Offensive Weapons Bill

Written e vidence submitted by T he Fifty Calibre Shooters Association of the United Kingdom (FCSA-UK) (OWB95)

Specifically regarding:

Clause 28 (1)(2)

Clause 29 (1)(2)

Executive summary

This document is produced by the Fifty Calibre Shooters Association (FCSA UK)

· The FCSA is the target shooting club with the greatest experience in rifles with over 13,600 Joules of muzzle energy (ME) , particularly .50 BMG rifles

· We are restricting our comments to addressing Clause 28 (1)(2) and 29 (1)(2) that will prohibit the possession of such rifles and such comments can be evidenced

· Such prohibition will end the ir well-established and legitimate sporting use , namely target shooting in which members successfully compete internationally

· There would be unintended consequences regarding historic collectable rifles

· The Consultation Document and Impact Assessments are inaccurate, misleading and biased towards the Government’s position

· N o detailed or firm evidence of enhanced risk to public safety through their legal possession is provided

· These rifles are shown to be intrinsically unsuitable for criminal use and their potential terrorist use is far less than other less powerful firearms

· There would not be "a net benefit to society" by their prohibition but there would be unnecessary costs to the Government and public purse

· Prohibition s disproportionate nature renders it challengeable under the ECHR

· There is no ballistic significance in the figure of 13,600 Joules ME, being above or below this figure does not inherently alter the potential "dangerousness" of a rifle

· To fulfil an " anti-material " role requires anti-material projectiles that are already prohibited

· Senior politicians communications on June 27 with MPs were misleading

· As Committee members may not be familiar with the more technical aspects of rifles and the issues in question , a guide of the technical issues is included

· E nhanced security arrangements could be applied as a condition on a F irearm C ertificate and , with other measures that are detailed, would assuage any remaining concerns about the continued possession of such rifles

· Suggestions are made regarding questions the Committee may wish to ask

1. Authority to submit written evidence

1.1 The Fifty Calibre Shooters Association of the United Kingdom (hereafter referred to as the FCSA) is a Home Office approved club (Home Office Ref CFP 10 1/7/4/1/2/1/2/3/474) affiliated to the National Rifle Association (NRA) of the UK.

1.2 The FCSA (UK) was formed in 2001 to support target shooting with .50 calibre rifles and other large calibre rifles at long range and is the primary club in the United Kingdom with experience in the use of such rifles.

1.3 As such we have been elected onto the British Shooting Sports Council (BSSC) to advise on matters pertaining to the use of such rifles.

1.4 The club is also affiliated internationally with the FCSA of the USA which was formed in 1985 and has over 2400 members, the Long Range Shooting Club of Australia and the FCSA of Switzerland.

1.5 We currently have 420 members in the United Kingdom from a wide spectrum of backgrounds who participate regularly in the sporting use of .50 calibre and other rifles, namely target shooting.

1.6 Target shooting World Championships are held annually in the USA at which British competitors compete with considerable success.

1.7 The FCSA is thus both the club with the greatest experience and understanding in the United Kingdom on matters relating to the use of such rifles and that which would be most adversely affected by the "Offensive Weapons Bill" were it to be passed into law, resulting in the prohibition of the civilian ownership of firearms with over 13,600 Joules (circa 10,000 ft/lbs) muzzle energy that would include .50 calibre rifles used by the club membership for target shooting.

2. Scope of written evidence:

2.1 Given that our expertise specifically relates to .50 calibre rifles and other rifles of similar muzzle energy we are limiting our comments solely to issues pertaining to two sections of the "Offensive Weapons Bill", namely Clauses 28 and 29 regarding the prohibition of rifles that ca n have more than 13,600 Joules muzzle energy.

3. Impact of the Bill upon target shooting with .50 calibre rifles

3.1 The .50 BMG cartridge is not new technology, it was developed in 1918.

3.2 In the early 1980s civilians in the USA began to use this cartridge for target shooting and the Fifty Calibre Shooters Association was created in 1985.

3.3 This drove the development of such rifles and informed the subsequent development of rifles for the military, the US army only adopting this calibre in 1991.

3.4 That a rifle or calibre is used by the military does not render it unsuitable for target shooting purposes.

3.5 By way of example the venerable .303 Lee Enfield was developed as a military rifle and is now solely used for target shooting.

3.6 The UK FCSA was created in 2001 for target shooting purposes primarily with .50 calibre rifles.

3.7 Members of the FCSA UK regularly compete in the annual World Championship in the USA representing Great Britain.

3.8 This year the UK was represented in July by eleven competitors, taking home 4 medals.

3.9 Were the Bill to be passed with its current wording this would bring to an end this legitimate sporting activity in which the UK participates internationally that has to date had an unblemished safety record and is undertaken by individuals already deemed safe by their Chief of Police through vetting to possess such firearms

4. Technical issues, terminology and clarification of facts

4.1 We appreciate that those sitting on the Public Bill committee considering the sections relating to rifles may not all have comprehensive knowledge of these rifles and the terminology used regarding them.

4.2 These are primarily bolt action rifles, generally of .50 calibre and some other similar calibres generally of a historic and collectable nature.

4.3 The "action" relates to the mechanism whereby cartridges are loaded into the chamber and secured for safe firing.

4.4 Essentially a bolt action rifle consists of the bolt which can be moved back and forwards, pushes the cartridge case into the chamber of the barrel, locks and provides for the safe firing of the cartridge.

4.5 The barrel of the rifle is connected to the receiver which supports the safe locking of the bolt to the barrel and is attached to the stock.

4.6 The bolt is removable and is of relatively small size to the rest of the rifle.

4.7 It is important to note that without the bolt the rifle is completely unusable.

4.8 Further to this, the bolt from one make or model of rifle is generally not usable in another make or model.

4.9 The "calibre" of the rifle relates to the diameter of the projectile (bullet), of which there are many, and is generally in inches (.50 being half an inch in diameter) or millimetres (eg 7.62).

4.10 When we refer to .50 calibre rifles within this document we refer specifically to the .50 BMG calibre.

4.11 When a rifle is fired a projectile exits the muzzle of the rifle at high velocity.

4.12 "Muzzle energy" is a measure of the kinetic energy of the projectile which is related to both its weight and velocity.

4.13 There are various measures of muzzle energy including "foot/pounds" and "Joules".

4.14 The "Offensive Weapons Bill" would prohibit the ownership of rifles with more than 13,600 Joules of muzzle energy. In the Consultation Document relating to this Bill a figure of 10,000 foot/pounds was used. Such levels of muzzle energy are approximately equal.

14.15 To put the concept of kinetic energy into context in a more widely understood situation, an average size loaded transit van (3,300 kg in weight) travelling at 60 miles per hour has over one million (1,185,000) Joules of kinetic energy.

4.16 There is also no intrinsic ballistic significance in the figure of 10,000 foot-pounds or 13,600 Joules muzzle energy.

4.17 Being above or below this level of muzzle energy does not inherently increase or decrease the risk associated with potential misuse of such firearms nor is directly related to the maximum effective range.

4.18 Reference is made in the consultation document to the term "materiel destructive" which is better known as "anti-material".

4.19 These are terms which are inappropriately applied to rifles as it actually requires a particular combination of rifle and anti-material projectile to fulfil this function.

4.20 Such combinations designed to fulfil this role are intended to damage equipment.

4.21 To fulfil this role does not derive solely from muzzle energy or calibre but requires specific projectiles designed for this role.

4.22 All such projectiles required to do so include "armour piercing" (designed to penetrate armour, having a hardened steal or tungsten core), "incendiary" (designed to create fire), "explosive" (designed to explode at the target) or combination thereof.

4.23 Such projectiles are already prohibited under current legislation.

4.24 It is worthy of note that such "anti-material" projectiles are produced not only in larger calibres than .50 but in smaller calibres with less than 13,600 Joules of muzzle energy.

4.25 The projectiles available to civilian target shooters in any calibre are not designed to be "material destructive" or "anti-material".

4.26 Projectiles designed for target shooting generally disintegrate on hitting an armoured target or bounce off.

4.27 The "range" of a rifle generally refers to two different distances.

4.28 The "maximum range" of a rifle is the maximum distance a projectile can be fired before returning to the ground. This is usually achieved by firing the rifle at an angle of around 35 degrees and rifles are completely inaccurate at such distances.

4.29 The maximum range is, however, not the "maximum effective range", the range at which it can be shot with any degree of accuracy.

4.30 This is generally considered to be below 2,000 yards for .50 rifles.

4.31 To shoot at such a maximal range would, however, require a rather large target, considerable training, experience and skill together with the ability to interpret meteorological conditions.

4.32 However, the "maximum effective range" of several other calibres with less than 13,600 Joules of muzzle energy exceeds that of .50 rifles.

4.33 .50 calibre rifles are intrinsically difficult to shoot accurately at long range.

5. Concerns regarding the Consultation Document, initial and current Impact Assessment (22 May 2108) documents.

5.1 We are concerned that these documents regarding the issues pertaining to firearms with over 13,600 Joules of muzzle energy have been, and continue to be, misleading such that those who accept them at face value would be prevented from forming a fully informed and balanced opinion thereupon.

5.2 By way of examples the inaccuracy and misleading nature of the use of terms relating to the "anti-material" issue, armour penetration capabilities and long-range capabilities have been addressed earlier

5.3 The more recent impact assessment (22 May 2018) makes reference to "an 11 per cent increase in offenses involving firearms" and that "the Government therefor needs new primary legislation to provide the police with the powers required to tackle offenses involving …..firearms".

5.4 Disingenuously it does not distinguish between the increase attributable to legally held and already illegally held firearms nor by type of firearm while it is known that the misuse of rifles constitutes only 1% of firearms offenses (primarily illegal possession and poaching).

5.5 It is also not stated, but known, that no legally owned .50 calibre rifle has been used in a homicide or any other criminal offence in the UK.

5.6 We are concerned that there was no consideration of alternatives to prohibition. Within the impact assessment the question is put "What policy options have been considered, including alternatives to regulation? Please justify your preferred option".

5.7 In response to this there is nothing considered between the option of "Do nothing" and "prohibit the supply and possession of high muzzle energy firearms".

5.8 The option of requiring enhanced security for the possession of such firearms does not appear to have been considered despite being seemingly somewhat obvious and raised as an option by the FCSA and others in response to the consultation document.

5.9 Reponses to specific enquiry as to why this option was not considered or, if it was, discounted received from Nick Hurd and Victoria Atkins did not address this issue at all.

5.10 It is intimated that such rifles have an enhanced potential to be used for criminal or terrorist purposes

5.11 That .50 rifles would be suitable for use for criminal or terrorist purposes is highly questionable as evidenced by their virtual lack of use for such purposes.

5.12 We are not aware of any such use in the United States where these rifles are generally freely available without restriction nor are we aware of any homicides using such rifles.

5.13 While reference is made in the current Impact Assessment document to the tragic incident in Las Vegas in October 2017 " which 58 people were killed and more than 800 injured" as a reason why "the government has therefor identified the need to introduce stricter controls on the ownership of such weapons", somewhat disingenuously no mention is made of the fact that the perpetrator did not choose to use a .50 calibre rifle which he could easily have acquired.

5.14 We are not aware of there having been any criminal use of a legally held .50 calibre rifle or other firearm with over 13,600 Joules, such as historic large calibre firearms, in the United Kingdom.

5.16 We understand that one .50 rifle was stolen, but found abandoned within 36 hours on waste ground, with the barrel sawn off.

5.17 This would seem to indicate that the criminals who stole it did not consider it suited their purposes.

5.18 Regarding potential terrorist use of such rifles we would again highlight the issue of the USA where they are generally freely available but not used for this purpose.

5.19 We understand that .50 calibre rifles were illegally used by the IRA during the Troubles in Northern Ireland.

5.20 Six military personnel were killed out of 3720 deaths during the conflict of which 1114 were British security personnel over which period there were over 36,000 shooting incidents.

5.21 This would indicate that the .50 rifle was not a firearm of choice for the terrorists.

5.22 Furthermore, these rifles were illegally imported into Northern Ireland, a source that would not be impacted upon whatsoever by the proposed ban.

5.23 It should be remembered that such firearms are heavy, bulky, difficult to transport and conceal, relatively slow to fire and very loud rendering the firing position difficult to hide.

5.24 Given the above we believe it is evidenced that rifles with over 13,600 Joules muzzle energy, including .50 calibre rifles, are inherently unsuitable for criminal or terrorist use.

5.26 On page 23, paragraphs number 68 and 69 there is a "Public Safety Statement".

5.27 It is stated in the "evidence base" under the section entitled "benefits" that "the penetration and fire rates of high calibre/rapid fire rifles means that if they were used in a crime, there is a significant risk of more deaths or more serious injuries than if were more conventional types of weapons were to be used".

5.28 Regarding firearms with a muzzle energy of over 13,600 Joules, including .50 calibre rifles used in target shooting, no evidence base is provided for this statement, neither historical nor ballistically factual.

5.29 Indeed, we would contest the validity of this statement for the reason given above.

5.30 It is further stated "These changes will therefore have a public safety benefit by reducing the risk of this situation arising".

5.31 We would, for the same reason contest this assertion regarding firearms with a muzzle energy of over 13,600 Joules, including .50 calibre rifles used in target shooting.

5.32 Our view is, to some extent, supported by the next paragraph in which it is stated "These benefits cannot be quantified due to the uncertainty of how many such incidents may be prevented by the legislation".

5.33 The following paragraph "for context, the affected rifles constitute 0.07 per cent of all registered rifles, and on average, there were 45 firearm-related homicides per year between 2004/2005 and 2104/2015" is irrelevant and potentially misleading for various reasons.

5.34 The rapid fire and rifles with a muzzle energy of over 13,600 Joules are lumped together.

5.35 While the reference is to rifles the "firearm-related homicides" referred to are not quantified as to type of firearm (eg handgun, shotgun or rifle) nor by whether legally or illegally held.

5.36 Why the figure for the year to 2016 (26 homicides) was omitted is unclear given that they were available from the Office of National Statistics (ONS) when this document was published.

5.37 The ONS report for England and Wales 2016 indicates that in 26 cases of homicide only one firearm was known to be licenced and in seven cases this was unknown.

5.38 It is further stated that over the last 5 years there was an average of 3.8 homicides per year where a "licensed firearm" was used.

5.39 This is considerably less than the "45 firearm-related homicides per year", that is quoted in the Impact Assessment, the vast majority of which were thus committed using an illegal firearm, and thus could thus reasonably be considered misleading.

5.40 Furthermore, the total number of licensed firearms extends considerably beyond solely rifles and, by 2016 numbered in England and Wales at around 1,870,757.

5.41 This would indicate that .50 calibre rifles constituted only around 0.0034% of all licensed firearms.

5.42 Even if it is considered that there is an equal distribution through all legally held firearms regarding the type used in homicides (which is not the case, rifles being far less frequently used) .50 calibre rifles would feature in 0.00013 homicides per year and in ten years their prohibition would statistically prevent 0.0013 homicides.

5.43 That is to say that, at best, statistically, it would take over 7,600 years to prevent one death, which is longer than the span of recorded history.

5.44 This is somewhat less than the "0.4 homicides per year" than it is stated that "the legislation would need to prevent", "in order to have a net benefit to society".

5.45 Statistically, thus, it can be shown that the legislative change to prohibit firearms with over 13,600 joules of muzzle energy is not evidence based or fit for purpose.

6. European Convention on Human Rights (ECHR) issues

6.1 We consider that the prohibition of rifles with over 13,600 Joules of muzzle energy will breach Article 1 of Protocol 1 of the ECHR of those who currently own such rifles.

6.2 This states that "Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law".

6.3 It should be noted that those who use or collect such rifles are part of the "public" the "interest" of whom require to be considered.

6.4 We consider, for the reasons already put forward, that the "public interest" would neither be served by the prohibition nor is it proportionate to the alleged risk rendering it thus open to challenge under the ECHR.

7. Concerns that the results of the Consultation appear to have been ignored

7.1 We note that the total number of responses received was 10,712 of which approximately 60% of the responses were on the firearms proposal.

7.2 We note that the vast majority of responses were against prohibition (78%).

7.3 We also note that while it is recorded that enhance security for storage was raised as an option as opposed to prohibition this was not considered or evaluated in the revised impact assessment of 22 May 2018, the reasons for which are unclear.

8. Concerns regarding subsequent communications from senior politicians


8.1 We have been copied a letter from the Rt Hon Sajid Javid to fellow MPs sent on the 27th June 2018 and an email of the same date sent to fellow MPs by Victoria Atkins.

8.2 We are sufficiently concerned that their contents could be considered to be grossly misleading MPs to feel the need to respond to specific portions of them that pertain to the prohibition of firearms with a muzzle energy of over 13,600 Joules.

8.3 Letter from the Rt Hon Sajid Javid

8.4 "These are very powerful firearms that could cause devastating public harm if they got into the wrong hands".

8.5 All firearms can cause "devastating public harm if they got into the wrong hands" and this statement is not evidence based. For the reasons detailed earlier, it can be shown that this is not the case and, were this principle to be accepted, the prohibition of all firearms could be considered.

8.6 "They are six times more powerful than the weapons used in the Charlie Hebdo terrorist attacks and are much more powerful than standard British Army rifles".

8.7 The firearms used in the Charlie Hebdo attacks were far more suited to a terrorist attack being relatively concealable, were automatic, had a rapid rate of fire, were easily transportable, had a high magazine capacity, with light rounds so a large number can be carried, were easily handled and carried by individuals and used at short range where the power of the firearm had nothing to do with its lethality.

8.8 Such firearms are already prohibited in the UK.

8.9 .50 Calibre target rifles are very heavy, not concealable, are bolt action with a slow rate of fire, are not easily transported, the rounds are of a weight that reduces the number that can be carried, are heavy and not easily handled (especially in a confined space) and not suited to be used at short ranges such as in the Charlie Hebdo attack.

8.10 Indeed, were they to have been used it could be reasonably argued that had they been used the death toll would have been considerably reduced.

8.11 To state that .50 target rifles are "much more powerful the standard British Army rifles" is grossly misleading and fails to acknowledge that many rifles used for hunting and target shooting are also more powerful. So called "standard army rifles" have to make a balance between accuracy, the range at which they are likely to be required to be used and the weight of the ammunition the soldier can carry, the latter issue making smaller and so less powerful rounds more appropriate for this role.

8.12 .50 calibre target rifles are utterly unsuited for issue as a "standard British Army rifle" due to size, weight both of rifle and ammunition, difficulty in transportation, slow rate of fire and unsuitability for close combat use.

8.13 "These guns have a range of several miles. Their penetrative powers mean that with the right ammunition they can penetrate body armour worn by soldiers".

8.14 The misleading nature of this statement is addressed earlier regarding the maximum range of rifles as opposed to their maximum effective range.

8.15 While reference is made to their ability to "penetrate body armour", "with the right ammunition" it is not made explicit that such ammunition is already prohibited in the UK or that less powerful rifles have this capability with such prohibited ammunition.

8.16 "Concerns have been raised by UK law enforcement about the civilian ownership of high muzzle energy rifles and rapid firing rifles and the risk they may pose to public safety".

8.17 No evidence base has been presented for this.

8.18 "These rifles have already posed a potential risk to public safety. A .50 calibre rifle was stolen from the home of a licensed firearms holder alongside other weapons in July 2016".

8.19 Somewhat disingenuously it is omitted to mention that the rifle was found having been abandoned on waste ground.

8.20 This would indicate that those having procured it found it unsuitable for criminal use or to pass on to others.

8.21 "In another case a licensed firearms holder of weapons including a .50 Calibre rifle was also involved in supplying firearms and ammunition to Sundish Nazran, who was the chief armourer to a West Midlands organised crime gang".

8.22 Again, somewhat disingenuously it is omitted to mention that the rifle was not supplied to the crime gang and to have done so would have been evident in due course to the police when he was no longer in possession of it.

8.23 "Given these concerns and the potential risk to public safety from these types of rifles the Government is taking action to prohibit their ownership, manufacture, sale and importation".

8.24 The alleged concerns and purported risk to public safety are not evidence based.

8.25 In these circumstances, the Government has a duty to safeguard the public and take action".

8.26 While no action is evidenced as being required, the alternative to prohibition of enhanced security being required for their possession is not raised as an option.

8.27 Email sent to fellow MPs by Victoria Atkins.

8.28 "A number of colleagues mentioned clause 28, which is on high-energy rifles. My right hon. Friend the Home Secretary said at the start of the debate that we will listen to colleagues’ concerns. I reiterate that this is not an attack on rural sports; it is a response to the threat assessment of the National Crime Agency and the police".

8.29 As a national club we deal with many police firearms department in the UK, not one has raised concerns about our members ownership of rifles with a muzzle energy of over 13,600 Joules.

8.30 As none of our shooting takes place in an urban environment it is indeed an attack on rural sports.

8.31 Furthermore, the alleged "threat assessment" has not been evidenced.

8.32"Given the strong concerns expressed, I will take a moment to explain how clause 28 came into being. For those who are not familiar with such weapons, they are very large and heavy firearms that can shoot very large distances".

8.33 They are very large and heavy which renders them intrinsically unsuitable for criminal use.

8.34 "One example I have been given is that they can shoot the distance between London Bridge and Trafalgar Square-some 3,500 metres".

8.35 To quote this figure is disingenuous and misleading.

8.36 This issue of maximum and effective range is dealt with earlier (with .50 rifles not being effective at anything near to that distance) and it should be added that to be able to shoot at a target is has to be within line of sight, which is not the case between London Bridge and Trafalgar Square.

8.37 I can share with the House the fact that there has been a recent increase in seizures at the United Kingdom border of higher-powered weaponry and ordnance".

8.38 No evidence base for this is provided, details of the "weaponry and ordnance" or numbers.

8.39 That they were allegedly "seized" indicates that they were being imported illegally and not sourced from those legally held on firearms certificates.

8.40 Such illegal importation would not be influenced by prohibiting them.

8.41"The assessment is that those weapons were destined for the criminal marketplace, and that the criminal marketplace is showing a growing demand for more powerful weaponry".

8.42 This may be misleading as the only evidence of criminal "use" in the UK mainland was the theft of one .50 rifle that was then found abandoned on waste ground and is addressed earlier.

8.43 "That is the background against which we are operating. Having received such an assessment, we must consider it with great care. We have a duty to consider it and to protect the public. I gently correct the suggestion that such high-energy rifles have not been used in crime. As the hon. Member for Belfast East (Gavin Robinson) said, high-energy rifles were used in the 1990s during the troubles to kill people who were charged with securing Northern Ireland".

8.44 The issues regarding this latter point is addressed earlier.

9. Concerns about the potential effect of misleading information being provided to MPs upon their opinion.

9.1 Many members of the FCSA have written to their MP raising concerns regarding the proposed prohibition of firearms with over 13,600 Joules muzzle energy, which would include the .50 target rifles.

9.2 Several have received what appears to be a stock response which appears based upon the erroneous information provided and addressed within the body of this document as follows:

9.3 "I note your concerns regarding the measure in the Bill to prohibit civilian possession of high energy rifles. I believe it is important to remember that these are incredibly powerful weapons which could cause unthinkable public harm if they were to get into the wrong hands. I understand that these guns are more powerful than standard British Army rifles, have a range of several miles and can, with certain ammunition, breach the body armour worm to protect soldiers in combat.

9.10 I was particularly concerned to hear that these dangerous weapons have on occasion fallen into the wrong hands. A .50 calibre rifle was stolen from the home of a licensed holder of firearms last year and in another case, a licensed owner of weapons including a .50 calibre rifle was involved in the firearms and ammunition supply chain of an organised crime gang in the West Midlands."

9.11 The content of these responses with their inaccurate hyperbole would indicate that they have been influenced by erroneous information as evidenced within the body of this report with regard to range, capabilities and potential for misuse.

10. C oncern s about the potential uni n te nde d consequences of such legislation with regard to historic and collectable firearms.

10.1 H istoric anti-tank rifles which were designed and manufactured between 1918 and 1942 and rendered obsolete by the middle of World War 2 due to advancements in tank armour are in various collections and held on firearms certificates.

10.2 These rifles were never designed for, nor are they capable of, accurate shooting beyond 300 yards.

10.3 However, the vast majority will exceed 13,600 Joules of muzzle energy.

10.4 Numbers are very low, values are very high, and these are highly collectable and somewhat unusual firearms.

10.5 Were this Bill to pass as it stands these historic rifles would be rendered prohibited and have to be destroyed.

10.6 This would be another unintended consequence of any prohibition.

11. Summary

11.1 We believe that we have demonstrated that there is no genuine threat to public safety from the possession of firearms of over 13,600 Joules of muzzle energy under Section 1 of the Firearms Act .

1 1.2 We have demonstrated that they are inherently unsuitable for criminal or terrorist use as opposed to other firearms.

11.3 We have shown that they pose a significantly lower risk to public safety due in part to their size, weight , difficulty in concealment and transport, noise, slow operation and the level of skill required to use them at extended ranges .

11.4 We have demonstrated that other smaller and less powerful calibres with less than 13,600 Joules of muzzle energy are superior regarding long range target shooting.

11.5 We have demonstrated that their purported "anti-material" capabilities require the use of projectiles that are already prohibited under current legislation.

11.6 Such prohibition would end the legitimate and established sporting use of such firearms in target shooting, an activity that British citizens compete successfully on an international basis.

11.7 Prohibition is thus not necessary, needlessly restrictive, needlessly costly to the Government, will result in unintended consequences and public safety will not have been improved.

12. Reasonable a lternative s to prohibition


12.1 While we consider that no change to the st at us quo is required we acknowledge that, however misinformed, some Members of the Committee will retain concerns about the risk of such firearms with over 13,600 Joules of muzzle energy moving from legitimate ownership through theft.

12.2 The FCSA has taken steps to mitigate against such a potential issue and would support a layered approach to enhanced security .

12.3 We have modified the way in which we advertise our range booking to members, so that this data is now secure and only accessible to members.

12.4 New members go through a strict vetting process and must already have a firearm certificate.

12.5 We would suggest that Firearm Certificates for such rifles should not be issued to individuals who have not already held a Firearms Certificate for five years, this being the time it would come up for its first renewal.

12.6 This would help identify those truly committed to target shooting at this level.

12.7 To further minimise the risk of theft we would recommend that consideration be given to the imposition of enhanced security requirements as a condition on the Firearm Certificate for possession of such firearms.

12.8 There is preceden ce for this approach as is detailed within "Appendix 3: Conditions for firearm certificates" within "Guidance on Firearms Licensing Law April 2016 for the police" from the Home Office.

12.9 Such conditions can be applied by the Chief Officer of Police to ensure that the certificated firearm can be held without risk to public safety.

12.10 We would recommend that the following conditions be applied to the possession of firearms with over 13,600 joules of muzzle energy:

12.11 When stored, the bolt of the rifle is stored in separate police approved cabinet to the rest of the rifle.

12.12 When in transit, the bolt is separated from the rest of the rifle.

12.13 When in transit, the bolt remains with the certificate holder or other authorised individual except when legally prohibited (for example travelling by air).

12.14 When being transported the case containing the rifle is locked and secured to the vehicle.

12.15 When on the shooting range the bolt is removed when the rifle is not being used and remains with the Firearms Certificate holder.

12.16 The rifle can only be used by the Firearms Certificate holder and cannot be lent or rented to any other individual.

12.17 The property in which the rifle is secured is equipped with a monitored alarm.

12.18 We reiterate that without the bolt these rifles are unusable.

12.19 Such conditions on a Firearm Certificate would sufficiently mitigate the risk perceived by those concerned about the potential diversion of such firearms through theft while permitting their continued legitimate use.

13. Suggested questions for the Committee to pursue regard ing the prohibition of firearms with more than 13,600 Joules of muzzle energy

13.1 We would respectfully suggest that the Committee makes the following enquir ies :

13.2 Of the Home Secretary – Why was the option of enhanced security not considered and included, or the reasons for it being discounted, as an option in the Impact Assessment?

13.3 Why was the legitimate sporting use of such rifles, including on an international target shooting basis, not made explicit in the Consultation Document, Impact Assessment or his letter to MPs on the day of the second reading to allow those considering this matter to make informed and balanced decisions.

13.4 Why did he send out a letter to MPs on the day of the second reading that could be considered misleading and does he accept that it was so ?

13.5 If he does, what action does he intend to take to rectify the matter?

13.6 If he does not accept this, on what evidence base does he hold this view?

13.7 Of Victoria Atkins – Why did she send an email which could be considered misleading to all MPs following the second reading of the Bill and does she accept that she was factually in error?

13.8 Of the NCA – What are the specific and evidenced risk s that they have identified regarding the legal possession of firearms with a muzzle energy of over 13,600 Joules , particularly as anti-material projectiles are already prohibited ?

13.9 Why could any such perceived risk not be addressed by enhanced security being a condition of possession?

13.10 Of the Firearms and Explosive Working Group (FELWG) – Have they identified any specific risks to the public associated with ownership of firearms with over 13,600 Joules muzzle energy under Section 1 of the Firearms Act?

13.11 Of the National Ballistic Advisory Service - Have they identified any specific risks to the public associated with ownership of firearms with over 13,600 Joules muzzle energy under Section 1 of the Firearms Act?


Mr Chris Stevenson Dr Scott Wylie

FCSA Chairman FCSA BSSC representative

Dated: 17th July 2018 Dated: 17th July 2018


Prepared 23rd July 2018