I am writing to you as Secretary of the Gun Trade Association, Northern Ireland. This Association has been operational for two years, and has sought to promote the interests of Registered Firearms dealers in Northern Ireland, as well as the customer base, which we serve. Our membership represents 90 per cent of the trade volume of firearms within Northern Ireland, and is recognised as a significantly informed body, on the matters relating to firearms use, safety and legislation, by the Northern Ireland Office and the PSNI. During our time of active representation, we have liased extensively with the Northern Ireland Office and the Police Service of Northern Ireland, seeking to be seen as pro-active in addressing the issues which are to be investigated under the terms of your committee remit.

  Our Negotiating committee welcomes the announcement of your new enquiry, and we would hope within the course of this document to briefly identify our position in reference to the four main points of enquiry as identified within your press notice. We would add that as an Association we have amassed a significant amount of document and intelligence, as well as industry relevant experience held by our membership, which at an appropriate time we would also like to place at your disposal. We trust that your office would approach us for this information, as either written or verbal submission at the appropriate time.

Firearms legislation in Northern Ireland, with particular reference to differences from equivalent legislation in Great Britain;

  In response to these variations which exist between Northern Ireland and Great Britain, we would note that the following differences as being the most significant, meaning that if these points we aligned with Great Britain the shooting and firearms communities would enjoy much fuller equity of ownership and parity of esteem.

(a)  Most Shotguns in GB are held on Shotgun Permit, whereas in Northern Ireland these are detailed on the much more stringent Firearms Certificate.

(b)  Shotgun owners in GB do not have to display "good reason" by producing Land Owner "letters" when applying for a permit. Whereas in Northern Ireland this is an enforced and antiquated requirement for all firearms certificate applications where a shotgun is being sought.

(c)  Within GB there is no requirement to justify an unlimited private holding of shotguns (ref Firearms Law: Guidance to Police 2002. Ch11. Point2) Within Northern Ireland each individual application and firearm is subject to justification and verification at the point of application.

(d)  Within GB the holder of a shotgun permit is not required to have the purchases of shotgun cartridges recorded on his/her shotgun certificate. Current legislation in Northern Ireland requires the Firearms Certificate holder must have the purchase of all shotgun cartridges recorded on their firearms certificate, in addition to which the lack of regular purchases which can be interpreted as a record of use, can be construed as a valid reason not to renew a holder's certificate.

(e)  Within GB Registered Firearms Dealers are permitted to complete transactions where a member of the public is exchanging shotguns of a similar type and calibre. These transactions are known colloquially as "one on one off's". This is because the permit holder has decided to change his shotgun but is only replacing it with a different make or model; he/she is not seeking to vary the calibre or type of firearm held. Within Northern Ireland, all such transactions are processed and approved by the PSNI and this can take up to 12 weeks to complete. This obviously has a commercial impact upon the trade and shooting communities within Northern Ireland, and is totally unnecessary.

(f)  Within GB Registered Firearms Dealers are permitted to supply and vary shotguns to shotgun certificate holders, without prior permission of the local constabulary. In Northern Ireland these type of transactions all require prior approval of the PSNI, including but not limited to point (e) above.

(g)  Within Great Britain holders of shotgun permits, are afforded the flexibility of being able to "loan" shotguns to other permit holders. This flexibility is not afforded to the shooting community within Northern Ireland. In addition non-permit holders in GB can use a shotgun under the supervision of a shotgun permit holder, again this flexibility is not afforded to the shooting community within Northern Ireland. This disparity in legislation obviously precludes N.I. Registered Firearms Dealer's from expanding business opportunities such as safety training, corporate entertainment days and test of shotguns prior to sale.

(h)  Within Northern Ireland, a rifle of .22 calibre, is strictly licensed, and is only granted upon the submission of a Land Letter, to shoot upon a certain names property. For the period of ownership this land remains the only location where the licensed .22 rifle may be fired, additionally only one .22 calibre rifle may be licensed for use on any property regardless of size. Needless to say these conditions of ownership and use do not exist within Great Britain.

(i)  Air Rifles and Air Pistols with a muzzle energy of up to and including 12 ft-lbs and up to and including six ft-lbs respectively can be held in GB without any permit, authorisation or control being required. Such air products within Northern Ireland can only be held if granted on a Firearms Certificate. In addition authorisation to hold air products, which are described as pistols, inevitably is dependant upon being a member of a registered shooting club. This disparity between NI and the mainland is further exemplified as irrational as potential owners of an air operated firearms must have a firearms certificate to own and operate an air firearm of 5ft-lbs, whereas conversely should a member of the public wish to own and operate a crossbow of up to 155 ft-lbs the only condition of sale and ownership is that they are proved to be over 18 years of age.

(j)  Within Great Britain there is no defined lower age limit to operate a shotgun when accompanied by an adult. This obviously promotes a more effective learning curve within young shooters. Within Northern Ireland, young shooters must wait until they are 16 years of age to be able to apply to operate a shotgun, but only on lands, which they own and have access to.

(k)  At present Northern Ireland is the only European enclave, which operates the required system of "Removal Orders". Such removal orders are only required when moving bullet-firing firearms from mainland GB into Northern Ireland. Self evidently it is illogical that registered firearms dealers can import more efficiently and cost effectively from Germany or Italy than they can within what is essentially their own country. With a resulting lack competitiveness in the UK markets and a loss of revenue to the British exchequer.

(l)  Responsible members of the shooting community within Northern Ireland can have a holding of handguns, numbering as many as he/she can justify in the context of sporting endeavour. Conversely the Registered Firearms Dealer, with all his/her incumbent security and safety precautions is not permitted to hold any such handguns for retail purposes.

Any inadequacies in the existing controls designed to prevent the misuse of firearms;

(a)  Current controls neglect to respond effectively to persons who have committed offences which would in effect make them a prohibited person for ownership of a firearm. This inadequacy exists as the control is not triggered to respond to such instances, until the persons firearms certificate is presented for variation or renewal. The Gun Trade association, Northern Ireland, has already presented a more effective scenario for tightening this control mechanism to the Northern Ireland Office.

(b)  Within Northern Ireland there is no system or structure where Firearms Law Guidance is circulated or provided to the PSNI, and openly available tot eh general public. Within GB the Home Office publishes and circulates detailed and accurate Firearms Law Guidance, covering all aspects of Firearms, acquisition, sale, use, loan, etc in exceptional detail. This detailed document is also available for purchase by Registered Firearms Dealers, interested parties and the general public.

(c)  Whilst perhaps not directly relevant to the course of this enquiry our membership would sight the lack of control on powerful crossbows as being of concern to public safety as "bad press" associated with misuse of such items is generally reflected towards the responsible firearms retail and shooting communities across NI and GB.

The potential for amendment of the Firearms (Northern Ireland) Order 1981 to address the reasonable expectations of legitimate firearms users while ensuring public safety;

(a)  As industry experts and professionals in the use, safety and sale of firearms, our membership seeks always to represent the highest standards of quality and effectiveness when promoting public safety both internally to our membership and externally to our consumer base and public bodies. The Registered Firearms Dealers of Northern Ireland, in all our suggestions listed above, have verifiably and empirically accounted for public safety within our recommendations, and as professionals within the industry are amongst the best positioned to consult upon, act on and implement contingencies and strategy relating to the effective promotion of Public Safety. Our recent multi-media presentation to senior Northern Ireland Office executives and PSNI Firearms Licensing outlined several initiatives and proposals, which our membership saw as being germane to this topic.

  The Gun Trade Association, Northern Ireland, recognises the complexities raised in undertaking a review such as this, as well as the difficulties in effectively detailing our written comments for your consideration. With this in mind we trust that our offer of additional demographic, biographical and statistical information at our disposal may be called upon as required by your committee members or review team. Additionally the negotiation committee of the Gun Trade Association, Northern Ireland, would like to extend its willingness to your office and your review committee to make oral submission within the fuller context of this review should you deem this appropriate.

29 April 2002