Offensive Weapons Bill

Written evidence submitted by Michael Ebbage, in a personal capacity as a competitive target shooter (and licensed firearms owner) (OWB64)

Dear Sirs,


My evidence relates specifically to section 28, paragraph 2 of the bill and the proposal to ban self-ejecting (extracting) firearms, as that is my area of expertise. My submission highlights that their rate of fire is comparable to other manually operated firearms and is not remotely similar to the potential of semi or fully-automatic weapons. There is no recorded criminal use for this specific firearm type and nothing to demonstrate that existing controls are not working. Furthermore, the ban would be considerably more expensive than the consultation alluded to. Finally, that this aspect of the proposal is not evidence based, so there is no demonstrable reason for its inclusion in a bill designed to reduce violent crime.


I am an FAC holder, an active competition shooter and someone who would be directly impacted by the bill as it stands. I am a member of my local Home Office approved rifle club (Oundle) and a member of the UKPSA shooting association, for which I hold a competition licence that I use to compete across the UK (including the British and Scottish championships). My primary discipline uses a self-extracting rifle (where spent cases are automatically ejected following a shot), which would be banned (reclassified as "prohibited weapons") if the proposals in the bill go ahead without amendment. I am the 2017 champion for that class of rifle (UKPSA - Gallery Rifle Open) and I am hoping to continue to enjoy competitive success throughout 2018 and in subsequent years.


1. The earliest self-ejecting (extracting) rifle I am aware of is the H&R Model 755, dating back to the 1960s. I am not aware of any recorded violent crime with this mechanism - and the Home Office has not produced any statistics showing this. They aren't used by any military that I am aware of (as they don't serve that function) and I don't believe they are any more attractive to criminals than any other firearm. The bill relies on the potential misuse of this type of firearm, which is not supported by any evidence. Like other rifles in the UK, they can only be purchased / owned by individuals who have demonstrated sufficient good reason to the police, and have satisfied the appropriate background any medical checks. The Home Office has not produced any data to support a ban of this type of rifle (and instead, makes frequent references to the danger of large calibre / high-muzzle energy rifles, which are entirely different to self-ejecting rifles).

2. Describing a self-extracting / self-ejecting rifle as being "rapid-fire" is misleading. The British Army's pre-World War I speed shooting exercise - known as the "Mad Minute" - tested a riflemen's ability to hit a target (at least 100 yards away) as many times as possible within one minute. In 1908, the record (set by Sergeant Major Jesse Wallingford) was a score of 36 hits, using a manually operated bolt-action rifle. A semi-automatic AR-15 is considered to have a rate of fire of around 60-90 rounds per minute (the official manual lists the maximum effective rate of fire at 45 rounds per minute) - but in practical terms it can fire as quickly as someone can pull the trigger. A self-ejecting (extracting) rifle cannot remotely fire (even half) as fast as a semi-automatic rifle. After taking a shot, you need to wait for the case to eject and action to lock back, then you need to operate a lever to release the action forward (doing so prematurely jams and potentially damages the rifle) - only then can you take a subsequent shot. From my competition experience, I've yet to see one exceed the capability of other manually operated rifles (bolt-action, lever-action etc.). A self-ejecting firearm has a similar rate of fire to that of a bolt-action rifle demonstrated over a century ago - therefore I'd assert these rifles cannot be considered to be anymore dangerous to the public than other target rifles legal in the UK. Modern self-ejecting rifles may have an appearance that sometimes makes them superficially comparable to automatic weapons (being made from aluminium and polymer components, typically finished in black paint), but this is a consequence of manufacturing changes, rather than purpose or capability. I believe this appearance has led to them being perceived as being more dangerous than traditional firearms, but have not seen any evidence to back this up.

3. Semi-automatic rifles may pose an enhanced risk, as they can be combined with devices such as "bump fire" stocks that can increase their rate of fire dramatically (to hundreds of rounds per minute) - effectively making them fully-automatic assault rifles. This is what the US refers to as "rapid-fire", something not legally a machine-gun, but effectively with the same capability. The bill includes a proposal to ban these devices, which I fully support, as there is no lawful civilian application for them (target shooting or hunting etc.). However, it should be noted that these devices do not influence the rate of fire of a self-ejecting (extracting) firearm at all, due to the differences in the mechanism.

4. The consultation has grossly under-estimated the cost of any proposed ban. The consultation limited its scope to ".50 calibre rifles" (highlighted for being anti-materiel) and MARS / VZ-58-type rifles (for being rapid fire, activated by two trigger pulls). Now with the much broader definitions in the proposed bill, rather than approximately 1000 rifles being affected at a surrender cost of around £2000 each, I believe there are now around 4000-5000 rifles at risk (with a much higher average cost, likely to exceed £3000). This raises the direct cost of any ban from around £2 million, to well over £15 million.

5. All the empirical evidence tells us that the existing controls we have in place (firearms licensing, background and medical checks, secure storage requirements, Home Office approved rifle club membership criteria etc.) are working effectively. There is no evidence that there is any enhanced risk of violent crime from this specific type of firearm (having been legally owned in the UK without incident for decades). The proposed ban is not evidence based and is entirely predicated on fear and ignorance. If the proposed ban goes ahead, it is not likely to save one single life. This represents a raw deal for owners and very poor value for money for the tax payer, as the same money spent elsewhere - on services such as the NHS - would have a measurable benefit.

6. Recent / ongoing improvements to things like the firearms certificate application processes, standardised medical checks, clarification on obsolete (antique) firearms and improvements to the laws surrounding deactivated firearms (closing the loophole of lower standards from outside the UK), have demonstrated that the government is tackling the issue of public safety surrounding the potential misuse of firearms in the UK. These changes have been sound, evidence based improvements to guidance and legislation, following a demonstrable need. The proposed ban would not follow this pattern, and would instead form a dangerous precedent, where things are banned for subjective, questionable reasons.


1. Consider removing self-ejecting (extracting) firearms from the bill, as there is no evidence to suggest they are / have been used in violent crime - or any indication that they will be in the future.

2. Allow the police to require evidence of genuine participation in competitive shooting for these types of rifle, limiting their ownership, whilst allowing those participating in the sport to continue to do so (only if the government can suitably demonstrate an enhanced risk from them).

3. Consider enhancing the security requirements for the storage of self-ejecting rifles (if the government can demonstrate any enhanced risk from them).

4. Consider granting Section 5 authority for genuine competition shooters, so that they may continue to enjoy their sport, whilst being subject to appropriate additional scrutiny.

5. Continue to focus on the deactivation standards and obsolete firearms, as they have loopholes that have been demonstrably exploited by criminals in recent years.

6. As an alternative, consider limits on magazine capacity for centre-fire rifles. No matter what the mechanical rate of fire, if a firearms only holds a limited number of rounds, its effective rate of fire is always going to be limited.

7. At the very least, consider "grandfather rights" for existing owners, as legitimate target shooters should not have to suffer having their lawfully acquired property seized by the state - and it would dramatically reduce the cost to the taxpayer.

Yours Faithfully,

Michael Ebbage

July 2018


Prepared 17th July 2018