But a variation isn’t keeping open an authority, it’s changing it for something else, there is also a big difference between say, 6 months and indefinitely!
What about the situation where you apply for a moderator at grant or renewal then decide not to purchase and use that slot as a 1-4-1 for something else? Do you have to do this within 1 week, 1 month a year? No, of course you don’t it can sit there and the get varied, what is the difference?
As far as I read it, as it is there in black and white, there is no time limit for a variation. This is definitely something I would argue with the FLD should they ever try to contradict the guidance.
I have done that many variations over the years the size of my file is a running joke within the FLD! I’ve never had a time limit and ultimately this is not a query on whether the variation can happen but whether or not after a certain time a fee is applicable.
If you are not increasing the number of firearms on your certificate, irrespective of time passed, no fee is applicable, simple as that!