1) The
Phoenix Shooters Association is a Home Office Approved target shooting club
serving the
2) In this response we will only deal with the sections relating to the advertising of legal firearms and shooting clubs.
3) We support the majority of the code, but we are concerned that certain sections exhibit an ignorance of the shooting sports, and appear to show a severe prejudice born out of that ignorance. The shooting sports have an enviable record for safety[1] and our competitors comply with the law more rigorously than most competitors in any other sport, due to the possibility of losing their certificates if convicted of an offence.[2]
4) We
see an apparent link being made by the BCAP between the legal ownership of
sporting firearms and the criminal use of firearms. In point of fact nothing
could be further from the truth: The legal ownership of firearms has been
declining since 1988, as the restrictions on legal ownership have increased,
yet the number of people being killed and injured by criminals using unlicensed
and banned firearms has increased dramatically over the same period. [3]
5) Every
applicant for a firearm or shotgun certificate is vetted thoroughly by the
police, - something I am well aware of as this was one of my functions with the
police before my retirement. This means that certificate holders are amongst
the most law-abiding people in the
6) Target Shooting clubs of themselves have to be vetted by the police, then obtain Home Office approval to operate, and the criteria for this are complex and rigorous.[4]
7) We
are very concerned that there are errors in the statements of law made in the
consultation document at 10.1.319(2)(a) – it is NOT an offence for anyone under
18 to possess a firearm, and it is not an offence for anyone under 17 to
purchase some firearms. There are numerous exceptions and exemptions which the
document fails to address, giving a totally false impression.
8) We
note that 10.1.319(2)(b) infers that the possession and use of sporting
firearms is “liable to encourage the commission of crime.” This is far from the reality, and it is a
fact that the sale of such firearms is very closely restricted to those with
the proper authority to possess them – IE a firearm or shotgun certificate
holder (who as we said in paragraph 5,) are amongst the most law-abiding people
in the
9) In
10.8 you state that it is an offence for anyone other than a Registered
Firearms Dealer to sell a firearm – again this is incorrect – one certificate
holder may sell a firearm to another certificate holder. It is worrying that
your legal advice in this area has been so poor.
10) In paragraphs 10.65 to 67 you imply that firearms are offensive weapons – and that is true for illegal, banned firearms in the hands of criminals, but that is completely untrue for the sporting firearms held legally for use in target shooting. In 10.70 you say that guns are intended to murder or maim. This is an emotive statement without any backing – the intent of the designer or manufacturer is irrelevant to the use of the implement. Swords, darts, javelins, discuss, shot, bows etc were ALL originally designed as weapons of war, but no-one would call them offensive when used in sport, as they are in the same way as our guns.
11) We are
particularly concerned that one of the most law-abiding minorities in the
12) It is a fact that in schools where shooting is a sport it has been found to promote self-discipline, self control, and responsibility; an antidote if you like to the so-called “gun culture.”
SUMMARY
13) Q 55 and Q 56 Our answer is – No, we do not agree with the BCAP’s proposal to “strengthen” the prohibition.
14) We have a counter-proposal – that the
section relating to guns and gun clubs is removed.
15) Our
reasoning is largely above, but we’d add that we see newspaper, magazine and
interest advertisements for the shooting sports every day of the week, and
there has been no evidence of any form of widespread offence being caused.
There is no reason that the advertising of lawful use a legally-held sporting
item should not be “condoned.”
16) It is very clear that the BCAP have some severe prejudices based on a lack of knowledge. Our proposals would help to correct the belief (obvious in the BCAP documentation) that the sporting use of firearms is illegal, causes crime, or is dangerous and corrupting in some way.
17) We would invite members of BCAP to meet us to see exactly what “gun clubs” are, and how they operate – this would help dispel the current clearly-displayed prejudice.
9/6/09
[1] Source:
The Royal Society for the Prevention of Accidents Home and Leisure Accident
Surveillance web database.
[2] Source: Home Office Publications “Criminal Statistics
[3] Source: Home Office Publications “Firearm certificate
statistics
[4] Source: Home Office Publication “Firearms: approval of rifle and muzzle-loading pistol clubs” Home Office Communications Directorate 3/98 – FA-4 HOME J98-2365JJ.
[5] . TV Advertising Standards Code 3.1, and the Radio Advertising Standards Code 16.1 to 16.3.