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By "Lingus"

The form being circulated is in accordance with The Act (as amended). It has been sent to assist gun owners and Firearms Registry comply with the requirement of that part of the Act.

On closer examination, It has been created so that members of more than one club or discipline, or those who travel elsewhere to shoot, can nominate a primary club appropriate to the firearm being used, so that only the "principal club is responsible for reporting your participation requirements."

The problems I see in this situation are:
a) The futility of the Act by continually adding imposts on licensed persons.

b) The sudden appearance of club licensing by "approval number", and so manage this part of the act. Ref: "…., there is a different
approval number for each type of club". Immediate confusion. Is it TYPES of clubs that are managed by license, or CLUBS per se that are licensed? Given history, I am sure the "Club Approval Number" contains numbers to identify both the club type and the specific club. This is defacto club licensing, and once "licensed" I imagine that it be far simpler to revoke a license "approval number" than challenge what is "approved". I might be wrong, but doubt it. Having said that – database management functions best by numbers then associations, so it is natural to enter a code that would assist in database use.

c) The onus which exists on clubs where their `license' can be revoked.

d) The ridiculous imposts on licensees, who if not with an alternative use for each firearm type (such as hunting on nominated properties), must nominate a club and maintain and be able to prove that over a 12 month period that `he' must "(i) participate in at least 6 club organised competitive shooting matches …..  (ii) for each different kind of pistol that the person possesses…."

e) The firearms registry is acting consistent with other arms of government, where they have no responsibility, and we are totally
accountable and subject to often inappropriate penalties.


f) The impact this will have on crime will be negligible if at all, simply because the persons already licensed and approved not only have a history of not being involved in crime, but are an added impost on them – not the real problem elements.

g) Achieving positive outcomes as per promises of "making society safer" and "getting guns off the streets" are totally unrelated to
this part of the Act.

Relating to the attached form – it is poorly written and confusing. First though:

a) The cost of return postage has been placed on each licensee. This cost is insignificant to the individual but is a substantial cost to the Registry when considering all licensees. As "Customers" we already pay for `service', and reply paid postage must be part of
that. As they want compliance – let them pay for it.

b) It is not made clear to persons (such as myself) that there is no need to complete the back of the form relating to shotgun and rifles in possession, when substantially used on properties – not at "approved" clubs.

c) How are people to comply, and must they comply, should they substantially use their firearm(s) off "approved" facilities, but
occasionally use them at such facilities?

d) Must those people join an "approved" club, and submit annual activity statements to that club?

e) What penalties will befall the licensee and their nominated club should they not comply?

f) Are those people to specifically write to the commissioner annually to explain why compliance was not achieved? (ref Sect 96/4)

g) Will penalising people and / or clubs in any way achieve the stated aims that precipitated changes to the Act and Regulations since 1996?

h) If not – what benefits can follow by persisting with complying to these parts of the Act and Regulations.

i) The Act and Regulations should be reviewed with substantial meaningful input from end users, and revoke aspects that are
identified as being pointless, or indeed harassment on those who abide by reasonable law and process.

Specifically relating to the form – it says:
"This form has been sent to all licence holders with genuine reasons that require a club membership."
Insert: That means – pistol, rifle, shotgun licensees who use club facilities.

If you have a genuine reason of RECREATIONAL HUNTING/VERMIN CONTROL as a member of an approved hunting club, you MUST complete the back page (Section F, Principal Club Nominations). All other RECREATIONAL HUNTING/VERMIN CONTROL license holders MUST complete the front page only.
Insert: That all means:
a) Club shooters must complete the back page.
b) Non club shooters do NOT complete the back page.
c) All license holders are deemed to be involved in Hunting/Vermin

THE BACK PAGE is partly completed with club registration details then says:

Insert: This reminds NON club shooters that it is unnecessary to deal with the back page.

You must nominate a Principal Club for EACH type of club that you are a member. In EACH section from 1 to 4, indicate your Principal Club by marking one principal club box with an X and write your club
membership number.

Insert: That is clear, but the column where the X is to be placed is not.

If your Principal Club is NOT listed below, ADD this to the list in each section applicable and mark the principal club box (ask your club for the approval number, there is a different approval number for each type of club).
Insert: That is clear.

If you are no longer a member of a club listed below, please indicate your ceased membership by marking the Club Ceased box with an X.
Insert: That is clear, but the layout of the form is not.

Again – the problem arises with the Act and the subsequent Regulations that require certain things. In order to identify, quantify and manage everything legal, (in order to somehow affect the illegal), the system focuses not on the accredited user, but the tools used by the user.

This is why systems collapse and why this is all absolutely pointless. Far better to focus on licensing and accreditation of the person. Having run those gauntlets, it is pointless focussing resources on the tools an accredited person uses.

An example of the utter absurdity to reinforce my point. A friend in Darwin who was an active IPSC shooter and FA18 pilot with two tours of duty in the Middle East in charge of a multi million dollar machine, and armed with government supplied weapons to blow people into little bits. He returned to face the handgun bans and restrictions and in disgust, surrendered his guns and left the Air Force.

On one hand, the government trusted him with enormous killing power, but would not trust him with a calibre of 4x100ths of an inch larger calibre, nor with more than 10 round magazines. It is indeed ABSURD.

What support from gun owners would the government expect should Australia need them?

a) Craig Capper is putting into effect that which the Act and Regulations state.
b) He has introduced de facto club licensing under the guise of club management and club reporting of member activity.
c) We are expected to pay postage for compliance.
d) None of this will affect the bad and the mad.

(1) NSW "Firearms Regulation 2006"

(2) Firearms Registry circular: 100339212/CLU 2 April 2007 – Craig
Capper (acting Mgr) With attachment of a double page form for "Nominated Club"