Offensive Weapons Bill

Written evidence submitted by Keith Charles Howell, Chairman, Frome & District Pistol Club Ltd (OWB21)

The following submission refers to Clause 28 (and Clauses 29 thru 35 arising from that Clause) on High Energy and Manual Release Firearms.


· No evidence has been presented by the Home Office or Bill Draftees that Public Safety will be improved by the proposed banning of these categories of firearms.

· These proposals will not restrict either terrorists or criminals from obtaining their firearms of choice, handguns and semi/fully automatic centre fire rifles.

· The piecemeal banning of firearms from sports shooting, based on calibre and mechanism, has a long history of failure to improve Public Safety in the U.K.

· The firearms covered by Clause 28 of the Bill are already subject to restriction under the Firearms Acts (1968 / 1988 / 1997)

· Firearms Certificate (FAC) holders in the U.K. must show ‘Good Reason’ for each and every firearm they wish to possess and demonstrate regular usage.

· Every FAC holder is subject to criminal, medical and character / social investigation by the Police Authority of their residence area.

· All firearms must be kept securely when not in use (and when in transit) and this security is subject to inspection and the requirements of the Home Office Memorandum of Guidance to the Police (on Firearms).

· These proposed restrictions would limit members of the shooting community from competing internationally and hamper handicapped shooter who cannot utilise other mechanisms thru disability.

· The cost of compensation for those firearms proposed to be banned under Clause 28 is considerably more than that identified by the Home Office.

Introduction to the Author

Keith Charles Howell

Chairman, Frome & District Pistol Club Ltd

The author has continuously held a Firearm Certificate (FAC) since 1981 and has shot all disciplines (Pistol / Gallery Rife / Muzzle Loading / Long Range Rifle / Clay) at local, Club and National level and hold qualifications to act in an Official capacity on both Civil and Military ranges.

In addition to target shooting, he also has in excessive of 30 years’ experience in Deer and Vermin Control and Game shooting on open land.

He has been the Training Officer for Frome & District Pistol Club Ltd (A Home Office Approved Club affiliated to the National Rifle Association) for in excess of 20 years, teaching safe firearms handling and has been the Chairman of this Club for the last 4 years.


1. The basis of the Firearms Acts is that restriction of firearms in the hands of civilians improves the safety of the public.

The Home Office has presented NO evidence that the banning of firearms generating in excess of 1,600 joules of energy or those employing a Manual Release operating mechanism represent either a past or future threat to the general public that would render then ‘especially dangerous’ and require reclassification into Section 5 (Prohibited) of the Firearms Acts.

2. The second assumption for the proposed ban of these categories of firearms is that they MAY fall into the hands of criminals or terrorists.

Criminals and terrorists rely on a supply of ILLEGALLY held firearms either from an existing pool or imported into the U.K. The Home Office has failed to provide ANY evidence that the theft of LEGALLY held firearms represents a current or future threat to either public or Police Officers safety.

3. Firearms legislation in the United Kingdom has a history of restricting availability of firearms to civilian users by targeting either the calibre or type of mechanism used by the firearm in response to an incident, thus:

1968 Firearms Act – response to the death of Metropolitan Police Officers at the hands of armed criminals, later caught and sentenced. The shooting community noted that the 1967 Green Paper that preceded this Act stated that ‘A reduction to a minimum of firearms available to the general public was, in and of itself, a good reason’.

1988 Firearms Act – banned the civilian ownership of centrefire self-loading rifles in response to the Hungerford incident when Michael Ryan shot 16 people (including himself). Subsequent investigation showed that this was a licencing failure as he had no ‘Good Reason’ to be granted an FAC.

1997 Firearms Act – banned the availability of ‘small firearm’ (pistols and revolvers) in response to the Dunblane incident when Thomas Hamilton shot dead children and teachers. The Cullen Report noted that the Police Officer charged with interviewing Hamilton recommended that his FAC was not renewed, but was over-ruled by a more senior officer, another licensing failure. The shooting community noted that part of the Cullen Report were subject to 100 year disclosure clauses, twice that of Cabinet papers – why?

Violent Crimes Act 2002 – restricted the sale or air weapons by post and certain categories of blank firing, imitation and airsoft weapons were restricted in response to an incident where a child was blinded by misuse of an air weapon.

As a result of this piecemeal approach, of which Clause 28 of the Offensive Weapons Bill is a further example, the U.K. now has a set of Firearms laws that are difficult to interpret, leave legitimate users open to inadvertent technical breaches of law and make it difficult for ANYONE to understand (Please See Recommendations, Page 5)

4. The firearms proposed to be banned as ‘especially dangerous’ in Clause 28 are already subject to control under the Firearms Acts.

In the case of the High Energy rifles, the sport of long range shooting requires significant money and time to become proficient. Long Range rifle shooting is a science that requires hours of research, preparation of both equipment and hand loaded ammunition to optimise the performance of both shooter and rifle, and a lot of practice.

It is inconceivable that a terrorist or criminal would be able to utilise such a firearm without some form of previous skill or practice, for which they would have had to have access to an ILLEGAL firearm to become proficient.

The case for Manual Release firearms is similar. Shooters spend both time and effort to optimise their firearms to produce the best possible performance. The ‘fast firing’ attributes of such firearms alluded to by the Home Office in their desire to ban such firearms are a myth – these firearms fire one shot per squeeze of the trigger, the same as any of the other firearms available to the shooting community.

The benefit of such mechanisms becomes apparent where the user has some form of physical disability that precludes the manipulation of more traditional bolt action or lever action mechanisms, for these shooters there are no alternatives, and to restrict their availability is to deny them the opportunity to compete on a level playing field with their more able bodied colleagues.

5. The existing Firearms Acts require all Firearms Certificate holder to demonstrate ‘Good Reason’ for each and every firearm they possess. Good reason is interpreted in the Home Office Memorandum of Guidance as being target or live quarry shooting.

In the case of the firearms under Clause 28 these would only be used for Target Shooting (with the sole exception of some High Energy ‘Dangerous Game’ rifles used abroad). The holder of these categories of firearms would have to be a Full Member of a Registered Target Shooting Club - regulated by the Home Office, in order to possess and use such firearms.

6. Every applicant for a Firearm Certificate must submit to a comprehensive review of their life and their reasons to own ANY firearm before a Certificate is granted and this is subject to review every 5 years with the understanding that ANY action on their part (including motoring offences) resulting in a prosecution would lead to an immediate revocation of their Certificate and the confiscation of their firearms.

Any further (unsubstantiated) restrictions on the type of firearm allowed to be owned is further penalising one of the most law abiding segments of the general public.

7. Firearm security is already comprehensively covered in the Home Office Memorandum of Guidance to the Police (Firearms). All firearms must be held in a locked steel cabinet (CE approved) bolted to the fabric of a dwelling, action parts (Bolts etc., where possible) and ammunition to be separately stored.

All security arrangements are subject to inspection by the Police Licensing Authority and Certificates are not issued unless these conditions are met.

The incidence of firearms stolen from legitimate holders is so low as to be virtually non-existent.

8. The compensation costs associated with the ban are considerably under-estimated at between £1-6 M, It is likely that the Southern Gun Company, a highly innovative company operating in Bodmin, Cornwall and exporting throughout the world– would be put out of business and would be seeking compensation that alone would exceed these estimates.


Members of the shooting community often have to seek advice from the various shooting Associations (BASC, NRA, CPSA etc.) and their Clubs because their visiting Police Authority Firearms Enquiries Officer (FEO) has ether imposed or placed obstacles in the way of grant or renewal of Certificates due to miss-interpretation of the Acts.

There is a complete lack of uniformity and training of the Licensing Authorities staff across the U.K. and this is manifested by significant delays, expense and frustration in the process.

The continued loss of valuable Police resources and time / cost combined with the huge burden placed on the shooting community by attempting to track every single firearm movement and transaction needs to be replaced by a simplified system.

It is time that the whole existing legislation regarding firearms in the U.K was repealed and combined into a single Act that concentrates on the FITNESS of a person to hold firearms and not what mechanism or calibre the firearm uses.

The individual firearms forensic characteristics should be established and retained by the Proof House and thereafter the onus should be placed on the holder to retain evidence of the disposal / transfer of the firearm, in that way any firearm that does get misused can be traced.

Certification could then be simplified by assessing the individual as being fit to hold firearms OF ANY CALIBRE or MECHANISM.


The banning of any firearm by calibre, energy or mechanism has no basis in logic.

The analogy to be used is this – if the maximum speed limit for all vehicles in the U.K. is 70 MPH why do we not limit ALL vehicles to that maximum by law - any Government that proposed that would lose the next election!

The Offensive Weapons Bill contains Clauses that restrict the availability and use of Bladed Weapons and Corrosive Substances and these are widely supported, but the inclusion of firearms, already subject to restrictions, makes no logical sense.

7 July 2018


Prepared 9th July 2018