Response to Home Office Consultation Paper on Control of Firearms


Firearms Controls Consultation
Home Office
5th Floor
50 Queen Anne’s Gate


Dear Sirs, 

Controls on Firearms – A Consultation Paper 

I have carefully examined the above consultation document and wish to record my responses and comments. 

My knowledge and expertise in relation to firearms derives from over 40 years of sporting shooting, in the United Kingdom and in several overseas countries, and from detailed study of many aspects of firearms and shooting sports over that period. 

I am a member of the British Association for Shooting and Conservation, an office bearer of the Eden Wildfowlers Association, the author of four books on country sports and of several thousand magazine articles on shooting and related subjects. 

I will respond to the consultation document at two levels – firstly by making a number of general comments about the control of firearms and, secondly, by responding specifically to a number of questions raised in the document about which I have direct knowledge or a particular interest. 

A. – General Considerations 

In giving consideration to any amendments to the current framework and regulations relating to the control of firearms, the Home Secretary should pay regard to the Labour Party 2001 election manifesto commitment to place no additional restrictions upon shooting sports. The exact wording was “We have no intention whatsoever of placing restrictions on the sports of angling and shooting". 

He should also pay regard to the statement issued by the Labour Party on 15th July 2004, in the form of a press release by Martin Salter MP, to the effect that the Labour Party intended to produce a Charter for Shooting with a view to positively encouraging participation in shooting sports. Once again the exact wording was The Labour Party today announced its intention to produce its first ever Charter for shooting and to update its 1996 Charter for Angling as part of a co-ordinated initiative between Ministers at both DEFRA and DCMS to positively encourage the development of both sports. The current Labour manifesto states that the party “will not place restrictions on the sports of angling and shooting” but this new initiative will go much further in setting out measures that can be taken to promote participation in both sports and to highlight the social and environmental benefit of angling and shooting.” 

The third general point that I wish to make is to remind the Home Secretary that all legitimate users of sporting guns and firearms share his desire to see a reduction of armed crime. However, I believe that it is a fundamental error to believe that further regulation of legally held guns and firearms will have any affect whatsoever upon the incidence of armed crime. 

Firearms and Shotgun Certificate holders are, by definition, an overwhelmingly law-abiding section of the community as the absence of a criminal record is a prerequisite to the granting of a Certificate and any involvement in crime will lead to the Certificate being revoked. 

Also, legally held firearms are rarely stolen and make no significant contribution to the pool of illegal weapons available to criminals. 

A much more effective contribution to reducing armed crime would be to relax many of the current restrictions on legal private firearms ownership and, thereby, release much police time from wasteful, non-productive administrative tasks. 

In general terms, therefore, I recommend to the Home Secretary that he should seek ways of relaxing the burden of regulation currently placed upon sporting shooters by the existing Firearms Acts. This would give effect to his Party’s commitment to encourage participation in shooting sports and release police time to pursue the perpetrators of armed crime. 

B. – Specific Considerations (page numbers in brackets refer to the Home Office consultation paper) 

Foreword (p3) – I wholly support the Home Secretary’s commitment to tackling gun crime and, in particular, the introduction of minimum sentences. I also support the commitment to adequate and meaningful consultation with voluntary organisations, the police, community groups and other interested parties. The crucial role of groups representing shooting sports in such consultations should be more strongly stated. 

Categories of Firearms Licensing (p6) – A category of “prohibited weapons” must be retained as there are clearly certain weapons that have no legitimate sporting purpose and should be reserved for use by the military services and police forces. 

There is no good reason for continuing to perpetuate two separate categories of sporting weapons, held on Firearms Certificates and Shotgun Certificates respectively. The additional and stricter controls on sporting rifles serve no meaningful purpose. 

A single Certificate should, therefore, be introduced, with conditions no more onerous than these currently applying to Shotgun Certificates. This would result in a system that was more readily understood by users and by police officers and would result in administrative savings. 

Types of Gun (p6) – The consultation document asks whether any other types of firearms should be moved into the prohibited category and, in this regard, specifically mentions pump action and self-loading shotguns. 

At present, such shotguns, if held on a Shotgun Certificate, are limited to a magazine capacity of two rounds. Such guns have a slower sustained rate of fire than conventional double-barrelled shotguns. They do not, therefore, present any additional danger. 

Because self-loading shotguns typically have a lower recoil than conventional shotguns, they are particularly suitable for use by young people, women and people with disabilities. No additional restrictions should be placed upon their ownership or use. 

“Good Reason”, “Standards of Fitness”, “Certificate Conditions”, “Number of Guns” (p7) – As mentioned above, there is no reason to impose more onerous conditions upon firearms owners than currently apply to shotgun owners. The question, therefore, should not be about imposing additional requirements upon Shotgun Certificates but, rather, relaxing those applicable to Firearms Certificates. 

“Wishing to participate in a sport” should be accepted as sufficient reason to possess any sporting shotgun or firearm and the number of guns or firearms owned by an individual should be a matter of personal choice, rather than regulation. In practice, the high cost of guns, together with the requirement to keep them secure, will place practical limits upon the number an individual is likely to own. It should be recognised that different calibres of rifle are required for different quarry species and that a person participating in game shooting, wildfowling and clay pigeon shooting might require seven or eight different configurations and gauges of shotgun. 

Certification Process (p7) – The certification process should be streamlined to make it more readily understandable, to reduce police time and cost to the taxpayer and to remove current restrictions that serve no useful purpose.  

Young People and Guns (pp13-14) – As in any sport, it is highly desirable that children and young people should be introduced at as early an age as possible. There are huge benefits to young people in having access to a wide range of sporting activities and shooting sports have the added advantage of taking place in the open air in the countryside. 

Becoming educated and trained in the use of guns is a very powerful way of achieving a sense of self-discipline and respect for other people, for wildlife and for law and order. The importance of encouraging the early introduction of children to guns and to shooting sports cannot be over-emphasised. 

The government should give urgent attention to providing grant assistance towards the costs of running training schemes for children and young people in the field of country sports in general and shooting sports in particular. 

The other aspect of this issue is that guns are dangerous and some children may not have sufficient maturity to handle them responsibly and safely without adult supervision. For this reason some degree of regulation is necessary. The optimum balance would be for children of any age to be permitted to use guns under adult supervision but for them not to be allowed to own guns or use them unsupervised until the age of 17. In terms of specific recommendations: 

  • There should be no minimum age for the use of guns or firearms by children when supervised by an adult.
  • The supervising adult should be a Firearms or Shotgun Certificate holder and should be aged over 21.
  • Children should not be required to hold Shotgun or Firearms Certificates when using guns under the supervision of an adult Certificate holder. This provision should also apply to young people between the ages of 17 and 21.

Registered Firearms Dealers (pp15-16) – The suggestion that gun shops should have blacked out or frosted windows is totally contrary to the Labour Party commitment to encouraging participation in shooting sports. 

Mail Order Deliveries (p16) – The recently imposed restriction on mail order deliveries of guns should be reversed. It should be replaced by a system whereby the purchaser can send his Certificate to the vendor by Post Office Special Delivery and the goods can be delivered to the purchaser by secure courier. The present ban upon mail order delivery discriminates very heavily against people living in rural areas who may be physically remote from a sufficient range of shops to allow reasonable price competition. Subject to security of Certificate and goods, as outlined above, there should be no restriction upon newspaper, magazine or internet sales. 

Ammunition (p17) – There is no good reason to institute any further controls upon the supply or possession of shotgun ammunition. The number of rounds used by any individual might vary from a few dozen to several thousand per annum. 

C. - Conclusion 

I wish to conclude by reminding the Home Secretary that shooting sports in the UK have an excellent safety record, provide invaluable training and education for young people, contribute very significantly to rural economies and, in particular, have no connections to armed crime. 

Controls and restrictions upon the legal use of registered guns and firearms by law-abiding Certificate holders should be relaxed and every effort should be made to encourage young people to participate in shooting sports. 

I shall be grateful if you will acknowledge receipt of this response. 

Yours sincerely,


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