Response to Home Office Consultation on behalf of:

would contest the proposed changes on the following grounds:

Adverse Impact on Public Safety

The stated purpose of the Firearms Acts 1968 – 1997 is the prevention of crime and the preservation of public safety. On that basis, strongly believes that the public purse ought to bear a substantial proportion of the costs of administering the firearms licensing system since the system is for the wider public good, not just for the shooting community.

Furthermore, the proposed huge increase in fees for clubs is actually counterproductive since it could result in the closure or serious shrinkage of clubs. Within their communities, clubs are centres of volunteering excellence, relying upon unpaid members to serve as officers, administer the considerable paperwork and train new probationary members etc. The existence of a substantial network of clubs is one of the most important contributors to public safety, because the close personal contact within a club serves as one of the best measures to identify those unsuitable for a FAC at an early stage.

Threat to the Sport

Rifle clubs are diverse organisations; many shoot fullbore and smallbore rifles and need Home Office Approval or the Scottish equivalent (HOA) to provide access for their members to club rifles. By applying the proposed fee of £1,050, it will mean an 1150% increase which will drive down the number of clubs purely due to the cost implications, since most clubs operate on a not-for-profit basis. Reducing the number of HOA clubs and increasing the fees to such an extent would:

significantly reduce the opportunities for many to enjoy shooting;

significantly reduce shooting opportunities to those with low incomes, including young shooters, because access to club rifles is critical for the training of probationary members and enabling the instruction of safe handling, marksmanship, range safety etc.;

reduce the number of clubs able to train probationers in safe shooting;

reduce the number of clubs so that those remaining would have larger memberships, resulting in a lower level of contact between club officials and individual club members, thereby making it harder for unsuitable individuals to be identified;

make shooting untenable within universities due to the turnover of committee members requiring University clubs to pay £900 every 6 years and £470 fee annually to change the named individual; and

result in higher membership fees, which in itself will act as a disincentive to take up shooting, especially within smaller clubs.

is also concerned that if such an evidence-based assessment is now not to be used, when firearm and shotgun certificate fees are next examined, then they may be subject to unreasonable rises and further threaten the future of the sport with no benefit for public safety, and a detrimental effect on participation in sport across the community.

Use of Inaccurate Data

Our colleagues at the UK National Rifle Association (NRA) advise us that the NRA has 881 affiliated organisations of which 484 are HOA Clubs. The Home Office has estimated in the paper that there are 434 HOA Clubs. This means that even without taking any other factors into account, the fees proposed will over-recover costs by around 12%. Additionally, the fact that the Home Office can only estimate this number and cannot report an accurate count of the number of HOA Clubs does not provide us with confidence in the statistics provided, and it calls into question the efficiency and/or cost-effectiveness of the systems used. It reinforces the statement that the impact assessment has not been subject to rigorous independent scrutiny. No detailed scrutiny makes it likely that avoidable inefficiencies have been included in the proposed fees.

The Home Office Fees Working Group (which included officials, police Firearms Licensing Managers and representatives from the shooting organisations) has not been reconvened to examine the basis for these proposed fees. During 2013 & 2014, the Group adopted a very rigorous, evidence-based approach, arriving at sustainable figures that were acceptable to all its members. The same exercise has been overlooked and needs to be carried out before any changes in fees can be proposed.

Improper Workload Assessment

The Impact Assessment reports a ratio of Home Office costs (largely constituting of administration) to Police costs (involving background checks, interviews, site visits etc.) incurred of nearly 6:1. The Impact Assessment gives no breakdown of the actual work flow involved in processing a club application. The cost is calculated by estimating a percentage of the total cost of funding the department. This allows no scrutiny of the efficiency or otherwise of the departmental processes and operations. To report that it costs six times as much to process a two page application form compared to the practical and detailed checks on the ground is either grossly inaccurate or reflects massively inefficient systems and processes - with a disproportionate focus on document processing rather than the more meaningful Police checks.

As mentioned earlier in this written response, the value added by volunteers in clubs to the process and the contribution they make to the workload is not only valuable in ensuring public safety, but the financial value of this contribution has been completely overlooked as part of the workload process. As such, the considerable practical value of the contribution made by clubs greatly exceeds the £84 fee currently paid -but this is not identified, considered and costed as part of the assessment process.

In summary, and its members strongly urge the Home Office to reconsider the proposal that has been presented. The licensing scheme helps to maintain public safety and this has been completely overlooked. The proposed increases would hugely impact on the network of clubs across England, Wales and Scotland, who do so much to support and ensure the safe practice of shooting in cooperation with the Police.

In order for there to be any confidence within the shooting community about any proposal on matters of this nature, consider it essential that the Home Office Firearms Working Group be convened as soon as possible to examine all aspects of the scheme, and report back. and our members, in partnership with Scottish Target Shooting, stand ready to support that Working Group in any way necessary.

Yours sincerely,

Response to Home Office Consultation Questions

Summary Response

Business or other organisation

Not applicable

Not applicable

Scotland.

- We are a not-for-profit organisation.

- We are a paying membership organization.

Strong Disagree.

Clubs

challenges these proposals on the following grounds:

- Adverse Impact on Public Safety

- Threat to the Sport

- Use of Inaccurate Data

- Improper Workload Assessment

Consultation Questions

Question 1: Are you responding as?

As an individual (proceed to Q2)

As a business or other organisation (proceed to Q4)

Question 4: Where is the main location of your business or organisation?

England

Wales

Scotland

Other (please specify)

Question 5: What is the nature of your business or organisation’s interest in this consultation? (Selected from options provided)?

We advocate the increased regulation of firearms.

We are a firearms trade or representative body.

We are a not-for-profit organisation.

We are a paying membership organization.

We are not a business.

Question 6: What is the name of your business or organisation?

Question 7: To what extent do you agree that licence holders should pay the full cost of the licence?

Strongly Agree

Agree

Neither Agree nor Disagree

Disagree

Strongly Disagree

Question 8: Are there any specific categories or types of licence holder where a lower fee is warranted (entailing a level of Government subsidy)?

Yes

No

Don’t know

If yes, please specify and give reasons?

Clubs are sources of volunteering excellence, relying upon unpaid members to serve as officers, administer the considerable paperwork and train new probationary members etc. The existence of a substantial network of clubs is a contributor to public safety with the close personal contact in a club serving as one of the best measures to identify those unsuitable for a FAC at an early stage. By applying the proposed fee of £1,050, it will mean an 1150% increase which will drive down the number of clubs purely due to the cost implications, since most clubs operate on a not-for-profit basis.

Also, the value added by volunteers in clubs to the process and contribution they make to the workload is not only valuable in ensuring public safety but the financial value of this contribution has been completely overlooked as part of the workload process. As such, the contribution made by clubs greatly exceeds the £84 fee currently paid but this is not identified, considered and costed as part of the assessment process. For these reasons and many more outlined in a separate written response submitted, strongly feels clubs should be granted a lower fee.

Question 9: Do you have any other comments about the proposals (max 300 words)?

challenges these proposals on the following grounds:

Adverse Impact on Public Safety - The purpose of the Firearms Acts are the prevention of crime and the preservation of public safety. As such, the public purse ought to bear a substantial proportion of the costs since the system is for the wider public good and the existence of a healthy network of clubs of manageable size contributes substantially to public safety.

Threat to the Sport – HOA is primarily sought by clubs to provide access for members to club rifles. By applying the proposed fee of £1,050, it will drive down the number of clubs to such an extent that it would significantly reduce the opportunities for many to enjoy shooting; significantly reduce shooting for low income families; reduce the number of clubs able to train probationers in safe shooting; make shooting untenable within universities; and result in higher membership fees which will act as a disincentive to becoming involved in target shooting.

Use of Inaccurate Data – That the Home Office can only estimate the number of HOA clubs does not provide confidence in the assessment which has not been subject to rigorous independent scrutiny. The Home Office Fees Working Group needs to be reconvened to examine the proposed fees.

Improper Workload Assessment - The Impact Assessment reports a ratio of Home Office costs to Police costs incurred of nearly 6:1, giving no breakdown of the actual work flow involved. There is no scrutiny of the efficiency of the departmental processes and no acknowledgement of the in-kind contribution made by volunteers in clubs to the process.

is also concerned that if such an evidence-based assessment is now not to be used, when firearm and shotgun certificate fees are next examined, then they may be subject to unreasonable rises also and further threaten the future of the sport with adverse implications for public safety.