I think we need to put down the collective paddle for a bit though. It's quite exhausting beating that particular drum. If the message isn't clear by now it never will be!
Conor asked what we comments we would like to make, I'd like to suggest the following.
• Whilst, broadly, most people accept the 'enduring marker', this should only be added if we are to move to the 10 year licence and, along with that, a reduced burden for the firearms teams, not a reduction in staffing levels. The aims should be threefold; increased public safety, reduced workload, increased efficiency in application/ variation/ renewal turn arounds.
• The GP's assessment should be unbiased and honest based on a patients record. Due to the addition of the 'enduring marker' this should be a one-time only affair. On application a GP's referral is requested. This request should be from the licencing authority, not the individual. Once the GP signs off that there is no reason, from the medical records and not from personal bias, for refusal the relevant licence should be issued and the marker added to a patients records. There should never be a further requirement for GP involvement throughout the lifetime of the individual, not the lifetime of the certificate.
• As this is touted as 'increasing public safety' then the majority, if not all the costs involved should be met by the public purse. As this is essentially a box ticking exercise then the costs should be reasonable (£20-£50), fixed and consistent across all areas. There should be no deviation or facility to 'invent' charges by either constabularies or GP's, that is to say that rather than having 'regard' to costs they should be clear, fixed and transparent.
• Should a GP refuse to reply on moral or personal grounds then there should be a national facility of GPs to whom referrals can be made, these should be at the same cost as a regular referral and should not take longer than average to process; no waiting month upon month for a reply. The applicant should not deem to be 'punished' if their own GP's surgery refuses to assist.
• The idea of consulting with neighbours, partners, wives is a non-starter I'm afraid. This needs to be scratched completely. The process of application relies on two referees of good standing and no criminal record. This is sufficient and there is no evidence that any other additional processes will increase the thoroughness of the check. Once the initial application is approved any subsequent renewals WILL NO LONGER REQUIRE the referees. There is no point if there have been no additional offences committed by the applicant. All that is required is good reason (land authority, club or both).
• Further to this last point, contacting of neighbours is a complete compromise to security. It also is biased toward refusal. Pick 10 people at random and ask them whether they would be happy for their neighbour to possess firearms and the results I would say with some confidence would be negatively biased.
• Along with fixing the costs of the medical referral so too should the HO guidance be fixed. No longer should local constabularies be allowed to have 'regard' to the advice. It should be law, fixed and not subject to personal interpretation and bias in either direction. This would prevent the postcode lottery of licencing and force constabularies to apply the law evenly and fairly across the UK.
• Whilst we are reforming the licencing it would be positive if we had a little carrot as well as stick. I propose a review of the processes of 'one for one', using the Northern Ireland model or other models with the key principle being freeing up the onerous demands on licensing authorities. The process should be simply to pass on a rifle to a licence holder (either gift or purchase) or RFD, notify the authority and then proceed to replace. This would free up time to do more thorough initial checks of new applicants and security reviews of existing applicants.
• The removal of moderators from licences. They are no different to a magazine, muzzle brake or other accessory and, provided it is allowed for under EU law, should be allowed to be owned freely without FAC requirement. A little carrot to the stick.
• Ideally I would like to see the implementation of a national database, electronically managed and a move away from paper based certification. We have drivers licences that already manage multiple data entries, carry photo ID, addresses etc, I cannot see why a similar digitally based system can not be used. Police could quickly check a persons credentials when stopped in possession and it would allow the FAC holder to access his records and record and changes in circumstance (firearms added/ sold, requests to vary etc.)
That's it I think..
