Home Office Consultation - Last chance to influence

[LeadWasp]

The consultation period for the Home Office consultation paper on Offensive and Dangerous Weapons, which if its conclusions are accepted would ban civilian use of .50 and many other high muzzle energy rifles, is drawing to a close, in fact we have less than 5 days to respond. The following document contains additional information, it is not an exact copy of our previous correspondence. The attachment contains further details on just how flawed this consultation is, and a stark reminder to never accept any figures presented to us without scrutiny.

 

Does this affect you? If you think not, because you don’t use or own an HME type rifle then please bear in mind that one of the concerns raised by the Police is of being ‘outgunned’. Can you consistently hit a figure 11 target at 1000 yards with your 6.5mm or .308? If yes (and I hope the answer is yes) then your calibres could be next. Also, don’t forget the term ‘designed for military use’ as used by the Home Office. If the Home Office later decide that they have a particular dislike of any firearm that falls into this category, then many more firearms could be at risk of prohibition.

 

Any responses will have to be received by the Home Office by the 9th of December.

 

If you have still not yet responded we urge you to do so individually as soon as possible.

 

You response can be sent by email to:

 

Offensive.Weapons.Consultation@homeoffice.gsi.gov.uk

 

The consultation document can be found here:

https://www.gov.uk/government/consultations/offensive-and-dangerous-weapons-new-legislation

 

The “impact assessment” document, which includes the “evidence base” can be found here:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/651758/IA_Firearms.pdf

Edited December 5, 2017 by LeadWasp

[LeadWasp]

Folks this has the potential for the misery to flow down to at least every holder of a rifle capable of firing either .224 or .30 projectiles so it COULD AFFECT YOU!

As the proposals are so poorly worded and thought out they could eventually be applied to any rifle capable of shooting Section 5 ammunition.  So includes for example .223, 22-250, Swifts, 30-06's, .308's.  It may say .50 Cal on the tin but it has a heap of bad news for ALL rifle shooters.

If you are a keeper or a stalker or even just aspire to one day shoot PLEASE TAKE AN INTEREST AND DO YOU BIT to defend your sport. 

thank you.

[CaptainBeaky]

Already done, and written to mp separately.

[7daysinaweek]

I have previously responded.

7diaw

[Wingman]

Can someone share an example of the letter text they have submitted?

[Dogs]

+1 would be handy 

[Newbie to this]

There are a few examples in this thread, but don't copy and paste because someone stated that they don't accept copy and paste letters, there's enough to give a rough idea what to write, copy your MP as well if you like.

Hope this helps

https://forums.pigeonwatch.co.uk/forums/topic/363519-looks-like-50-cal-and-some-22-could-be-going/?page=5&tab=comments#comment-3340862

Edited December 6, 2017 by Newbie to this

[LeadWasp]

Example letter to MP - spacing has been corrupted by cutting the text and there is no 'paste as' on here so apologies

"

Dear

 

Re: Home Office Consultation on New Legislation on Offensive and Dangerous Weapons.

 

I understand that you are my Member of Parliament covering (to be inserted).

 

I write regarding the above consultation of the Home Office, the content of some of which causes me considerable concern.

 

Specifically, within it there is a proposal to move .50 calibre rifles from the requirements of section 1 of the Firearms Act to be placed under section 5 thereof.

 

This would effectively ban the use of .50 calibre rifles by civilians despite their being actively used by many target shooters who regularly compete both in United Kingdom and Internationally.

 

Club officials from the Fifty Calibre Shooters Association (FCSA, a Home Office approved target shooting club) met with the Home Office and it is my understanding that the intent is now to move beyond the scope of the original consultation document placing only .50 calibre rifles under section 5 to including all firearms with the muzzle energy of greater than 10,000 ft/lbs.

 

The “consultation document” and “impact assessment” is emotive, inaccurate, is not evidence-based and would not appear to meet with the Home Office “consultation principles 2016”.

 

I have great concerns that this proposed banning of a variety of rifles used for target shooting in the United Kingdom, which have not been involved in criminal activities in the United Kingdom and are singularly unsuited for this purpose or those of a terrorist nature, is unnecessary, unduly restrictive to legitimate sportspeople, unnecessarily costly for the government and the “thin end of the wedge” with regard to shooting sports in general in the future.

 

I particularly hold this view as the alleged concerns of the Home Office with regard to such target rifles falling into “the wrong hands” can be simply addressed by additional security measures.

 

I write to ask your position on this matter, whether you would oppose such a proposed ban on .50 calibre rifles or firearms over 10,000 ft/lbs and whether your support in this matter can be relied upon.

 

I have attached to this letter an appendix providing details of how to access the “consultation document”, “impact assessment” and some of the reasoning why these documents are misleading and inaccurate.

 

I appreciate that this issue may be of an unfamiliar technical nature to you and should you wish clarification and any points please revert to me.

 

I look forward to hearing from you at your earliest convenience.

 

Yours sincerely,"

 

Additional info:-

Home Office “consultation on new legislation on offensive and dangerous weapons”

 

Synopsis of concerns regarding accuracy and validity.

 

Overview

The Home Office has published a consultation document within which is expressed an intent to move all .50 calibre rifles to section 5 of the firearms act. This would essentially prohibit the civilian ownership of such rifles.

 

The consultation document can be found here:

https://www.gov.uk/government/consultations/offensive-and-dangerous-weapons-new-legislation

 

The “impact assessment” document, which includes the “evidence base” can be found here:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/651758/IA_Firearms.pdf

 

 

Officials from the FCSA having met with the Home Office, it would appear that the intent is to move beyond placing not only .50 calibre rifles under section 5, but to also include ALL firearms with the muzzle energy of greater than 10,000 ft/lbs.

 

It is unclear whether legislation based upon a consultation on one specific issue (i.e .50 calibre rifles) can legally be implemented on another issue (namely firearms over 10,000 ft/lbs muzzle energy).

 

Review of the Home Office guidelines on “consultation principles 2016” indicates that consultation should “give enough information to ensure that those consulted understand the issues and can give informed responses. Include validated assessments of the costs and benefits of the options being considered when; this might be required where proposals have an impact on business or the voluntary sector”.

 

It is further indicated that “consultation should be targeted. Consider the full range of people, business and voluntary bodies affected by the policy, and whether representative groups exist”.

 

At first sight it would appear that were the Home Office to pursue legislation effectively banning firearms with an excess of 10,000 ft/lbs muzzle energy on the basis of the current consultation document, then such “consultation principles” would not have been met.

 

To move forward with legislation prohibiting firearms with the muzzle energy in excess of 10,000 ft/lbs clearly includes a wide range of calibres, not simply .50 which are used for long-range target shooting, but also several smaller calibres and a number of rifles which can be considered as historic firearms of the collectable nature.

 

We understand that the Home Office is already drafting legislation to put forward to Parliament and that it is highly unlikely that they will not pursue some change to firearms legislation.

 

Were this legislation to be passed not only would it affect current and future target shooters utilising such calibres but would, no matter what the official line may be, be the “thin end of the wedge” with regard to the legal ownership of other calibres used in other disciplines, both sporting and target, which would potentially become subject to such legislative changes.

 

By way of example, as in other countries, consideration could potentially be given to calibres of a military nature such as .223, .303 and .308 under the pretext of being particularly dangerous as armour piercing ammunition (although already restricted under section 5 for civilian ownership) has been manufactured in such calibres.

 

This Home Office proposal is thus one which may in due course potentially affect the wider shooting community and should most strongly be resisted.

 

Specific Points

The following points are to hopefully better inform you of the detail of the consultation document, its flaws and highlighting specific issues therein.

 

1. The consultation document refers to .50 calibre rifles, however we have been led to understand that the Home Office proposes to ban all firearms over 10,000 ft/lbs muzzle energy.

 

2. It is stated within the “evidence base” with regard to .50 calibre rifles that “… the ownership by civilians creates a risk of these weapons getting into the hands of either criminals or terrorists”.

 

It would appear that rifles in general are rarely used in criminal activities other than poaching, which the .50 calibre rifles do not lend themselves to, and this appeared to be accepted by the Home Office.

 

There has been no evidence to suggest that such civilian owned rifles as the Home Office is considering banning have been used in any criminal activities in the United Kingdom.

 

It would also appear that other than isolated use by the IRA in the 1990’s .50 calibre rifles have not been used in terrorist activities.

 

50 calibre rifles are in the main very heavy, difficult to transport and conceal due to their size.

 

There appears to be very little evidence from the United States to suggest that in a country in which these firearms are largely unregulated they have been used to any significant extent in either criminal or terrorist activities.

 

3. It is further stated within the “evidence base” that “these rifles were originally designed for military use to allow for firing over long distances in a manner capable of damaging vehicles and other physical capital (referred to in military terms as “materiel”). They are also designed to be able to penetrate armour worn by soldiers. If these rifles were used any criminal capacity it would allow for the penetration of police body armour and defensive protections than would not be possible with lower calibres”.

 

There are various issues with this statement.

 

A. While the .50 calibre round was developed in 1918 as a machine-gun round, the development of rifles chambered for this round was primarily driven by civilians in the early 1980s who led the developments in this field, the American military only adopting this calibre for use in a rifle in 1991.

 

B. The original rifles were designed for target shooting rather than to be “capable of damaging vehicles and other physical capital”.

 

C. They were not designed specifically to penetrate armour worn by soldiers.

 

D. Some smaller calibres have more penetrative capabilities than .50 rifles particularly if using armour piercing ammunition that is already considered section 5.

 

The “anti-material” capability does not relate to the rifle but to the ammunition used. “Anti-material” ammunition such as armour piercing, incendiary or explosive is already prohibited for civilian ownership and use.

 

It is also of note that other calibres of greater than 10,000ft/lbs, for example .460, have not been developed for any anti-material role but primarily for long-range target shooting and the projectiles for such calibres have not been commercially produced for an anti-material purpose.

 

The ammunition and projectiles currently available for civilian use in .50 rifles does not meet the requirements to be considered as armour piercing for military purposes. Stanag 4383  12.7x99 ammunition: “AP projectiles must completely perforate Armour plate 22mm thick in 321/375 Brinell at 100 meters.” 

 

Further to the .50 calibre issues, the concept that all firearms over 10,000 ft/lbs muzzle energy are especially dangerous would appear to have no particular ballistic evidence base. It would appear that the “10,000 ft/lb” muzzle energy proposed limit merely represents a good soundbite rather than being evidence-based in a scientific manner.

 

4. The “evidence base” does not appear to consider that .50 calibre rifles are used simply as target rifles. Members of the FCSA shoot competitively both in the United Kingdom and abroad. Members of the FCSA regularly compete internationally in the World Championships of this calibre representing Britain and have had considerable success over the years.

 

5. It is stated in the “evidence base” with regard to the .50 calibre rifle that “this firearm can deliver a projectile over several miles which can pose a danger to public safety should it be used any criminal capacity”.

 

While a projectile fired at an elevation may theoretically travel some 7000 yards this is potentially only 30% further than a .30 projectile and less distance than many other rounds.

 

The statement, however, can be read as suggesting that the rifle has an elevated degree of accuracy at such a range which is completely inaccurate. This statement is made without any evidence base.

 

The maximum potential effective range of the .50 rifle is in the region of 2000 yards while that of a .308 could be considered in the region of 1500 yards.

 

To shoot at such distances, however, would require considerable training and skill not only with regard to shooting but also interpretation of environmental conditions beyond that would be reasonable to consider within the abilities of most criminals and terrorists.

 

It is also noteworthy that other calibres have far better ballistic capabilities at longer ranges than the .50 rifle.

 

6. In estimating the costs to the government associated with the prohibition of such rifles, only the banning of .50 calibre and more rapid firing rifles has been considered.

 

There has therefore been a considerable underestimate in the potential costs. Firstly it is stated “industry experts have advised that the value of these is likely to range from £3000-£5000”.

 

This is clearly wrong as AI rifles retail for just shy of £8000 and the most recent equivalent of the AMSD rifle was 17,000 Swiss francs which would mean the kit used by one of our members would be just shy of around £18,000 including spare barrels. This would be before consideration was given to recompensing for reloading items only usable for .50 calibre rifles including dies, cases and projectiles.

 

By way of example .50 Amax branded target projectiles currently retail at over £4 each.

 

Financial consideration has also not been given in the “evidence base” to the impact of a 10,000 ft/lb ban to the government and upon firearms dealers.

 

The FCSA have requested an indication from members and others of how much their .50 rifle and associated specific tools and components would require compensation for, and the same information from those who have other firearms that are capable of generating in excess of 10,000 ft/lbs muzzle energy, this would potentially be of use in quantifying the cost to the government.

 

7. In quantifying the “benefits” it is alleged that “the size of calibre or the fire rate of these rifles is likely to mean that were used in a crime there is a significant risk of more deaths or serious injuries than if more conventional types of weapon were used”.

 

This statement is made without any evidence base.

 

It is stated “under the high cost scenarios the policy would need to prevent three homicides over the next 10 years to break even; in the midpoint the policy would need to prevent two homicides, and one in the low estimate”.

 

As detailed earlier there are considerable issues with regard to the accuracy of even the high cost scenario.

 

It is also noteworthy that no evidence is presented to indicate that any homicides would be prevented by this legislation with regard to either .50 firearms or those of over 10,000ft/lbs muzzle energy. Were this to be the case this would nullify the potential financial benefits of prohibition of such firearms.

 

8. On the financial issue it would appear also not to have included the loss of income to the MOD/landmark. The FCSA currently pays £36,000 in range fees.

 

We understand that other clubs would also pay considerable fees to the MOD/landmark. To have a better understanding of such fees and whether range bookings would reduce or cease where there to be to be a ban on .50 rifles or those of over 10,000 ft/lbs would be useful.

 

9. We understand that many individuals who target shoot on field firing ranges stay in remote rural communities to attend such shoots providing income to local communities, restaurants, inns, B&Bs that will see a decline in use were such prohibitions to be brought into legislation.

 

This financial cost does not appear to have been considered in the “evidence base”.

 

10. The Home Office in its impact assessment is stated under the heading of “what policy options have been considered, including any alternatives to regulation? Please justify the preferred option” effectively only two options.

 

The two options they appear to have considered are to “do nothing” or to “prohibit” the civilian ownership of .50 rifles and, by implication from their stated aim, the ownership of any firearm of over 10,000 ft/lbs.

 

This does not appear to have given due consideration to “any alternatives to regulation” as it would appear to have been their obligation.

 

It has been difficult to definitively determine what has driven this proposed legislative change at the specific point in time.

 

It has been indicated that it has come about as a result of the theft of a .50 calibre rifle that was subsequently recovered. It has also been indicated that there are concerns (unattributed) that some terrorist organisation may seek to acquire such a rifle from a civilian source be that their home or en route to a shoot.

 

While we have concerns about the viability of the misuse of such firearms by either criminal or terrorist organisations it would be appropriate to give consideration to addressing potential storage and transport security issues.

 

Various suggestions have been made and we consider the following is potentially appropriate and may possibly assuage the concern of the Home Office that such firearms may fall into the “wrong hands” and preclude requirement for a complete ban on .50 rifles or those over 10,000 ft/lbs.

 

A. A requirement for the bolt to be stored separately from the receiver in a separate safe.

 

B. That the residential premises in which a .50 or over 10,000 ft/lb rifle is stored has a monitored alarm system.

 

C. When the firearm is being transported that the bolt remains with the individual at all times and separated from the rifle.

 

Other suggestions have included the removal of the firing pin, the attachment of a trigger lock and the attachment of the GPS tracking device to the firearm.

 

Such enhanced security could be included in the Home Office Guidance to the police and included as a condition on the individual’s firearm certificate.

 

To take this line of enhanced security would reduce the perceived risks of such firearms falling into the “wrong hands”, avoid the requirement for legislative proposals and action being taken to negate them, reduce the costs to the government while permitting the continued participation of target shooters in a legitimate sporting activity.

 

Conclusion

We would be grateful if you give consideration to the above and should you wish any clarification on any of the points raised please revert to me.

[LeadWasp]

We are very keen that the responses are not identical thus would be grateful, as far as possible, that you do not simply cut and paste but write your own response by email or letter and, if possible, copy to your MP.

 

The points you may wish to consider including in your response could include the following:

 

1. The Home Office guidelines on “consultation principles 2016” indicates that consultation should “give enough information to ensure that those consulted understand the issues and can give informed responses. Include validated assessments of the costs and benefits of the options being considered”.

 

It is further indicated that “consultation should be targeted. Consider the full range of people, business and voluntary bodies affected by the policy, and whether representative groups exist”.

 

Our view is that the consultation document is not evidence based, does not meet the standards required by the Home Office under its own “consultation principles” and is thus invalid and should be abandoned for the following reasons:

 

(a) The consultation refers to .50 rifles of a "materiel destruction" type. It appears through discussion to have been extended to include all firearms with a muzzle energy of over 10,000 ft/lbs.

 

On the basis of the current consultation document it would not appear that the Home Office are pursuing legislation effectively banning firearms with an excess of 10,000 ft/lbs muzzle energy.

 

To move forward with legislation prohibiting firearms with the muzzle energy in excess of 10,000 ft/lbs clearly includes a wide range of calibres, not simply .50 which are used for long-range target shooting, but also several smaller calibres and a number of rifles which can be considered as historic firearms of the collectable nature, the owners and users of which have not been "targeted".

 

(b) Were it to be limited to a single calibre, namely .50, this would still include many older calibres and other sporting rifles the users and owners of which have not been targeted.

 

(c) The use of the term "materiel destruction" with regard to the .50 rifle, is in itself inaccurate through omission of the fact that to fulfil this role requires ammunition that is already prohibited under Section 5 of the firearms act and thus the legally held rifles cannot be used for this purpose. The term ‘material destruction’ is purely a marketing term used by firearms manufacturers, there is no legal definition and a technical definition is somewhat ambiguous.

 

Such an omission precludes those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

(d) It is further stated within the “evidence base” that “these rifles were originally designed for military use to allow for firing over long distances in a manner capable of damaging vehicles and other physical capital (referred to in military terms as “materiel”). They are also designed to be able to penetrate armour worn by soldiers. If these rifles were used any criminal capacity it would allow for the penetration of police body armour and defensive protections than would not be possible with lower calibres”.

 

There are various issues with this statement.

 

A. While the .50 calibre round was developed in 1918 as a machine-gun round, the development of rifles chambered for this round was primarily driven by civilian competitive target shooters in the early 1980s who led the developments in this field, the American military only adopting this calibre for use in a rifle in 1991.

 

B. The original rifles were designed for target shooting rather than to be “capable of damaging vehicles and other physical capital”.

 

C. They were not designed specifically to penetrate armour worn by soldiers.

 

D. Many smaller calibres under 10,000 ft/lbs muzzle energy have more penetrative capabilities than .50 rifles, particularly if using armour piercing ammunition that is already prohibited for civilian use under section 5.

 

E. The “anti-material” capability does not relate to the rifle but to the ammunition used. “Anti-material” ammunition such as armour piercing, incendiary or explosive is already prohibited for civilian ownership and use. When used with conventional ball or target ammunition the rifle does not have any anti material capability above and beyond that of any other high velocity large calibre rifle.

 

F.  Other calibres of greater than 10,000ft/lbs, for example .460, have not been developed for any anti-material role but primarily for long-range target shooting and the projectiles for such calibres have not been commercially produced for an anti-material purpose.

 

G. It is also of note that a .50 calibre rifle using standard ‘ball’ ammunition can generate under 10,000 ft/lbs of muzzle energy if manufactured with a shorter barrel.

 

Not to have included such information within the consultation document could reasonably be considered to be misleading and preclude those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

 

(d) Not to have expanded upon the recognised civilian use of this calibre for sporting purposes, namely target shooting in which members of the FCSA shoot at an international level which they will no longer be able to do also precludes those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

(e) It is stated within the “evidence base” with regard to .50 calibre rifles that “… the ownership by civilians creates a risk of these weapons getting into the hands of either criminals or terrorists”.

 

This does not appear to be evidence based at all within the document.

 

Indeed the failure to mention that official UK statistic show that rifles feature in less than 1% of firearms crime which should be known to the authors of the consultation document (in the main poaching and simple unauthorised possession), could reasonably be considered to be misleading and preclude those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

We note the failure to mention the virtual lack of any criminal use of .50 rifles and absolute lack of terrorist use in the USA where such firearms are freely available (in many States including ammunition of of an anti material capability that is already banned in the UK) which would also indicate the impractability of using such rifles in these activities that are raised as potential concerns in the consultation document.

 

Such an omission could reasonably be considered to be misleading and preclude those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

(f) With regard to the cost of implementing such proposals would be the Home Office has made an gross error of considerable magnitude.

 

The consultation document makes a simple statement that the value of these rifles lies between £3,000 and £5,000.

 

This is simply incorrect and again misleading. 

 

Many of the rifles are far more costly and the figure does not take account of the ancillary gear that would have to be compensated for including dies, cartridge cases, carrying cases, ammunition, projectiles, scopes if dedicated to this rifle, long range mounts and even some presses. The cost of such items in .50 calibre is considerably above that of smaller calibres. One member recently costed his equipment solely for .50 shooting at over £50,000 and probably considerably more. (You may wish to total up how much your dedicated gear would be to include in your response).

 

The costing also does not include other .50 rifles that may be caught under the proposed ban.

 

The above would indicate that that the Home Office has failed to "Include validated assessments of the costs and benefits of the options being considered”. As such if has failed to "give enough information to ensure that those consulted understand the issues and can give informed responses".

 

(g) To extend the ban to all firearms of over 10,000 ft/lbs would encompass a considerable and unquantified number of other firearms and ancillary equipment the compensation cost of which has not be included in the costing at all.

 

In not do so the Home Office has failed to "Include validated assessments of the costs and benefits of the options being considered”. As such if has failed to "give enough information to ensure that those consulted understand the issues and can give informed responses".

 

(h) Furthermore on the financial issue it would appear also not to have included the loss of income to the MOD/landmark. The FCSA currently pays £36,000 in range fees.

 

We understand that other clubs would also pay considerable fees to the MOD/landmark. 

 

To extend the ban to firearms of over 10,000 ft/lbs would further exited such costs that have not been evaluated or included in the impact assessment .

 

In falling  to do so the Home Office has failed to "Include validated assessments of the costs and benefits of the options being considered”. As such if has failed to "give enough information to ensure that those consulted understand the issues and can give informed responses

 

(I) We also understand that many individuals who target shoot on field firing ranges stay in remote rural communities to attend such shoots providing income to local communities, restaurants, inns, B&Bs that will see a decline in use were such prohibitions to be brought into legislation.

 

This financial cost does not appear to have been considered in the “evidence base”.

 

In falling  to do so the Home Office has failed to "Include validated assessments of the costs and benefits of the options being considered”. As such if has failed to "give enough information to ensure that those consulted understand the issues and can give informed responses

 

(j) The Home Office includes a costing based upon number of lives saved over a period of time indicating the number of lives that would require to be saved given their estimates of the costs to seemingly break even.

 

Firstly, no evidence base what so ever is presented to indicate how many, if any, lives would be saved were the policy to be implemented.

 

Secondly, two firearms groups are lumped together (MARS and .50) with no differentiation between them as to this issue.

 

Thirdly, given the gross inaccuracy of the cost estimates as detailed above, this component of the Impact Assessment is rendered meaningless.

 

The Home Office states in  the “Benefits” section of the “Evidence Base” that “On average, there were 45 firearm related deaths per year between 2004/2005 – 2014/2015”.  This is misleading as the vast majority are not committed using a legally held firearm, even less so a rifle and there are no known civilian deaths attributable to a legally held .50 rifle, all facts that should have been readily available to the Home Office in its preparation of this proposal.

 

One of our members has prepared an evidence based assessment on this point (attached) which indicates that at best the prohibition of .50 rifles would take over 7,500 years to prevent one death.

 

As such the Home Office has failed to "Include validated assessments of the costs and benefits of the options being considered”.  As such it has also failed to "give enough information to ensure that those consulted understand the issues and can give informed responses".

 

(k) It is stated in the “evidence base” with regard to the .50 calibre rifle that “this firearm can deliver a projectile over several miles which can pose a danger to public safety should it be used any criminal capacity”.

 

While a projectile fired at an elevation in the region of 30 degrees may theoretically travel some 7000 yards this is potentially only 30% further than a .30 projectile and less distance than many other rounds.

 

The statement, however, can be read as suggesting that the rifle has an elevated degree of accuracy at such a range which is completely inaccurate. This statement is made without any evidence base.

 

The maximum potential effective range of the .50 rifle is in the region of 2000 yards while that of a .308 could be considered in the region of 1500 yards.

 

To shoot at such distances, however, would require considerable training and skill not only with regard to shooting but also interpretation of environmental conditions beyond that would be reasonable to consider within the abilities of most criminals and terrorists

 

It is also noteworthy that other calibres have far better ballistic capabilities at longer ranges than the .50 rifle.

 

Beyond the concerns highlighted earlier with regard to potential criminal use being highly unlikely to have not not evidenced or qualified such an assertion with factual information the consultation document could reasonably be considered to be misleading and preclude those without specialist knowledge to "understand the issues" and thus "give an informed response".

 

2. There are a couple of other issues of note to be considered:

 

(a) Further to the .50 calibre issues, the concept that all firearms over 10,000 ft/lbs muzzle energy are especially dangerous would appear to have no particular ballistic evidence base. It would appear that the “10,000 ft/lb” muzzle energy proposed limit merely represents a good soundbite rather than being evidence-based in a scientific manner

 

(b) In quantifying the “benefits” it is alleged that “the size of calibre or the fire rate of these rifles is likely to mean that were used in a crime there is a significant risk of more deaths or serious injuries than if more conventional types of weapon were used”.

 

This statement is made without any evidence base.

 

3. Possible options to suggest.

 

While we believe that there is absolutely no reason for there to be any changes made to the legislation regarding .50 rifles or those with over 10,000 ft/lbs muzzle energy there is the possibility that the Home Office may not agree with us and feel the need for whatever reason, misguided or simply political, to do or be seen to do "something".

 

Given this, you may wish to consider the following in your response.

 

The Home Office in its impact assessment is stated under the heading of “what policy options have been considered, including any alternatives to regulation? Please justify the preferred option” effectively only two options.

 

The two options they appear to have considered are to “do nothing” or to “prohibit” the civilian ownership of .50 rifles and, by implication from their stated aim, the ownership of any firearm of over 10,000 ft/lbs.

 

This does not appear to have given due consideration to “any alternatives to regulation” as it would appear to have been their obligation.

 

It has been difficult to definitively determine what has driven this proposed legislative change at the specific point in time.

 

It has been indicated that it has come about as a result of the theft of a .50 calibre rifle that was subsequently recovered. It has also been indicated that there are concerns (unattributed) that some terrorist organisation may seek to acquire such a rifle from a civilian source be that their home or en route to a shoot.

 

While we have concerns about the viability of the misuse of such firearms by either criminal or terrorist organisations it would be appropriate to give consideration to addressing potential storage and transport security issues.

 

Various suggestions have been made and we consider the following is potentially appropriate and may possibly assuage the concern of the Home Office that such firearms may fall into the “wrong hands” and preclude requirement for a complete ban on .50 rifles or those over 10,000 ft/lbs. We propose a layered approach to security, taking into account the threat and risk, a proportionate response would comprise of the following actions:

 

A. A requirement for the bolt to be stored separately from the receiver in a separate safe.

 

B. That the residential premises in which a .50 or over 10,000 ft/lb rifle is stored has a monitored alarm system.

 

C. When the firearm is being transported that the bolt remains with the individual at all times and separated from the rifle.

 

D. Range booking dates and locations will no longer be publicised on the website, these will be in a secure area for verified members only.

 

Such enhanced security as outlined in points A, B & C above could be included in the Home Office Guidance to the police and included as a condition on the individual’s firearm certificate and avoid the imposition of legislative change.

 

To take this line of enhanced security would reduce the perceived risks of such firearms falling into the “wrong hands”, avoid the requirement for legislative proposals and action being taken to negate them, reduce the costs to the government while permitting the continued participation of target shooters in a legitimate sporting activity.

 

Consideration could also be given to requiring that all applicants for a variation of their FAC for a .50 BMG rifle to be required to be a member of the FCSA and be certified as having gone through a yet to be determined training syllabus on safe use and security.

 

4. Regarding MARS.

We have huge sympathy for our sporting colleagues who use what the Home Office seem to term "fast firing" rifles.

As we have put ourselves, the FCSA, forward as representing the .50 (and by implication other high powered rifles) to the Home Office, which they appear to have accepted, we feel we cannot specifically address the issue of the "fast firing" rifles without diluting the validity of the opinion we put to the Home Office.

 

We have asked one of our members XXX to put forward suggestions on how to address the concerns of this group, as many of our members own such firearms, please contact XXX for further information.

 

Many of you will have seen the robust response from the NRA, that addresses both the .50 and MARS issues, to the consultation document which we wholeheartedly support. 

 

5. Conclusion

We would be grateful if you give consideration to the above. Feel free to circulate to colleagues and clubs who also enjoy shooting sports of any nature. We would appreciate any constructive comments or suggestions that may help mitigate against the imposition of legislation that would be restrictive to shooting sports at this time and be the “thin end of the wedge” with regard to the broader shooting community.

 

In particular we would be most grateful if people could be proactive in taking legitimate action against such proposals even if this includes doing things against their natural habits such as responding to this consultation document.

[The Mighty Prawn]

Got my reply from my MP yesterday, didn't mention anything at all about my questions and instead talked about Hungerford and Dunblane and how many lives have been saved as a result of that legislation!

Am replying tonight to point out not accepting question time avoidance strategy and want to know why despite zero evidence or reasoning they are pursuing this matter - will let you know if anything useful comes back

Although interestingly I now have a signed letter from an MP that states 'the handgun ban will never be reversed' so that's good to know!

[Breastman]

Filled in the ticky box part (and got 8 others to do it as well - just sat them in front of my laptop and 'made' them fill it in ), wrote to the official consultation email address and to my MP. Likely wasting my time but if you don't take part you can't complain about the result!

[LeadWasp]

1 hour ago, Breastman said:

Filled in the ticky box part (and got 8 others to do it as well - just sat them in front of my laptop and 'made' them fill it in ), wrote to the official consultation email address and to my MP. Likely wasting my time but if you don't take part you can't complain about the result!

+1 Absolutely right and thank you for your powers of persuasion.

It is the loose wording, poor logic and gross generalisations in the proposals that open the door to function creep and the eventual wider application of any legislation.  Frankly anyone with any rifle should be doing something about this.

I'm staggered by the apathy across the board - and after shooters marched in London for the CA Tim Bonner/Liam Stokes remarks are disgraceful in their narrow mindedness. " to ensure that lawful stalking and pest control were able to continue unaffected "  They might simply be representing their members but they need to remember that others represented THEM in their hour of need.

[Breastman]

I hold shooters with that attitude with more contempt than out-and-out antis 

[LeadWasp]

Shooting is a broad church yet every coven is remarkably intolerant of, and disinterested in,  the others.