workplace safety and
environmental regulations administered by federal and state agencies. The Occupational
Safety and Health Administration (OSHA) and California Occupational Safety and Health
(Cal/OSHA) regulate employee exposure to airborne lead, ventilation, respiratory protection,
medical surveillance, and other workplace safety requirements4. The California Department of
Toxic Substances Control (DTSC) regulates the handling, storage, transportation, and disposal
of lead contaminated materials and other hazardous wastes generated by shooting range
operations5. A summary of these regulatory responsibilities is provided in Attachment 1.
Indoor shooting ranges are also subject to a Building Permit in which the City’s applicable
building, mechanical, electrical, fire, accessibility, and other life safety requirements are
reviewed. Specialized components such as ballistic containment and bullet trap systems,
mechanical ventilation and filtration systems may be required to meet federal, state, or local
requirements.
Second Amendment
The Second Amendment protects an individual’s right to keep and bear arms. In District of
Columbia v. Heller (2008), the United States Supreme Court recognized an individual ’s right to
possess firearms for lawful purposes, including self-defense. McDonald v. City of Chicago
(2010) held that the Second Amendment applies to state and local governments, and New
York State Rifle & Pistol Association v. Bruen (2022) and Wolford v. Lopez (2026) establish the
current framework for evaluating firearm regulations under the Second Amendment.
Federal courts have also recognized that the Second Amendment protects the ability to
lawfully acquire firearms. However, this does not prevent local governments from applying land
use regulations to firearm related businesses. Courts consider the practical effect of a
regulation, including whether it meaningfully limits the ability to lawfully acquire firearms or the
ability to learn to use them, in the case of ranges. The exact constitutional test that would be
applied in the event of a challenge is highly uncertain, due to the shifting landscape.
3 Federal Gun-Free School Zones (18 U.S.C. § 922(q)) and California Gun-Free School Zones (Penal Code §
626.9). The restrictions only apply to public property, and, therefore, it is not unlawful to operate a firearms dealer
within 1,000 feet of a school.
4 OSHA/Cal-OSHA lead standards (29 CFR § 1910.1025; 8 CCR § 5198)
5 DTSC hazardous waste authority (Health & Safety Code, Div. 20, Ch. 6.5 / Title 22 CCR)
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Local Land Use Authority
The Ninth Circuit addressed the issue of local land use authority in Teixeira v. County of
Alameda (2017), which involved a zoning ordinance requiring firearm retailers to be separated
from certain uses, including schools. The court upheld the ordinance and found that the
Second Amendment does not guarantee a firearm retailer the right to operate at a particular
location.
Although Teixeira was decided before Bruen, the Ninth Circuit confirmed in B & L Productions,
Inc. v. Newsom (2024) that restrictions on where firearms may be sold do not necessarily
violate the Second Amendment. The relevant consideration is the practical effect of the
regulation on the ability to acquire firearms. More recent Ninth Circuit decisions, including
Nguyen v. Bonta (2025), further demonstrate that regulations that meaningfully limit firearm
acquisition require additional Second Amendment analysis.
These decisions support evaluating the practical effect of proposed land use regulations to
ensure there is land zoned for commercial and industrial activities outside of separation areas.
A summary of the principal decisions relevant to local land use regulation s is provided in
Attachment 2.
Local Regulatory Approaches
Staff reviewed regulations adopted by 14 California jurisdictions and the City of Chicago to
better understand the range of regulatory approaches used for firearm related businesses.
Chicago was included because its regulations have been the sub ject of significant litigation
and provide an additional example of how firearm related businesses have been regulated
following more recent legal challenges. A detailed comparison of the jurisdictions reviewed is
provided in Attachment 3. Many of the ordinances reviewed were adopted before Bruen and
subsequent federal court decisions. Staff therefore evaluated the se regulatory approaches
through the lens of the current legal framework rather than treating those ordinances as
models for adoption.
The regulatory approach varies by jurisdiction. Some jurisdictions adopted local firearm dealer
licensing programs, discretionary permit requirements such as a Conditional Use Permit
(CUP), operational standards, and/or land use regulations such as separation requirements.
These jurisdictions use licenses and permits to regulate matters such as security,
recordkeeping, employee requirements, and the manner in which firearm sales are conducted.
However, these regulations overlap with activities already regulated through federal and state
licensing and regulatory programs.
Land use related permits such as a CUP allow for case-by-case review. However, this
approach lacks objective zoning standards that establish clear and predictable requirements
that allow the City to directly address compatibility issues. The use of separation standards is a
common zoning tool used to address compatibility between uses. Requirements for a
separation between certain uses deemed relevant for that jurisdiction provide consistent and
objective requirements.
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Analysis
If the City were to apply additional regulations to the firearm related uses, Staff would
recommend a focused land use approach consisting of an objective separation requirement
from schools. This approach addresses compatibility issues between land uses while not
duplicating existing federal and state regulatory programs for firearm dealer licensing, firearm
sales, security, recordkeeping, and other operational requirements and avoids conflicts with
established case law.
Separation Standards
Separation standards are a common zoning tool used to address compatibility between uses.
According to the Giffords Law Center’s statewide survey of local firearm ordinances, 34
California jurisdictions have adopted objective separation requirements for firearm related
businesses. Staff reviewed a representative subset of these jurisdictions in greater detail to
compare the types of protected uses, separation distances, and measurement methods most
relevant to Dublin as shown in Table 1 below.
Table 1. Firearm Separation Requirements
Jurisdiction Residential
Zoning/Uses
Educational &
Child-Oriented
Uses
Community & Civic
Uses
Regulated
Commercial
Uses1
Pleasant
Hill 150 ft 1,000 ft 500 ft -
Alameda
County 500 ft 500 ft - 500 ft
Oakland 1,000 ft Varies Varies 1,500 ft
San Carlos 1,000 ft 1,000 ft 1,000 ft 1,000 ft
Chicago, IL -
500 ft – primary
and secondary
school
500 ft – government
owned or leased parks -
1. Regulated commercial uses vary by jurisdiction and may include other firearm dealers, liquor
establishments, adult entertainment businesses, and massage related establishments.
The City currently uses separation standards for the regulation of tobacco retailers, adult
businesses, hazardous waste facilities, and cottage food operations. Of these uses, the
tobacco retailer standard is most similar to the established federal and state 1,000-foot Gun-
Free School Zones around K–12 schools. The City requires tobacco retailers to maintain a
1,000-foot distance between tobacco retailers, a 1,000-foot distance from K–12 schools, and a
500-foot separation to a playground, youth center, city-owned and city-operated recreational
facilities, park, or library.
Staff evaluated three separation scenarios: a) applying a 500-foot separation from schools; b)
applying a 1,000-foot separation from schools; and c) applying the tobacco retailer separation
standards. In the evaluation, Staff considered land use compatibility and whether reasonable
opportunities would remain for firearm related uses to locate within the City as shown in Table
2 below. Attachment 4 provides additional information, and Attachment 5 provides maps
demonstrating the separation under each of the three separation scenarios.
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Table 2. Separation Alternatives
Scenario
Acreage Outside
Separation
Areas
Percent Outside
Separation Areas
500-foot school separation 1,082 acres 95%
1,000-foot school separation 947 acres 83%
Tobacco retailer separation 758 acres 67%
Policy Options and Recommendation
Based on the existing regulatory framework, current Second Amendment case law, the review
of other jurisdictions, and the separation analysis, Staff identified the following options for the
City Council’s consideration:
Option 1: Maintain existing regulations. Continue to regulate firearm related businesses and
indoor shooting ranges under the existing zoning framework. This means, for example, that the
proposed firearm retailer and indoor shooting range adjacent to BASIS Independent School in
Downtown Dublin would be allowed.
Option 2: Establish a 500-foot separation between firearm related uses and public and private
K–12 schools. While this option provides 95% availability outside the separation areas for
firearm related businesses, Staff believes the separation level would have minimal effect.
Option 3: Mirror the tobacco retailer separation standard. Staff does not recommend this
option because it would significantly reduce available commercial and industrial land for
firearm related businesses. It is important to preserve reasonable opportunity sites within the
City in accordance with the Second Amendment considerations discussed above.
Option 4 (recommended): Establish a 1,000-foot separation between firearm related uses
and public and private K–12 schools. Staff recommends this option, which maintains
consistency with existing firearm possession laws while also recognizing schools as sensitive
environments. Staff also believes this still maintains adequate land zoned for commercial and
industrial activities outside of separation areas.
If directed, Staff could also evaluate the feasibility of adding a local requirement for applicants
to provide documentation demonstrating compliance with applicable federal and state (i.e.,
OSHA, Cal/OSHA, and DTSC) workplace safety and environmental regulations for indoor
shooting ranges as part of the building permit process.
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Next Steps
Based on the City Council’s direction, Staff will prepare the appropriate regulations and
policies to implement that direction. If amendments to the DMC are proposed, Staff will
prepare the amendments for consideration and a recommendation by the Planning
Commission and final action by the City Council.
STRATEGIC PLAN INITIATIVE:
None.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
The City Council Agenda was posted.
ATTACHMENTS:
1) Existing Federal and State Regulatory Framework
2) Second Amendment Case Law Relevant to Local Land Use Regulation
3) Firearm Related Use Regulations by Jurisdiction
4) Commercial and Industrial Land Use Acreage Comparison
5) Separation Scenario Maps
33
Attachment 1
FEDERAL AND CALIFORNIA REGULATORY FRAMEWORK
Firearm Retailers and Indoor Shooting Ranges
Purpose. This attachment summarizes federal, state, regional, and locally administered regulatory programs applicable to firearm
retailers and indoor shooting ranges. The matrix identifies the responsible agency, regulated subject, applicable authority, principal
requirements, inspection and enforcement responsibilities, and relevance to the City's land use review. These programs regula te matters
including firearm dealer licensing and transactions, occupational safety, lead exposure, hazardous waste, building and f ire requirements,
and other operational matters. They are distinct from the City's land use authority, which addresses the location and compati bility of
firearm-related businesses.
Planning Oriented Regulatory Matrix
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
ATF - Federal
Firearms
License
Engaging in the
business of
importing,
manufacturing, or
dealing in
firearms; dealer
records;
transfers;
inventory losses.
18 U.S.C. §§
922, 923; 27
C.F.R. Part 478.
Federal Firearms
License; identity
verification;
transaction and
acquisition/disposition
records; compliance
with transfer
prohibitions; reporting
theft or loss; license
renewal.
ATF industry
operations
investigators conduct
compliance inspections
and may issue warning
letters, warning
conferences,
suspension/revocation
proceedings, or
referrals as authorized
by law.
A City zoning approval
does not authorize firearm
sales. Federal licensing is
a separate prerequisite.
The FFL program does not
determine local land use
compatibility.
FBI / NICS and
California DOJ
point-of-contact
process
Purchaser
eligibility and
background
checks.
18 U.S.C. §
922(t); 27 C.F.R.
§ 478.102; Cal.
Penal Code §§
28220 et seq.
Background check
before transfer;
review of federal and
state prohibitions.
California dealers
submit transactions
through the DOJ
Dealer Record of
Sale system.
FBI and California DOJ
administer records
checks; prohibited
transfers may be
denied or delayed;
violations may be
referred for
enforcement.
Background-check
administration is not a local
zoning function and
generally does not require
a duplicative City process.
California DOJ -
Dealer
Licensing and
Centralized List
Eligibility to
operate as a
California firearm
dealer.
Cal. Penal Code
§§ 26700-
26915; DOJ
dealer
Valid FFL; applicable
local regulatory or
business license;
seller's permit; DOJ
DOJ may inspect
records and dealer
operations as
authorized by statute
State law expressly
anticipates applicable local
licensing but does not
require a local jurisdiction
34
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
regulations and
forms.
Certificate of
Eligibility; placement
on DOJ Centralized
List; employee
Certificates of
Eligibility for
employees handling,
selling, or delivering
firearms.
and may deny,
remove, suspend, or
pursue enforcement
concerning state
eligibility and dealer
compliance.
to create a police-permit
program. Zoning and any
City business-license
requirements remain
distinct.
California DOJ –
Ammunition
Vendor
Regulation
Retail sale and
transfer of
ammunition
Cal. Penal Code
§§ 16151,
30312, 30342–
30365, 30370–
30372, 30385–
30395.
California generally
requires ammunition
sales and transfers to
be conducted by or
processed through a
licensed ammunition
vendor. A California-
licensed firearms
dealer is
automatically deemed
a licensed
ammunition vendor,
subject to applicable
ammunition-sale
requirements. State
law also contains
provisions applicable
to ammunition
purchased or
received at licensed
target facilities.
California DOJ
administers
ammunition-vendor
licensing and
ammunition purchase
authorization
requirements and
maintains ammunition
transaction records as
required by state law.
An indoor shooting range
that sells ammunition may
be subject to California
ammunition-vendor
requirements. If the range
also engages in firearm
sales, the separate federal
and California firearm-
dealer licensing
requirements apply. These
requirements regulate
ammunition and firearm
transactions rather than
land use compatibility.
California DOJ -
Sales, Waiting
Period,
Records,
Storage and
Reporting
Dealer Record of
Sale, purchaser
documentation,
waiting period,
delivery
procedures, safe
handling,
Cal. Penal Code
§§ 26800-
26915, 27540,
28220 and
related
provisions.
DROS submission;
statutory waiting
period; delivery only
after approval and
compliance;
purchaser
identification and
DOJ audits/inspections
and criminal or
administrative
enforcement may
apply.
These requirements
regulate transactions and
dealer conduct. They do
not replace local review of
the location and physical
compatibility of the use.
35
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
storage, notices,
and records.
documentation;
dealer storage and
security
requirements;
employee eligibility;
records and required
notices.
OSHA - Federal
Lead and
Workplace
Safety
Employee
exposure where
federal OSHA
has jurisdiction;
general safety
requirements.
29 C.F.R. §
1910.1025; 29
C.F.R. Part
1910;
Occupational
Safety and
Health Act.
Exposure
assessment;
permissible exposure
limit; engineering and
work-practice
controls; respiratory
protection; protective
clothing; hygiene;
housekeeping;
medical surveillance;
training; records.
OSHA may inspect
workplaces and issue
citations and penalties.
California operates an
approved State Plan,
so most private
workplaces in
California are
principally regulated by
Cal/OSHA.
Federal standards provide
a baseline and may apply
in limited federal-
jurisdiction settings. They
are not land use
entitlements.
Cal/OSHA -
Lead in General
Industry
Employee
exposure to lead
at indoor ranges
and during
cleaning or
maintenance.
8 C.C.R. §§
5198 and 5155;
Cal. Labor
Code; updated
lead standard
effective
January 1, 2025.
10 micrograms per
cubic meter 8-hour
TWA PEL under
§5198; exposure
assessment;
engineering/work-
practice controls;
respiratory protection;
protective clothing;
housekeeping;
hygiene facilities and
practices; medical
surveillance; training;
recordkeeping.
Cal/OSHA consultation
and enforcement;
workplace inspection,
citation, abatement,
and penalty authority.
Ventilation design and
operation may be
necessary to control
exposure, but compliance
is determined through
occupational-safety
standards and exposure
conditions, not by a city-
created technical lead
standard.
DTSC /
California
Hazardous
Waste Control
Law
Discarded
recovered bullets,
fragments, spent
ammunition
constituents, lead
Cal. Health &
Safety Code,
Div. 20, Ch. 6.5
(§§ 25100 et
seq.); 22 C.C.R.,
Waste determination;
generator
identification;
accumulation and
labeling; storage time
DTSC and the local
CUPA inspect and
enforce generator and
hazardous-waste
requirements.
A city may require
evidence of agency
compliance through
ordinary development
review, but creating
36
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
dust, filters,
cleaning
residues,
contaminated
media, and other
wastes.
Div. 4.5; DTSC
Shooting Range
Maintenance
Guidance.
limits; manifests and
authorized
transport/disposal;
employee training
and contingency
requirements as
applicable.
Recovered material
may be managed
differently if
legitimately recycled
and not discarded.
separate local waste
classifications or disposal
rules would risk
duplication.
CalEPA Unified
Program /
Alameda County
Certified Unified
Program
Agency (CUPA)
Hazardous-waste
generator
oversight;
hazardous-
material inventory
and business
plans; local
implementation of
state standards.
Cal. Health &
Safety Code
Chs. 6.5 and
6.95; 19 C.C.R.,
Div. 5; 27 C.C.R.
electronic
reporting
requirements;
CalEPA Unified
Program.
CERS reporting;
Hazardous Materials
Business Plan when
thresholds are met;
chemical inventory;
site map; emergency
response and
employee training
information;
hazardous-waste
generator
permits/identification
as applicable.
Alameda County
Department of
Environmental Health,
as CUPA, administers
permits, inspections,
and enforcement in its
jurisdiction, subject to
program boundaries
and local
arrangements.
Project conditions should
direct applicants to the
CUPA for applicability
determinations rather than
establish a parallel city
technical program.
U.S. EPA -
RCRA /
CERCLA /
EPCRA
Hazardous-waste
requirements and
reportable
releases of lead
or other
hazardous
substances.
Resource
Conservation
and Recovery
Act, 42 U.S.C.
§§ 6901 et seq.;
40 C.F.R. Parts
260-279;
CERCLA §103
and 40 C.F.R.
§302.6; EPCRA,
42 U.S.C. §§
11001 et seq.
Federal generator
requirements may
apply based on waste
classification and
generator status.
Certain releases at or
above reportable
quantities require
notification. EPA
states that lead
particles below
specified size and at
EPA or authorized
state agencies may
inspect and enforce.
California is authorized
to administer its
hazardous-waste
program, which may
be more stringent than
federal requirements.
EPA requirements are
conditional and fact-
specific. Whether an indoor
shooting range is subject to
EPA permitting or other
regulatory requirements
depends on the specific
activities, waste streams,
and potential releases
associated with the facility.
37
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
reportable quantities
may trigger release
notification.
California Fire
Code / Local
Fire Code
Official
Fire and life
safety; hazardous
materials; fire
protection
systems; storage
and handling;
emergency
access.
2025 California
Fire Code, Title
24, Part 9,
including
Chapters 9 and
50; locally
adopted
amendments;
Health & Safety
Code and Title
19 as applicable.
Building and
operational fire
permits as applicable;
hazardous-material
classification and
quantity review;
HMMP/HMIS when
required; storage
safeguards;
ventilation where
code-triggered;
automatic sprinklers
or extinguishing
systems when
required; alarm,
access, and
emergency
provisions.
Local fire code official
reviews plans, permits
construction/operations
as authorized, and
inspects for code
compliance.
Fire-suppression and
hazardous-material
requirements are governed
by generally applicable
building and fire codes and
project-specific review and
inspection. These
requirements are
addressed through existing
regulatory processes rather
than through firearm-
specific local standards.
BAAQMD - Air
District
Permitting
New or modified
sources of air
pollution and
associated
control devices;
toxic-air-
contaminant
review.
BAAQMD
Regulation 2,
Rules 1, 2 and
5; applicable
particulate and
toxic rules;
California Health
& Safety Code
air-district
authority.
Authority to Construct
and Permit to
Operate may be
required for a source
or control device
unless exempt.
Permit review
addresses emissions,
toxic risk, and
applicable control
requirements.
BAAQMD reviews
applications, issues
permits, inspects, and
enforces Air District
rules.
No firearm-range-specific
BAAQMD rule was
identified. Referral is
appropriate for a case-
specific determination
regarding ventilation
exhaust, filtration or other
emission sources.
City of Dublin -
Land Use,
Building and
Development
Review
Location, zoning
classification, site
design, building
permits, and local
Dublin Municipal
Code; California
Planning and
Zoning Law;
locally adopted
Zoning clearance or
entitlement; objective
separation standard if
adopted;
building/mechanical/
City departments
enforce local approvals
and adopted codes.
The City's principal added
value is determining where
the use may locate and
ensuring compliance with
generally applicable
38
Agency /
Program
Regulated
Subject
Primary
Authority
Core Requirements Inspection /
Enforcement
Planning Relevance
fire/building
coordination.
building and fire
codes.
electrical permits;
site-specific
conditions within
lawful authority;
referral to regulatory
agencies.
development standards,
not duplicating dealer
licensing or
occupational/environmental
regulation.
Ongoing Inspection and Enforcement. Regulatory oversight continues after a firearms retailer or indoor shooting range begins
operation. Depending on the facility and its operations, applicable requirements may be enforced through Cal/OSHA workplace
inspections, hazardous waste inspections by DTSC or the local CUPA, fire and life safety inspections, and Air District inspec tions where
applicable. The City would continue to enforce its land use approvals and applicable building and fire code requirements, while other
agencies would administer and enforce requirements within their respective areas of responsibility.
39
Authorities and Primary Sources
1. ATF, Federal Firearms Licenses.
https://www.atf.gov/firearms/federal-firearms-licenses
2. ATF, Federal Firearms Licensee Quick Reference and Best Practices Guide.
https://www.atf.gov/firearms/tools-and-services-firearms-industry/current-licensees/federal-
firearms-licensee-quick-reference-and-best-practices-guide
3. ATF, Firearms Compliance Inspections.
https://www.atf.gov/firearms/tools-and-services-firearms-industry/current-licensees/compliance-
inspections
4. FBI, National Instant Criminal Background Check System.
https://www.fbi.gov/how-we-can-help-you/more-fbi-services-and-information/nics
5. California DOJ, Becoming a Firearm Dealer and/or Ammunition Vendor.
https://oag.ca.gov/firearms/dealer-vendor
6. California DOJ, Firearms Dealer Frequently Asked Questions.
https://oag.ca.gov/firearms/dlrfaqs
7. California DOJ, Overview of Key California Firearms Laws.
https://oag.ca.gov/ogvp/overview-firearm-law
8. California Legislative Information, Penal Code, Part 6 – Control of Deadly Weapons.
https://leginfo.legislature.ca.gov/faces/codesTOCSelected.xhtml?tocCode=PEN&tocTitle=+Pen
al+Code+-+PEN
9. California Penal Code § 16151 – Ammunition Vendor.
Defines “ammunition vendor” and provides that a licensed firearms dealer is deemed a licensed
ammunition vendor for purposes of California law.
10. California Penal Code § 30312 – Ammunition Sales and Transfers.
Generally requires ammunition sales and transfers to be conducted by or processed through a
licensed ammunition vendor and contains an exception for ammunition purchased or received at
a licensed target facility when the ammunition remains on the facility premises.
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?article=2.&chapter=1.&division=
10.&lawCode=PEN&part=6.&title=4.
11. California Penal Code §§ 30342–30365 – Ammunition Vendors.
Establishes requirements governing persons and businesses engaged in the sale of
ammunition, including ammunition-vendor licensing and transaction requirements.
12. California Penal Code § 30352 – Ammunition Transaction Records and Target-Facility
Provision.
Requires ammunition vendors to record and electronically submit specified transaction
information and includes provisions applicable to persons purchasing or receiving ammunition at
a licensed target facility when the ammunition remains on the premises.
13. California Penal Code §§ 30370–30372 – Ammunition Purchase Authorizations.
Establishes the California Department of Justice ammunition purchase authorization process.
14. California Penal Code §§ 30385–30395 – Ammunition Vendor Licenses.
Establishes California ammunition-vendor licensing requirements.
15. Cal/OSHA, 8 C.C.R. § 5198 – Lead.
https://www.dir.ca.gov/title8/5198.html
40
16. Cal/OSHA, Occupational Lead Exposure Prevention Guidance.
https://www.dir.ca.gov/dosh/lead/
17. Cal/OSHA, 8 C.C.R. § 5155 – Airborne Contaminants.
https://www.dir.ca.gov/title8/5155.html
18. DTSC, Shooting Range Maintenance Guidance.
https://dtsc.ca.gov/shooting-range-maintenance-guidance/
19. CalEPA, Unified Program.
https://calepa.ca.gov/cupa/
20. CalEPA, Unified Program Laws and Regulations.
https://calepa.ca.gov/cupa/lawsregs/
21. Alameda County Environmental Health, Hazardous Materials / CUPA.
https://deh.acgov.org/
22. U.S. EPA, Release Notification for Lead from Ammunition.
https://www.epa.gov/epcra/release-notification-lead-ammunition
23. 2025 California Fire Code, Title 24, Part 9, Chapter 50.
https://codes.iccsafe.org/content/CAFC2025P1/chapter-50-hazardous-materials-general-
provisions
24. BAAQMD, Regulation 2 – Permits.
https://www.baaqmd.gov/en/rules-and-compliance/rules/reg-2-permits
25. BAAQMD, Regulation 2, Rule 1 – General Requirements.
https://www.baaqmd.gov/en/rules-and-compliance/rules/reg-2-rule-1-general-requirements
26. BAAQMD, Regulation 2, Rule 5 – New Source Review of Toxic Air Contaminants.
https://www.baaqmd.gov/en/rules-and-compliance/rules/reg-2-rule-5-new-source-review-of-
toxic-air-contaminants
41
Attachment 2
SECOND AMENDMENT CASE LAW RELEVANT TO LOCAL LAND USE REGULATION
Decision Holding (Plain English) Planning significance Effect on local zoning authority
United States Supreme Court Decisions
District of
Columbia v.
Heller, 554 U.S.
570 (2008)
The Second Amendment protects an
individual right to possess a handgun
for lawful self-defense. The right is
not unlimited. The Court identified
longstanding limits, including laws
concerning sensitive places and
conditions and qualifications on the
commercial sale of arms.
Establishes the protected
individual right and cautions
against treating firearm regulation
as ordinary policy balancing.
Does not decide firearm-retailer
zoning. Local land use rules remain
subject to the Second Amendment
when they burden protected
conduct.
McDonald v. City
of Chicago, 561
U.S. 742 (2010)
The Second Amendment right
recognized in Heller applies to state
and local governments through the
Fourteenth Amendment.
Local ordinances are subject to the
federal constitutional standard.
Cities may exercise land use
authority, but local enactments must
comply with the Second
Amendment.
N.Y. State Rifle &
Pistol Assn. v.
Bruen, 597 U.S. 1
(2022)
When the Second Amendment’s text
covers the regulated conduct, the
government must show that its
regulation is consistent with the
Nation’s historical tradition of firearm
regulation. Courts may not uphold a
firearm law merely by balancing
public benefits against the burden on
the right.
Requires legal analysis based on
constitutional text and historical
tradition rather than policy
balancing alone.
Objective land use standards are
not automatically valid or invalid.
The practical effect of the regulation
and the conduct it regulates remain
important to the constitutional
analysis.
Wolford v. Lopez,
609 U.S. ___
(2026), reversing
116 F.4th 959
(9th Cir. 2024)
The Supreme Court invalidated
Hawaii’s default rule barring licensed
carry on private property open to the
public without the owner’s express
consent. Applying Bruen, the Court
concluded that the State had not
shown a relevant historical tradition
supporting the broad restriction.
Wolford concerns carrying firearms
on private property, not firearm
sales or business location. It
reinforces that modern firearm
restrictions must be analyzed
under Bruen rather than justified
by policy balancing alone.
Does not decide firearm-retailer
zoning or school buffers. It is
relevant as current Supreme Court
guidance on the Bruen framework,
but should not be cited as direct
authority for or against a land use
separation standard.
United States Court of Appeals for the Ninth Circuit Decisions
42
Decision Holding (Plain English) Planning significance Effect on local zoning authority
Teixeira v. County
of Alameda, 873
F.3d 670 (9th Cir.
2017) (en banc)
Alameda County required firearm
retailers to obtain a conditional use
permit and maintain a 500-foot
separation from specified uses,
including schools. The court rejected
the Second Amendment claim
because the plaintiffs did not
plausibly allege that the ordinance
meaningfully impeded prospective
customers’ access to firearms. The
court also held that a dealer has no
freestanding Second Amendment
right to sell firearms at a chosen
location.
Directly addresses local zoning of
firearm retailers. The practical
effect of the ordinance on
customers’ ability to acquire
firearms was central to the court’s
analysis.
Remains important zoning
precedent, but it predates Bruen
and should not be treated as
establishing a stand-alone
“reasonable sites” test or a
numerical safe harbor for local
buffers.
B & L
Productions, Inc.
v. Newsom, 104
F.4th 108 (9th Cir.
2024), cert.
denied (2025)
The Ninth Circuit held that laws
barring firearm sales on state
property did not implicate the Second
Amendment where they did not
meaningfully constrain any
individual’s ability to keep and bear
arms. The court concluded that
Teixeira’s meaningful-constraint
approach is consistent with Bruen.
Provides the key post-Bruen link to
Teixeira. A restriction on the place
of sale does not necessarily
implicate the Second Amendment
when lawful acquisition remains
practically available elsewhere.
Supports examining the real-world
geographic effect of a location rule.
It does not establish that any
particular buffer distance or amount
of remaining land is constitutionally
sufficient.
Nguyen v. Bonta,
140 F.4th 1237
(9th Cir. 2025)
The Ninth Circuit held that
California’s one-firearm-per-30-days
law meaningfully constrained firearm
acquisition and implicated the
Second Amendment. The court then
found the law inconsistent with the
Nation’s historical tradition of firearm
regulation.
Illustrates the other side of the
meaningful-constraint inquiry: a
direct limit on how often an eligible
person may acquire firearms can
burden protected conduct.
Nguyen is not a land use case and
does not independently validate
zoning restrictions. It reinforces the
importance of evaluating the
practical effect of a regulation on
lawful acquisition.
43
Decision Holding (Plain English) Planning significance Effect on local zoning authority
Rhode v. Bonta,
145 F.4th 1180
(9th Cir. 2025)
The Ninth Circuit held that
California’s ammunition background-
check regime meaningfully
constrained the right to keep and
bear arms. In doing so, the court
expressly contrasted that statewide
regime with Teixeira and B & L
Productions, explaining that a minor
constraint on the precise locations
within a geographic area where
firearms may be acquired does not
necessarily meaningfully constrain
the right.
Provides recent post-Bruen Ninth
Circuit guidance tying Teixeira, B &
L Productions, and Nguyen
together. It emphasizes practical
effect, including the costs, delays,
and geographic scope of a
regulation.
Useful support for documenting the
geographic effect of a proposed
separation standard. It does not
establish that a particular buffer or
percentage of remaining commercial
land is constitutional.
44
Attachment 3
FIREARM RELATED USE REGULATIONS BY JURISDICTION
Comparative Jurisdiction Matrix
Jurisdiction Firearm Sales /
Zoning
Separation
Standard
Local Permit /
Operations
Indoor Shooting
Ranges
Current Primary
Citation / History
Planning and Post-
Bruen Observation
Dublin No firearm-
specific use
classification.
Retailers are
treated as retail
uses; indoor
ranges are treated
as Recreational
Facility/Indoor
uses.
None currently. No firearm-specific
local police permit
identified.
Allowance depends
on the zoning
district applicable to
Recreational
Facility/Indoor uses.
DMC §§ 8.08.020
and 8.12.050;
Ordinance No. 01-
26 (temporary
moratorium).
Baseline condition.
Proposed ordinance
would add objective
location standards
without creating a
new police-permit
program.
Pleasanton Firearm sales
require a permit
from the Chief of
Police and must
comply with
zoning and
business-license
requirements.
No firearm-specific
school separation
identified in
Chapter 6.64.
Firearm Sales
Permit; secured
facility and permit
conditions.
No dedicated
firearm-range
chapter identified;
land use
classification must
be confirmed for a
proposed site.
PMC §§ 6.64.030,
6.64.070 and
related provisions.
Nearby example of a
local permit model.
Dublin staff is not
recommending a
parallel local licensing
system.
Livermore No separate
firearm-retailer
land use
classification
identified in the
reviewed current
development
code.
None identified. No firearm-specific
local dealer permit
identified in the
reviewed current
code.
Gun
ranges/shooting
clubs are
addressed under
recreation/cultural
facility
classifications;
zoning allowance
depends on district
and entitlement
requirements.
Livermore
Development Code
Ch. 3-50; Livermore
Municipal Code Ch.
9.78 (discharge-
related provisions).
Nearby comparator,
but not a direct
school-separation
model.
45
Jurisdiction Firearm Sales /
Zoning
Separation
Standard
Local Permit /
Operations
Indoor Shooting
Ranges
Current Primary
Citation / History
Planning and Post-
Bruen Observation
San Ramon No firearm-
specific retailer
classification
identified in the
reviewed current
zoning code.
None identified. No firearm-specific
dealer permit
identified.
No firearm-specific
indoor-range
standard identified;
generally applicable
land use
classifications and
permits would
govern.
San Ramon Zoning
Ordinance, Title D;
municipal code
provisions
concerning
discharge and
weapons.
Not a direct
comparator for the
proposed zoning
standard.
Pleasant Hill Firearm sales are
subject to a police
permit and
firearm-specific
zoning standards.
150 ft from
residential uses;
1,000 ft from
public/private
schools; 500 ft
from parks, other
firearm sales,
massage
establishments,
and adult
entertainment
uses, subject to
code definitions
and exceptions.
Police permit;
security, insurance,
records, and related
operating
requirements.
No dedicated
indoor-range
standard identified
in the firearm-sales
ordinance.
PHMC Ch. 9.35 and
§ 18.25.160; Ord.
876 (2013),
amended by Ord.
896 (2016).
Direct Bay Area
comparator for a
1,000-ft school
separation. Predates
Bruen and should be
used as planning
context, not a
constitutional safe
harbor.
Fremont Firearm dealers
and gunsmiths are
restricted retail
uses requiring a
conditional use
permit where
allowed.
No firearm-specific
school buffer
identified in the
current cited land
use standard.
Chief of Police
firearms-dealer
permit; security
approval, controlled
storage, employee
requirements,
insurance, and
compliance
provisions.
Indoor ranges may
fall within applicable
recreation
classifications; no
dedicated range
standard identified
in the cited dealer
provisions.
FMC Ch. 5.55 and §
18.190.160; code
history includes Ord.
2081 (1994), Ord. 5-
2008, Ord. 23-2018,
Ord. 02-2020, and
later use-table
amendments.
CUP plus police-
permit model. More
discretionary and
operationally detailed
than Dublin’s
proposed approach.
Alameda
County
Firearm sales
require a
conditional use
permit in
applicable
500 ft from
residentially zoned
property, schools,
day care, liquor
stores, and other
County firearm-
dealer license;
compliance with
federal/state
licensing, building,
A CUP is required
where an indoor
range is allowed
under applicable
County
Alameda County
Code §§ 17.54.130-
17.54.141; Teixeira
v. County of
Alameda, 873 F.3d
Principal Ninth Circuit
firearm-retailer zoning
precedent. Teixeira
predates Bruen;
practical access and
46
Jurisdiction Firearm Sales /
Zoning
Separation
Standard
Local Permit /
Operations
Indoor Shooting
Ranges
Current Primary
Citation / History
Planning and Post-
Bruen Observation
unincorporated
zoning districts
and a County
firearm-dealer
license.
firearm sales
businesses,
subject to code
measurement and
findings.
fire, storage, and
security
requirements.
classifications;
project-specific
confirmation is
required.
670 (9th Cir. 2017)
(en banc).
remaining sites
remain important.
Palo Alto Firearm dealers
require a local
permit and, under
the 2023 zoning
amendments, a
conditional use
permit where
permitted.
Firearm-specific
zoning standards
apply under PAMC
§ 18.42.210;
current definitions,
measurements,
and exceptions
should control.
Permit, investigation,
annual renewal,
business/security
rules, inspection
authority, and
insurance
requirements.
No dedicated
indoor-range
chapter identified.
PAMC Ch. 4.57 and
§ 18.42.210; zoning
provisions adopted
in 2023 after Bruen.
Post-Bruen zoning
amendment. Useful
current comparator,
although the local
program includes
licensing and
operational controls
beyond Dublin’s
recommendation.
Oakland Firearm dealers
require a local
permit and
planning/zoning
compliance.
Distances vary by
protected use
under Oakland’s
current planning
regulations.
Police permit,
security, inventory,
records, reporting,
and inspection
provisions.
No dedicated
current range
standard confirmed
in this review.
OMC Ch. 5.26;
Oakland Planning
Code provisions
applicable to
firearms sales
activities.
Broad regulatory
program. Use only
verified current
provisions that directly
support the City’s
planning analysis.
San Carlos Firearm retailers
are limited to a
designated
Firearm
Establishment
Business Area
and require land
use and law-
enforcement
approvals.
1,000 ft from
residential zoning,
schools, day care,
youth/community
centers, places of
worship, parks,
and specified
firearm-related or
commercial uses.
Law Enforcement
Safety Permit;
security/surveillance,
management plan,
annual renewal,
inspections, and
operating-hour
limits.
Expressly
regulated. Indoor
ranges are limited
to designated areas
and require land
use and safety
permits, a range-
safety officer,
management plan,
and operational
controls.
SCMC Chs. 5.13
and 5.14; Title 18,
including §
18.23.300;
Ordinances Nos.
1540 and 1542
(2019).
Most comprehensive
Bay Area comparator.
Broader than Dublin’s
proposed zoning-only
approach and
adopted before
Bruen.
San Marcos Retail firearm
sales may occur
in conjunction with
an approved
indoor shooting
500 ft for indoor
ranges from child
care, K-12 public
schools, public
parks, residential
Local firearm-dealer
license; CUP
conditions may
address operating
issues and law-
Indoor ranges
permitted in the
Industrial Zone with
a CUP and firearm-
specific standards.
SMMC Ch. 5.60 and
§ 20.40.240.
Relevant indoor-range
comparator. Uses a
discretionary CUP
and a 500-ft
separation.
47
Jurisdiction Firearm Sales /
Zoning
Separation
Standard
Local Permit /
Operations
Indoor Shooting
Ranges
Current Primary
Citation / History
Planning and Post-
Bruen Observation
range; local
licensing
provisions apply
to concealable-
firearm sales.
zones,
bars/breweries,
and other indoor
ranges.
enforcement
recommendations.
Santa Clara Firearm retailers
are treated under
generally
applicable
commercial retail
classifications; no
firearm-specific
use standard
identified in the
reviewed current
zoning code.
None identified. No firearm-specific
local police permit
identified.
No firearm-specific
indoor-range
provision identified.
Santa Clara City
Code Title 18
(Zoning).
General-code
comparator rather
than a model for
firearm-specific
standards.
Concord Firearm-related
retail uses are
subject to
applicable retail
classifications and
may require a use
permit where
specified.
None identified. No firearm-specific
local police permit
identified.
A use permit is
required where the
applicable indoor
recreation/range
classification is
conditionally
permitted.
Concord
Development Code,
Title 18; applicable
land use tables and
use-permit
provisions.
General discretionary
land use model; no
verified school buffer.
Danville Firearm retailers
are treated under
generally
applicable
commercial retail
classifications.
None identified. No firearm-specific
local permit
identified.
No firearm-specific
indoor-range
regulation
identified.
Danville Municipal
Code Title 32
(Zoning), applicable
commercial use
tables.
General-code
comparator.
Walnut
Creek
Firearm retailers
are treated under
generally
applicable retail
classifications.
None identified. No firearm-specific
local permit
identified.
No firearm-specific
indoor-range
regulation
identified.
Walnut Creek
Municipal Code Title
10 (Planning and
Zoning), applicable
use tables.
General-code
comparator.
48
Jurisdiction Firearm Sales /
Zoning
Separation
Standard
Local Permit /
Operations
Indoor Shooting
Ranges
Current Primary
Citation / History
Planning and Post-
Bruen Observation
Chicago,
Illinois
Firearms dealers
are a defined use
requiring a City
firearms-dealer
license and
compliance with
zoning.
500 ft from
primary/secondary
schools and
government-
owned or leased
parks under
current cited
provisions.
Firearms-dealer
license with
eligibility, safety-
plan, operating, and
renewal
requirements.
Shooting range
facilities are
classified as
participant
sports/recreation
uses and are
subject to zoning
and licensing
provisions.
Chicago Zoning
Ordinance §§ 17-
17-0106-C and 17-
4-0200; Municipal
Code Ch. 4-144,
including § 4-144-
750.
Included because
Chicago firearm-
business restrictions
have generated
federal litigation. It is
not a California peer
and should be treated
as supplemental
context.
49
Attachment 4
Commercial and Industrial Land Use Acreage Comparison
General Plan and Specific
Plan Land Use Designations
Existing
Acreage
Available
with 500-ft
School
Available with
1,000-ft
School
Available with
Tobacco
Sensitive-Use
Business Park/Industrial 101 101 95 50
Business Park/Industrial and
Outdoor Storage
60 60 60 21
Campus Office 127 127 103 97
Campus Office/High-Density
Residential
14 14 14 14
Downtown Dublin-Retail
District
113 109 88 81
Downtown Dublin -Transit-
Oriented District
87 51 10 10
Downtown Dublin – Village
Parkway District
31 31 31
20
General Commercial 216 211 203 176
General Commercial/Campus
Office
Use 2/Campus Office
Retail/Office
Retail/Office and Automotive
Total commercial and
industrial acreage
1,136 1,082 947 758
*Tobacco sensitive-use comparison applies a 1,000-foot separation form public and private
elementary, middle, junior high, and high schools and a 500-foot separation from playgrounds,
youth centers, City-owned and operated recreational facilities, parks, and libraries, measured
parcel boundary to parcel boundary, consistent with DMC § 8.43.040(B)-(C). The 1,000-foot
Retail Tobacco Shop-to-Retail Tobacco Shop spacing requirement in DMC § 8.43.040(D) is not
included.
Planning-level totals: 500-foot school separation – 1,082 acres (95%); 1,000-foot school
separation – 947 acres (83%); tobacco sensitive-use comparison – 758 acres (66%).
50
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Future BASIS
Independent
School
StratfordSchool
Dublin HighSchool
Future Shamrock
Hills School TK-8
EmeraldHigh SchoolEnlight
Academy
0 1 Mile
580
680
C A M P P A R K S
PROXIMITY DISTANCE STANDARD 500 ft School Buffer
Date Updated: 8/10/2026
PUBLIC WORKS
100 CIVIC PLAZA
CITY OF DUBLIN
General Plan Land Use
Commercial/Industrial
General Commercial
Retail/Office
Retail/Office and Automotive
Neighborhood Commercial
General Commercial/Campus Office
Campus Office
Campus Office / High-Density Residential
Industrial Park
Business Park/Industrial
Business Park/Industrial and Outdoor Storage
Medical Campus
Medical Campus / Commercial
Mixed Use
Mixed Use 2/Campus Office
Medium/High-Density Residential and Retail Office
Public/Semi-Public/Open Space
Regional Park
Parks/ Public Recreation
Open Space
Stream Corridor
Public Lands
Public / Semi-Public
Semi-Public
Residential
Rural Residential/Agriculture (1 Unit per 100 Gross Residential Acres)
Estate Residential (0.01 - 0.8 du/ac)
Low-Density Single Family (0.5 - 3.8 du/ac)
Single Family Residential (0.9 - 6.0 du/ac)
Medium-Density Residential (6.1 - 14.0 du/ac)
Medium/High-Density Residential (14.1 - 25.0 du/ac)
High-Density Residential (25.1+ du/ac)
Specific Plan Districts
Downtown Dublin - Village Parkway District
Downtown Dublin - Transit-Oriented District
Downtown Dublin - Retail District
Dublin Crossing
Only schools that are within 500 feet of
commercial land use zones are included with a buffer.
Attachment 5500 Foot School Buffer
51
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Future BASIS
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James DoughertyElementary School
Wells
Middle
School Future Shamrock
Hills School TK-8
Cottonwood
Creek School
EmeraldHigh SchoolEnlight
Academy
0 1 Mile
580
680
C A M P P A R K S
PROXIMITY DISTANCE STANDARD 1000 ft School Buffer
Date Updated: 8/10/2026
PUBLIC WORKS
100 CIVIC PLAZA
CITY OF DUBLIN
General Plan Land Use
Commercial/Industrial
General Commercial
Retail/Office
Retail/Office and Automotive
Neighborhood Commercial
General Commercial/Campus Office
Campus Office
Campus Office / High-Density Residential
Industrial Park
Business Park/Industrial
Business Park/Industrial and Outdoor Storage
Medical Campus
Medical Campus / Commercial
Mixed Use
Mixed Use 2/Campus Office
Medium/High-Density Residential and Retail Office
Public/Semi-Public/Open Space
Regional Park
Parks/ Public Recreation
Open Space
Stream Corridor
Public Lands
Public / Semi-Public
Semi-Public
Residential
Rural Residential/Agriculture (1 Unit per 100 Gross Residential Acres)
Estate Residential (0.01 - 0.8 du/ac)
Low-Density Single Family (0.5 - 3.8 du/ac)
Single Family Residential (0.9 - 6.0 du/ac)
Medium-Density Residential (6.1 - 14.0 du/ac)
Medium/High-Density Residential (14.1 - 25.0 du/ac)
High-Density Residential (25.1+ du/ac)
Specific Plan Districts
Downtown Dublin - Village Parkway District
Downtown Dublin - Transit-Oriented District
Downtown Dublin - Retail District
Dublin Crossing
Only schools that are within 1000 feet of
commercial land use zones are included with a buffer.
1,000 Foot School Buffer
52
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C A M P P A R K S
PROXIMITY DISTANCE STANDARD 1000 ft School Buffer 500 ft Buffer *
Date Updated: 7/16/2026
PUBLIC WORKS
100 CIVIC PLAZA
CITY OF DUBLIN
General Plan Land Use
Commercial/Industrial
General Commercial
Retail/Office
Retail/Office and Automotive
Neighborhood Commercial
General Commercial/Campus Office
Campus Office
Campus Office / High-Density Residential
Industrial Park
Business Park/Industrial
Business Park/Industrial and Outdoor Storage
Medical Campus
Medical Campus / Commercial
Mixed Use
Mixed Use 2/Campus Office
Medium/High-Density Residential and Retail Office
Public/Semi-Public/Open Space
Regional Park
Parks/ Public Recreation
Open Space
Stream Corridor
Public Lands
Public / Semi-Public
Semi-Public
Residential
Rural Residential/Agriculture (1 Unit per 100 Gross Residential Acres)
Estate Residential (0.01 - 0.8 du/ac)
Low-Density Single Family (0.5 - 3.8 du/ac)
Single Family Residential (0.9 - 6.0 du/ac)
Medium-Density Residential (6.1 - 14.0 du/ac)
Medium/High-Density Residential (14.1 - 25.0 du/ac)
High-Density Residential (25.1+ du/ac)
Specific Plan Districts
Downtown Dublin - Village Parkway District
Downtown Dublin - Transit-Oriented District
Downtown Dublin - Retail District
Dublin Crossing
Only areas that are within 500 or 1000 feet of
commercial land use zones are included with a buffer.
* 500 ft buffer includes parks, City owned facilities, and day care centers.
1,000 Foot School Buffer and 500 Foot Buffer from Other Sensitive Uses
53
Regulation of Firearm
Retailers and Indoor
Shooting Ranges
City Council Meeting
September 1, 2026
54
Background
•DMC regulates firearm retailers as retail uses, and indoor ranges as
Recreational Facility/Indoor uses.
•Received an inquiry for a retailer/range near BASIS Independent School
-raised land use compatibility concerns.
•Moratorium adopted through January 27, 2027.
•Reviewed federal/state law, Second Amendment case law, other
jurisdictions’ rules, and land use alternatives.
55
Existing Regulatory Framework
•Firearm Retailers
•Permitting (ATF and DOJ)
•Background checks, waiting periods, recordkeeping, secure
storage, inspections, enforcement, etc.
•Gun-Free School Zones (1,000 feet of schools)
•Indoor Shooting Ranges
•Air quality regulations (OSHA and Cal/OSHA)
•Hazardous materials (DTSC)
•Construction requirements
56
Second Amendment / Local Land Use Authority
Court decisions guide how local governments may regulate firearm sales
and ranges:
•Teixeira(2017) —May regulate location if firearm access isn’t
meaningfully constrained.
•Bruen(2022) —Regulations must align with the nation’s historical
tradition of firearm regulation.
•B & L Productions(2024) —Location restrictions OK if firearms remain
available elsewhere.
•Nguyen(2025) —Meaningful constraints on access require further
constitutional review.
57
Comparator Jurisdictions
•14 California jurisdictions and Chicago reviewed.
•Most ordinances predate Bruen(2022).
•Operational licenses/permits generally overlap with federal
and state regulatory activities.
•Separation standards generally address compatibility with
schools and other sensitive uses.
58
Separation Requirements in Other Jurisdictions
Separation requirements are common zoning tool uses to address compatibility
between uses.
150 ft 1,000 ft 500 ft Varies
500 ft 500 ft —500 ft
1,000 ft Varies Varies 1,500 ft
1,000 ft 1,000 ft 1,000 ft 1,000 ft
—500 ft (schools)500 ft (public
parks)—
59
Separation Alternatives Evaluated
Staff evaluated three scenarios, measuring how much commercial and industrial
land would remain available outside the separation areas.
1,082 acres 95%
947 acres 83%
758 acres 67%
60
Policy Options
Firearm-related uses continue under the
current zoning framework, and the proposed retailer and range next to BASIS
Independent School would be allowed.
Leaves 95% of land available, but Staff
believes this separation level would have minimal effect.
Not recommended; it would
significantly reduce available commercial and industrial land (67% remaining).
Consistent with existing
Gun-Free School Zone laws, recognizes schools as sensitive environments, and
preserves 83% of commercial and industrial land.
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Staff Recommendation
•Receive the report and direct Staff to prepare amendments to the
Dublin Municipal Code establishing a 1,000-foot separation
between firearm-related uses and public and private K–12 schools
and evaluate the feasibility of requiring documentation of
compliance with federal and state workplace safety and
environmental regulations during building permit review for indoor
shooting ranges.
62