Written evidence submitted by Mr Bob Meadows
1.0 EXECUTIVE
SUMMARY
1.1 Currently police forces manage the issue,
variation and renewal of both Firearms Certificates and Shotgun
Certificates, with different processes and costs that do not reflect
the actual expenses incurred by the force. This submission recommends:
The abolition of the Shotgun Certificate and migration
of shotguns onto a single Firearms Certificate to authorise Section
1[1]
and Section 2 firearms.
Increased application charges to reflect actual costs.
Application fee increases reviewed every five years,
to reflect actual cost increases/decreases.
Introduction of a "good reason" to hold
a shotgun.
The commissioning of a new Home Office Guidance to
the Police (based upon the 2002 version).
1.2 These changes will facilitate police forces
around the country to recover their costs, caused by the firearms
and shotgun licensing process and introduce a sensible control
on the ability for any member of the public to have a shotgun.
2.0 BACKGROUND
2.1 Certificates in General
2.1.1 Firearms Certificates (FACs) and Shotgun
Certificates (SGCs) are granted by police forces on submission
and approval of an appropriate application form, references, fees
and a visit to review the application and inspect security.
2.1.2 Five years after the initial grant of a
certificate, a renewal process must be undertaken to confirm the
current status of the grantee, re-check currently held firearms
and storage facility.
2.1.3 The renewal process involves a physical
visit from a Firearms Enquiry Officer (FEO), who holds the interview
at the applicant's premises for storage.
2.1.4 The role of the police is not to restrict
the granting of authorities, but to ensure appropriate checks
are made according to the statutory laws, rules and guidance.
2.2 The Shotgun Certificate (SGC)
2.2.1 The SGC can be applied for by any person
(who is not a prohibited person) and can obtain two referees that
have known them for two or more years. On being granted a SGC,
that person can purchase Section 2 shotguns and ammunition, as
they please.
2.2.2 There is no need to provide a good reason
for having a shotgun, although Police Firearms Enquiry Officers
(FEOs) will no doubt ask.
2.2.3 SGCs are presented to a seller of a Section
2 Shotgun and/or ammunition, when any transaction regarding those
items is undertaken.
2.2.4 The seller/transferor/lender of a Section
2 shotgun will add the item to the new holder's certificate.
2.2.5 Section 2 ammunition only needs the SGC
shown to the seller or transferor, to confirm its existence and
validity.
2.3 The Firearms Certificate (FAC)
2.3.1 The FAC can be applied for by any person
who is of an appropriate age, who is not a prohibited person,
has a valid reason and can find two referees that have known them
for two or more years.
2.3.2 An FAC permits an approved person to hold
Section 1 firearm and/or ammunition, which may include shotguns
and shotgun ammunition that do not fall within Section 2 of the
1968 Act (as amended).
2.3.3 An FAC is presented to a seller/transferrer/lender
of a Section 1 Firearms and/or ammunition, when any transaction
regarding those items is undertaken.
2.3.4 The seller/transferrer/lender of a Section
1 Firearm will add the item(s) to the new holder's certificate,
only if an authority has been granted for that calibre and type
of weapon or ammunition.
2.3.5 Section 1 ammunition purchase/transfer
needs the FAC to be given to the seller, transferor or lender,
to:
Allow purchase volume to be checked.
To have the ammunition transfer added to the FAC.
To confirm the FACs existence and validity.
2.4 Registered Firearms Dealer Certificates
2.4.1 Any person or company that wishes to trade
in firearms, shotguns, air weapons or ammunition, must be registered
to do so. That authority is known as a Registered Firearms Dealer
Certificate (RFD).
2.4.2 An RFD lasts for three years and is applied
for in a similar way to a FAC.
2.4.3 To obtain authority to trade as an RFD,
the applicant must have:
Be an appropriate person.
Be able to demonstrate the fulfilling of a public
need.
Be able to demonstrate a business plan.
Have a suitable storage area and appropriate security
for any firearms.
2.4.4 FEOs can call upon the services of the
force Safety Officer to provide expert advice on secure storage
areas used by RFDs.
2.5 Visitor Certificates
2.5.1 Visitor Certificates are issued by the
local force for temporary visitors to the United Kingdom, to allow
them to bring in firearms for use in the local area.
2.5.2 Visitors Certificates between for between
six and 20 persons (applied for at the same time) currently attract
a single maximum charge, whatever the total number of visitors
being applied for.
3.0 ISSUES
3.1 Cost of Processing
3.1.1 Currently, forces are not recovering the
cost of processing requests for Firearms and Shotgun related licensing,
as charges were last set in 2001[2].
3.1.2 Bedfordshire Police have analysed their
costs and believe the 2010 cost to grant a Firearms Certificate
is more like £130 per new application (see table below).
Table 1
CHARGES AND COSTS OF FIREARMS CERTIFICATION
| Description | Charge to Applicant
| Actual Est. Processing Cost |
| | |
| Firearms Certificate | |
|
| Application and Grant of FAC | £50
| £130 |
| Renewal of FAC | £40 |
£130 |
| One-for-one Variation of FAC | £0
| £25 |
| Variation of FAC | £26
| £50 |
| | |
| Registered Firearms Dealer |
| |
| Application and Grant of Full RFD | £150
| £500 |
| Temporary Transfer-in Full RFD | £12
| £50 |
| Renewal of Full RFD | £150
| £500 |
| | |
| Registered Firearms Air Weapons Only Dealer
| | |
| Application and Grant of Air Weapons Only RFD
| £150 | £250 |
| Renewal of Air Weapons only RFD | £150
| £250 |
| Temporary Transfer-in for Air Weapons only RFD
| £12 | £50 |
| | |
| Visitors Permit[3]
| | |
| Application and Grant of single Visitors Permit
| £12 | £25 |
| Application and Grant of 6+ Visitors Permits
| £60 | See individual rate
|
3.2 Cost to Applicant
3.2.1 Firearms users have not experienced any increase in
charges for their certification, since 2000.
3.2.2 Even in 2000, the charges generated were in no way representative
of the actual cost to forces processing the applications.
3.2.3 The current £50 charge for a FAC or SGC equates
to circa £10 per annum, 20p per week or 3p per day for the
facility.
3.2.4 Applicants are asked to renew their licenses every five
years for SGC/FAC holders and every 3 years for RFD holders.
3.2.5 Applicants who and not granted their applications, currently
have their fees returned.
3.3 Multiple Applications and Certificates
3.3.1 If an applicant is granted both an FAC and SGC, the
SGC is currently discounted by 80%, as much of the processing
can be done at the same time. This discounting is granted if the
SGC is coterminous with the FAC.
3.3.2 Both certificates must be synchronised in validity,
to enable renewal processing to be reduced in cost.
3.3.3 If an FAC holder wishes to purchase a Section 2 Shotgun,
this cannot be done without a SGC being applied for, authorised
and issued. An FAC holder could, alternatively to vary their FAC
to allow the purchase of a Section 1 shotgun at renewal time for
no charge.
3.4 Variations
3.4.1 When a holder of an FAC wants to purchase an additional
firearm, this must be pre-authorised through the Variation process
by the Firearms Licensing Manager, ensuring it is appropriate
to be purchased and stored.
3.4.2 Any Variation of an FAC is a chargeable event, unless
one of the following is true:
It is done at certificate renewal time.
An existing firearm has recently been disposed of and an application
has been approved to retain that authorisation.
A firearm of that type and calibre has already been authorised
to be acquired.
3.4.3 Shotguns are not currently limited by number on an SGC.
3.4.4 Most FAC Variations can be done without an FEO visit.
3.5 Good Reason
3.5.1 The application for a SGC does not currently have to
demonstrate "good reason" for wanting a shotgun.
3.5.2 Good Reason might include:
Shooting vermin, game etc. on land over which the application
has gained and can demonstrate authority.
Clay Pigeon Shooting at a Home Office Approved or Affiliate to
an appropriate National organisation.
Professional use in the course of their employment.
3.6 Notification of Transfers
3.6.1 Currently, notifications of transfers are mainly done
by fax or post. This requires multiple keying of data and does
not take advantage of an electronic notification process.
3.6.2 Both the Transferor and Transferee currently notify
police forces.
3.7 Section 1 Shotguns and Police Officers
3.7.1 If a Police Officer stops a certificate holder with
a Section 1 Shotgun, the officer probably has no idea whether
the item is Section 1 or Section 2, thus no idea whether the holder
needs an FAC or SGC.
3.8 Home Office Guidance
3.8.1 The 2002 issued document "Firearms Law—Guidance
to the Police" is a useful document for both the Police and
certificate holders.
3.8.2 This Home Office guidance is outdated and would benefit
from being refreshed.
4.0 RECOMENDATIONS
4.1 Implement a single Firearms Certificate (FAC)
4.1.1 Implement a single Firearms Certificate to replace the
current SGC and FAC. The concept of co-terminus certificates would
be unnecessary.
4.1.2 All firearms and shotguns would be listed on the new
FAC, as would authorisations of ammunition to be purchased and
held.
4.1.3 Shotguns should be treated like firearms and have authority
to acquire for shotguns to be purchased on the certificate.
4.1.4 As a shotgun is disposed of, an authority to acquire
could be opened (if requested) through a one-for-one variation
process. This is common in the current FAC environment.)
4.1.5 Firearms Enquiry Officers (FEOs) could recommend an
appropriate level of shotguns that would be able to be securely
held, after the visit to the firearm storage location.
4.2 Implement a new RFD-AIR (RFD-Air)
4.2.1 Implement a new form of RFD, which only allows the holder
to deal in Air Weapons, thus has reduced security requirements.
4.2.2 Charges for initial grant and renewal of an RFD-Air
would be reduced from a full RFD.
4.3 One for One Variations become chargeable
4.3.1 Introduce a charge for one-for-one variations, due to
the administration being caused in the Firearms License Management
Department.
4.3.2 One for One variation requests should be allowed within
30 days of the disposal of a shotgun or firearm.
4.4 Remove the multiple Visitor Permit charge
4.4.1 Introduce a single charge level for Visitor Permit issue,
which is in direct proportion to the number of Visitor Permits
required. For example for 10 permits, 10 times the single permit
charge would be required.
4.5 Introduce the requirement for having good reason for
owning a Shotgun
4.5.1 No longer will it be permissible to have a shotgun,
without having good reason.
4.5.2 Good reason would be demonstrated by the same criteria
as current FAC holders have to provide, such as Game/Vermin, Target
shooting at an approved venue/club or professional use (e.g. employment).
4.6 Align minimum ages for Firearms and Shotguns
4.6.1 By re-aligning shotguns as Section 1 Firearms, all the
current restrictions of ages for firearms holders will apply to
shotgun holders.
4.6.2 This avoids the need for Firearms Licensing Departments
having to make judgement calls of young people, such as 10 year
olds.
4.7 Increase charges to cover costs
4.7.1 Charges for FACs and RFDs should be increased as follows:
Table 2
PROPOSED CHARGES FOR THE NEW RFD AND FACS
| Description | Current Charge to Applicant
| Proposed New Charge to Application |
| | |
| Firearms Certificate | |
|
| Application and Grant of FAC | £50
| £150 |
| Renewal of FAC | £40 |
£150 |
| One-for-one Variation of FAC | £0
| £25 |
| Variation of FAC | £26
| £50 |
| | |
| Registered Firearms Dealer |
| |
| Application and Grant of Full RFD | £150
| £500 |
| Temporary Transfer-in Full RFD | £12
| £50 |
| Renewal of Full RFD | £150
| £500 |
| | |
| Registered Firearms Air Weapons Only Dealer
| | |
| Application and Grant of Air Weapons Only RFD
| £150 | £250 |
| Renewal of Air Weapons only RFD | £150
| £250 |
| Temporary Transfer-in for Air Weapons only RFD
| £150 | £50 |
| | |
| Visitors Permit | |
|
| Application and Grant of single Visitors Permit
| £12 | £25 |
| Application and Grant of 6+ Visitors Permits
| £60 | Charged at Individual Rate
|
4.7.2 Following the submission of an Application for Grant/Renewal/Variation,
no refund will be allowed, once the application is received.
4.8 Migrate towards an online smartcard based service
4.8.1 Through the replacement of the paper-based FAC system
which is currently in place, with a smartcard based system, RFD
holders could perform checks and transactions on-line and save
the multiple keying of information by users and Firearms Licensing
Departments.
4.8.2 Smartcards could be dynamically updated, when read to
perform RFD transactions, from both the current transactions and
any previous manual transactions that had been updated centrally.
4.8.3 The need to send paper copies of transactions to RFD
and FAC licensing departments would be removed, as both the smartcard
and central database would be synchronised each time an FAC smartcard
was connected at and RFD location.
4.9 Implement a requirement for Public Liability
4.9.1 Users of Firearms and shotguns generally belong to clubs
and associations that provide 3rd party liability,
providing them cover in the event of an accident.
4.9.2 Evidence of this insurance should be a requirement at
application, renewal and variation to demonstrate protection of
the general public in the event of any incident.
4.10 Commission the update for the Home Office Guidance
4.10.1 Request the updating of the 2002 issued document "Firearms
Law—Guidance to the Police".
4.10.2 The update would provide suitable guidance, based upon
the statutory changes since 2002 and consequences of this Inquiry.
5.0 CONCLUSION
5.1 The opportunity to rationalise the firearms license management
into a single stream system should be taken advantage of, at this
time of change.
5.2 The additional opportunity to re-align charges for issue/renewal/variation
of Firearm Certificates, Registered Firearms Dealer authority
and Visitor's Permits is proportional and a realistic reflection
of the increase in costs since the last fee change in 1988 and
2000 respectively.
5.3 Without these increases in charges, Firearms Licensing
Departments will continue to be "cost centres", whereas
they should be "cost neutral" services.
5.4 Charges for FACs are proposed, which will increase charges
from 3p per day to 9p per day. This is a proportionally realistic
charge for the facility to hold firearms.
5.5 Charges for RFDs are also proportionately increased, with
a request for a new type of RFD, for air weapons only.
29 July 2010
1
1968 Firearms Act (as amended). Back
2
Firearms (Variation of Fees) Order 2000. Back
3
Visitors Permit Fees have not been changed since the 1988 Firearms
(Amendment) Act (Section 17.8). Back
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