Comments on Bill C-71

General

Public Safety Minister Ralph Goodale stated: “With this legislation and other measures, we are taking concrete steps to make our country less vulnerable to the scourge of gun violence, while being fair to responsible, law-abiding firearm owners and businesses.” This is not true. There is no evidence that the measures in the Bill will address any meaningful issue in any meaningful way.

Canadian firearms businesses and owners operate in one of the most regulated environments in the world.

The new rules contradict this point and simply don’t equate. In many ways this lowers the trust in government when they prohibit firearms where there is no evidence of a problem existing.

  • Canadian firearms businesses and owners operate in one of the most regulated environments in the world.If there was any evidence that further restricting law abiding business owners and gun owners would make our country safer, our members would be on board.
  • The new rules contradict this point and simply don’t equate. In many ways this lowers the trust in government when they prohibit firearms where there is no evidence of a problem existing.
  • School shootings are at the heart of the current public debate over firearms regulations, and this is an issue for all Canadians. All of us want to know our children are safe when they are at school. But Canada’s regulatory environment already provides the most stringent protection around the purchase and ownership of firearms. No additional firearms regulations are going to prevent a disturbed individual from carrying out a deranged plan to attack a school.
  • Metal detectors have been a proven method of enhancing security and are currently used in stadiums, government buildings, court houses, airports and banks. Why would we not take this simple step to secure our children from all dangerous weapons entering their schools?
  • Our focus, and our tax funding, needs to be spent on the most proven violence prevention efforts that focus on key public health strategies at the individual, community and societal levels to better identify and prevent violent behavior.
  • No method of security brings 100 per cent protection, it is time that our society stops wasting time and resources on ineffective gun control and starts directing their efforts on proven security measures to protect our children.
  • There is no evidence that escalating the level of red tape on licensed, law-abiding gun owners in Canada will enhance the safety of our children at school. For our society to continue to push and pay for these initiatives prevents us from getting to real solutions.

Misleading Government Statistics

The government’s missuse of statistics to argue shootings are increasing is quite evident by selecting the year 2013 as the base statistic instead of using all available data. Dating back to 1975.

  • The year 2013 saw Canada'slowest rate of criminal homicides in 50 years, and the lowest rate of fatal shootings ever recorded by Statistics Canada. Of course this would result in an apparent increase from 2013-2017. The year 2013 does not represent the norm over the last 50 years but in fact is an outlier.
  • Based on Canada's latest-known homicide rate (1.68 per 100,000 in 2016), it's also likely Canada's homicide rate in 2018 will be similar to or lower than it was 10 years before in 2008 (1.83 per 100,000)— or in 1998 (1.85 per 100,000), 1988 (2.15 per 100,000), 1978 (2.76 per 100,000)or, for that matter, 1968 (1.81 per 100,000).
  • The governments analysis using data only from 2013-2017 is very much slight of hand. Shame on the government for such sleazy tactics. The trend for Gun homicides is downward not up as the government claims.

The crime wave that wasn't

We don't yet know how 2018 will turn out for homicides, but there's a good chance it will be worse than 2013 — because every year since 1966 has been worse than 2013.

Claims of a 'Steady increase' are not true. See attachment showing firearms crime statistics since 1995.

So it's not accurateto say that "offences involving firearms have become more prevalent, especially since 2013." It would be more accurate to say offences involving firearms appear to have become more prevalent if we use the abnormal year of 2013 as a baseline.

Background checks for criminal violence and any mental illness will be conducted over the life of the individual, not the previous five year period.

The new law means increased background checks for the acquisition of licenses, including the “life history” of a purchaser – including their mental state and behavior.

Like most firearms owners, we are supportive of some form of mental health screening, but the potential for abuse in this section appears to outweigh any benefits.

  • Are new and existing diagnosis of mental illness or depression going to be reported? To who?
  • Are doctors now going to have to report all prescriptions for anti-depressants to the provincial CFO?
  • What happens once the person is cured/well again?
  • How is the CFO going to match up this information to holders of firearms license?
  • How will patient confidentiality be protected?
  • Is this just a “feel good” proposal with no practical consequence?

The last thing we want is for people to be scared to talk to their doctor about a mental health issue. But this is what is going to happen if you are a gun collector. If you talk about it, you will lose your guns. Gun owners will be scared to get treatment. And that’s ridiculous.

If taken at face value, the regulation is very open to interpretation.

You may have been in fight when you were 20 and were charged with assault, but now you are a 60-year-old man with depression and are being treated for it . . . the two things have nothing to do with each other. But because it meets the new key points, you may lose your license. And now, because licenses are tied with possession in the firearms act, you have to get rid of your guns – you can’t keep them in your home.

We request that the government “rethink” this initiative and develop something that will be effective in preventing individuals with mental illnesses, that make them dangerous to others, unable to legally possess firearms.

Both business and private sales of all firearms are subject to computerized license verification. Non-Restricted firearms transfers will not have the information regarding the firearm recorded.

  • How much will it cost to provide access to this computerized system and what assurances do we have this system will work any better than the federal payroll system.
  • What happens when the registration Web site is down for maintenance for several hours?
  • What evidence is there that the current system of having purchasers show the license is not working?

We request the government rescind this provision.

Businesses are required to keep records which will include the individual’s information and all information regarding the firearm(s) transferred. The business must keep the records for 20 years unless the business ceases to be a business. In that case all records must be surrendered to the authorities.

Under the new legislation, companies that sell firearms will be required to keep detailed records of firearm sales, as well as firearm purchasers. These records will not be shared with the government on a regular basis, however they will be available to the police via a judicial warrant if deemed necessary.

This is essentially forcing businesses to operate a “gun registry system” for government. A clear violation of the government’s election promise and an indirect tax on firearms owners by driving up costs for business.

  • What evidence is there that this measure will actually solve a crime, let alone prevent one?
  • What measures will be put in place to protect privacy?

We request that the government eliminate this unnecessary bureaucracy.

Authorizations to Transport have been gutted. The only permitted uses are to shooting ranges and Purchase-to-Home, but will still include “all ranges in province”. All currently held ATTs will be revoked on passage of Bill 71.

The new regulations also mean firearms owners have to obtain formal authorizations to bring restricted and prohibited firearms – including handguns – to gunshows or a gunsmith or to a border crossing.

  • Why is this change being made? Criminals, terrorists and the mentally ill will continue to ignore the laws. The only ones affected are law abiding gun owners.
  • How much is it going to cost and how may staff will be hired to process permit applications by gun owners to transport their restricted firearms to guns shows, a gun smith or a border crossing to take part in a completion in the US?
  • There is no evidence that there were any problems resulting from the current system.

We request that the government make no changes to the current system.

All of the Swiss Arms Classic series and all CZ-858s will be made 12(9) Prohibited. The owners of these rifles will be Grandfathered and permitted to transport to a range for the purposes of target shooting.

  • What evidence is there that these previously legal firearms are a problem?
  • This sets the stage for more future gun bans.
  • The government would better spend its time and energy preventing the illegal importation of firearms by criminals and terrorists.

We request that the government rescind this oppressive measure.

The power of the Governing Council to declare any firearm to be Non-Restricted has been revoked. The Governing Council may still be used to declare any firearms to be restricted or prohibited.

Classification of firearms does not change under the new legislation – non-restricted, restricted or prohibited – but the governing council now has jurisdiction to determine the classification of firearms without political interference. What political interference – we elect people to make decisions, not avoid their responsibilities.

The RCMP has a proven track record of incompetency in making firearms classification decisions.

We urge the Government to rethink their promise to repeal measures that give Cabinet the ability to reverse arbitrary decisions by the RCMP. Until the RCMP implements a fair and transparent process of classifying firearms, Cabinet will need every power available to protect law-abiding firearms owners in Canada.

A ruling by the RCMP Canadian Firearms Program has made Ruger 10/22 magazines that hold more than 10 rounds of .22 rimfire ammunition prohibited. With the stroke of a bureaucratic pen, the RCMP unilaterally turned hundreds of thousands of Canadians into criminals overnight. These instant criminals now face up to a 10-year prison term for possessing a prohibited device – a rifle magazine that’s been legal in Canada since the 1960’s. This ruling is inconsistent with the actual regulations and was made with:

  1. No advance notification;
  2. Lack of public input;
  3. No provision for an amnesty period and disposal process.

This legislation makes the un-elected police all powerful and unaccountable. This is unacceptable in a democracy.

We request that the government establish processes to prevent further unilateral actions by the RCMP.

UN Firearms Marking will be issued in a Technical amendment

These regulations duplicate current manufacturers’ marking and would result in a significant increase in the cost of firearms in Canada and a negative impact on the sporting goods industries, sports shooters and those Canadians who rely on hunting to feed their families, including, aboriginal hunters.

Canada’s already strict firearm import process already accomplishes every goal specified in United Nations Protocol 55/255, formally called the Protocol against the Illicit Manufacturing of and Trafficking in Firearms, Their Parts and Components and Ammunition, supplementing the United Nations Convention against Transnational Organized Crime.

We request that the government throw out this flawed and unnecessary regulation.

March 25, 2018