BASC welcomes government announcement on sound moderators

[Dalua]

I appreciate you believe that the shooting organisations should not have got involved then and should not be involved now in any discussions with Home Office or government on firearms licensing

I'm sorry to have given that impression, though I'm not sure how I have done so.

My point of view actually is that BASC were involved (which they should have been), but they did not spot the risks even after they were pointed out and therefore did not take an opportunity to optimise that involvement.
The results of their involvement were therefore suboptimal.

The results might have been no different if they had acted differently, of course - but the apparent inability to recognise that there was a problem in their approach continues to leave me uneasy as a member of the 'shooting community' on whose behalf they claim to act.

I think BASC's premature 'welcoming' of a hint that something might at some time in the future be altered to our benefit might be a symptom of an ongoingly hubristic approach to dealing with HO/Police/Government. I might, for example, be pleased to hear that a guest has set out to visit me; but I would not welcome him until he arrived.

 

[Dalua]

Similar to the current situation where you can buy an airgun mod without a slot but fitting it to an FAC Air rifle is a breach of conditions - despite it being the same mod

This is how I see it currently: it is the fitting of the mod to the S1 firearm which makes the mod an item requiring S1 authority to possess/use. Once removed from the S1 firearm, it presumably must revert to its former condition.

 

[Chill 123]

No thanks due to me - I didn't respond for or on behalf of BASC or its members.

I still find it curious that your organisation is so quick to 'welcome' an as-yet incomplete, and relatively trivial hinted-at improvement in firearms law - yet seems to have let that very profound shift in policy (not even law!) go unchallenged which has resulted in certificate-applicants having to pay random sums to GPs in addition to the statutory fee.

Hi Dalua
I though you couldn't remember if you responded ? As you are not a member of BASC who represents your views when talking to decision makers ? I
Chill

 

[Dalua]

Hi Dalua
I though you couldn't remember if you responded ? As you are not a member of BASC who represents your views when talking to decision makers ? I
Chill

1. I can't - though it's likely.
2. Apparently BASC anyway, as 'the voice of shooting'.

 

[Conor O'Gorman]

I think BASC's premature 'welcoming' of a hint that something might at some time in the future be altered to our benefit might be a symptom of an ongoingly hubristic approach to dealing with HO/Police/Government. I might, for example, be pleased to hear that a guest has set out to visit me; but I would not welcome him until he arrived.

The government has confirmed a change in approach on sound moderators from almost 60 years ago. This follows a consultation on deregulating sound moderators last year under the last government which in itself was significant progress. I think you stated a while back that if your new representative body conducts itself worse than BASC, you might well return.

 

[Dalua]

The government has confirmed a change in approach on sound moderators from almost 60 years ago. This follows a consultation on deregulating sound moderators last year under the last government which in itself was significant progress.

I'm not sure what that has to do with anything...

I think you stated a while back that if your new representative body conducts itself worse than BASC, you might well return.

or that, in fact. I don't think it's likely.

 

[Conor O'Gorman]

I'm not sure what that has to do with anything...

The topic of this thread is the government announcement on sound moderators. Further to the OP:

Christopher Graffius, BASC’s executive director of communications and public affairs, said: “The issue of sound moderators was raised with Dame Diana at a meeting of the All Party Parliamentary Group (APPG) on shooting and conservation last week and at a meeting with BASC and the British Shooting Sports Council (BSSC) earlier this year.

“The announcement comes off the back of years of lobbying work and we are glad the government has listened to the reasoned arguments put forward. BASC would like to thank the APPG, BSSC and Sir Geoffrey Clifton Brown MP, who is chair of the APPG and BASC vice president, for all of their work on the issue.”

 

[Kalahari]

Sadly, as a long term member of the BASC I would be happier if Christopher Graffius moved on to pastures new.

David.

 

[Conor O'Gorman]

Sadly, as a long term member of the BASC I would be happier if Christopher Graffius moved on to pastures new.

David.

That's an inappropriate comment David to make about a staff member on a public forum and bizarre also given that you will know as a long term member how instrumental Christopher has been on the political front and continues to be. If you have an axe to grind with Christopher please give him a call.

 

[Mike L]

there’s always one………… or three.

 

[Dalua]

Statement made by​

Dame Diana Johnson
The Minister of State for Policing and Crime Prevention
Labour
Kingston upon Hull North and Cottingham
Commons

Statement​

The Government is today publishing its response to the public consultation that was undertaken by the previous Government on a proposal to remove the firearms accessory known as a sound moderator from firearms licensing controls. The consultation ran between 21 February to 2 April 2024.

A sound moderator can be attached to a rifle barrel to reduce the sound and flash when the rifle is fired. It reduces the sound of the shot by around three quarters and accordingly these accessories are used to protect shooters’ hearing, to reduce the disturbance to others in the vicinity of shoots and to stop shooters being temporarily blinded by the muzzle flash of a shot. They are entirely inert objects containing no moving parts and do not of themselves create a risk to public safety. They are, however, currently defined as a firearm in the Firearms Act 1968 and therefore they are subject to the requirement to be licensed by the police.

The Government has decided to remove sound moderators from the requirement to be licensed, and that by doing so, it will not create any public safety risk nor impact in any way on the strength of our existing firearms controls. We do, however, see merit in making it a requirement for a person to be in possession of a valid firearms certificate, issued by the police, in order to lawfully possess a sound moderator. This will ensure that these accessories are only held lawfully by those with a legitimate purpose.

The public consultation also sought views on whether it would be appropriate to use a Legislative Reform Order, made under section 1 of the Legislative and Regulatory Reform Act 2006, if it were decided to deregulate sound moderators. Having given careful consideration to this, the Government’s view is that it would not be appropriate to use such an Order, given that this will require a change to the legal definition of a firearm set out in the Firearms Act 1968. The Government is therefore of the view that this change should be made through primary legislation, and we will therefore seek to make this change when Parliamentary time allows.

A copy of the government response will be placed in the Libraries of both Houses and published on gov.uk.

The bit I've put in bold is interesting. It suggests that there's a view that it is currently necessary to have a filled slot on an FAC to possess a moderator for a S1 firearm - which is clearly not correct, as if it were all owners of airgun moderators would be committing an offence under the Firearms Act, since there will work on S1 airguns and (often) .22's of the smaller kinds.
Most retailers behave (and in the absence of crystal clarity on this, why wouldn't they?) as though a mod designed for a S1 firearms (e.g. ASE and so on) can be sold only to someone with an FAC slot for it - but I don't think that is strictly necessary in law (though in the absence of clarity, perhaps sensible!).

The only interpretation of the current law which seems to make sense is that a variation on the FAC is necessary lawfully to possess and use a moderator which is actually attached to ('an accessory to') a S1 firearm. That leaves all moderators (and flash-hiders) unattached to S1 firearms outwith Firearms Act control: and that's why people can lawfully have, for example, a SAK or PH mod for their sub12ftlb airgun despite its undeniable usability on a S1 airgun or .22LR.
The question then is, if they can have a PH mod for their non-FAC airgun, why not an ASE Utra? And in answer, I can see no reason. I can see reasons why they wouldn't want one for that purpose, but no reason in law why they shouldn't buy or own one for it.

Given then, that the filled slot on your FAC is to permit you to fit a mod to a S1 rifle, not to possess a mod - you'd think nothing really needed changing other than to make that position clearer to everyone, since the trade, shooters and the FLDs behave as though the mods themselves are S1 items even when unattached to a S1 firearm.

So, if the change in legislation under consideration is to say that moderators/flash-hiders attached to S1 firearms no longer need a 'slot' on the FAC, but you do need to hold an FAC for the relevant firearm to own them, then they're going to have to start trying to define technically which mods can lawfully be owned by non-FAC-holders for use on S2 shotguns and uncontrolled airguns, and which can be owned only by FAC-holders.
It would be a lot easier to say that moderator slots will be granted for every rifle owned if requested (which they pretty much are, I think), to clarify that moderators themselves (i.e. unattached to an S1 firearms) are in fact not subject to any control in law, and to issue guidance to the FLD and gun trade that as a modus vivendi the 'filled slots' are a token-gesture, but moderators can be bought and sold at will among FAC-holders and RFDs - but that would criminalise all the airgun- and shotgun-mod and oil-filter owners.

I can't help feeling that it could make things even worse - and it does play to my oft-repeated fears that once people start meddling with the Firearms Act even if it is ostensibly for the shooters' benefit (there's a first time for everything, I guess...) they will have a golden opportunity to get up to all sorts of other long-planned mischief.

 

[VSS]

- and it does play to my oft-repeated fears that once people start meddling with the Firearms Act even if it is ostensibly for the shooters' benefit (there's a first time for everything, I guess...) they will have a golden opportunity to get up to all sorts of other long-planned mischief.

I think your fears are perfectly justified.

 

[Dalua]

I think your fears are perfectly justified.

We should fear the Home Office even when they're bearing gifts. Or perhaps especially then?

We should not, I think, be 'welcoming' their reassurances on anything. It suggests not only that we've learnt nothing from the history of firearms law in this country since 1920, but also nothing from more-recent 'negotiations' - and further, that we are never likely to learn anything at all useful in improving the outcomes of future negotiations.

 

[Cogswell & Harrison]

Statement made by​

Dame Diana Johnson
The Minister of State for Policing and Crime Prevention
Labour
Kingston upon Hull North and Cottingham
Commons

Statement​

The Government is today publishing its response to the public consultation that was undertaken by the previous Government on a proposal to remove the firearms accessory known as a sound moderator from firearms licensing controls. The consultation ran between 21 February to 2 April 2024.

A sound moderator can be attached to a rifle barrel to reduce the sound and flash when the rifle is fired. It reduces the sound of the shot by around three quarters and accordingly these accessories are used to protect shooters’ hearing, to reduce the disturbance to others in the vicinity of shoots and to stop shooters being temporarily blinded by the muzzle flash of a shot. They are entirely inert objects containing no moving parts and do not of themselves create a risk to public safety. They are, however, currently defined as a firearm in the Firearms Act 1968 and therefore they are subject to the requirement to be licensed by the police.

The Government has decided to remove sound moderators from the requirement to be licensed, and that by doing so, it will not create any public safety risk nor impact in any way on the strength of our existing firearms controls. We do, however, see merit in making it a requirement for a person to be in possession of a valid firearms certificate, issued by the police, in order to lawfully possess a sound moderator. This will ensure that these accessories are only held lawfully by those with a legitimate purpose.

The public consultation also sought views on whether it would be appropriate to use a Legislative Reform Order, made under section 1 of the Legislative and Regulatory Reform Act 2006, if it were decided to deregulate sound moderators. Having given careful consideration to this, the Government’s view is that it would not be appropriate to use such an Order, given that this will require a change to the legal definition of a firearm set out in the Firearms Act 1968. The Government is therefore of the view that this change should be made through primary legislation, and we will therefore seek to make this change when Parliamentary time allows.

A copy of the government response will be placed in the Libraries of both Houses and published on gov.uk.

The bit I've put in bold is interesting. It suggests that there's a view that it is currently necessary to have a filled slot on an FAC to possess a moderator for a S1 firearm - which is clearly not correct, as if it were all owners of airgun moderators would be committing an offence under the Firearms Act, since there will work on S1 airguns and (often) .22's of the smaller kinds.
Most retailers behave (and in the absence of crystal clarity on this, why wouldn't they?) as though a mod designed for a S1 firearms (e.g. ASE and so on) can be sold only to someone with an FAC slot for it - but I don't think that is strictly necessary in law (though in the absence of clarity, perhaps sensible!).

The only interpretation of the current law which seems to make sense is that a variation on the FAC is necessary lawfully to possess and use a moderator which is actually attached to ('an accessory to') a S1 firearm. That leaves all moderators (and flash-hiders) unattached to S1 firearms outwith Firearms Act control: and that's why people can lawfully have, for example, a SAK or PH mod for their sub12ftlb airgun despite its undeniable usability on a S1 airgun or .22LR.
The question then is, if they can have a PH mod for their non-FAC airgun, why not an ASE Utra? And in answer, I can see no reason. I can see reasons why they wouldn't want one for that purpose, but no reason in law why they shouldn't buy or own one for it.

Given then, that the filled slot on your FAC is to permit you to fit a mod to a S1 rifle, not to possess a mod - you'd think nothing really needed changing other than to make that position clearer to everyone, since the trade, shooters and the FLDs behave as though the mods themselves are S1 items even when unattached to a S1 firearm.

So, if the change in legislation under consideration is to say that moderators/flash-hiders attached to S1 firearms no longer need a 'slot' on the FAC, but you do need to hold an FAC for the relevant firearm to own them, then they're going to have to start trying to define technically which mods can lawfully be owned by non-FAC-holders for use on S2 shotguns and uncontrolled airguns, and which can be owned only by FAC-holders.
It would be a lot easier to say that moderator slots will be granted for every rifle owned if requested (which they pretty much are, I think), to clarify that moderators themselves (i.e. unattached to an S1 firearms) are in fact not subject to any control in law, and to issue guidance to the FLD and gun trade that as a modus vivendi the 'filled slots' are a token-gesture, but moderators can be bought and sold at will among FAC-holders and RFDs - but that would criminalise all the airgun- and shotgun-mod and oil-filter owners.

I can't help feeling that it could make things even worse - and it does play to my oft-repeated fears that once people start meddling with the Firearms Act even if it is ostensibly for the shooters' benefit (there's a first time for everything, I guess...) they will have a golden opportunity to get up to all sorts of other long-planned mischief.

A most eloquent description of something that has bothered me for quite some time.

Another scenario. Some of my CF moderators listed on my FAC fit on some of my sub 12 air rifles. Is there, or will there be, any offence caused should I pop one on my sub 12 BSA Ultra?

 

[JTO]

My introduction to pistol shooting was with the club's old single shot .22. It had a muzzle weight on the c9" barrel that must have been threaded. It must have been surrendered when handguns were banned, but I dare say there were a few similar weapons that were not, because they were not registered. I can see the reasoning behind the proposed need for an FAC to be able to buy a moderator because someone without a FAC could get one to fit to an un-registered firearm like the one I have mentioned, otherwise.

 

[Conor O'Gorman]

We should fear the Home Office even when they're bearing gifts. Or perhaps especially then?

We should not, I think, be 'welcoming' their reassurances on anything. It suggests not only that we've learnt nothing from the history of firearms law in this country since 1920, but also nothing from more-recent 'negotiations' - and further, that we are never likely to learn anything at all useful in improving the outcomes of future negotiations.

The government has confirmed a change in approach on sound moderators from almost 60 years ago. This follows a consultation on deregulating sound moderators last year under the last government which in itself was significant progress. These are welcome developments and the vast majority of people giving feedback to BASC on this agree. Your view is that BASC should not be welcoming this welcome move and apologies if I missed it but I don't think you have not commented on what your new representative body has stated on the government announcement nor what work it is doing to improve firearms licensing? It is strange that you focus on BASC but not your own new representative body on this. As for 1920, that was over a century ago and I dare say recreational shooting opportunities are more accessible and affordable to the average person today than it was then.

 

[Dalua]

It is strange that you focus on BASC but not your own new representative body on this.

It really isn't so strange: I've no beef with my current small insurance-providing organisation. For one thing, they don't appear to be yet again up to their necks in something the exact nature of which they are at risk of misunderstanding, and the outcome of which might have profound effects (and by no means necessarily good ones) on all UK shooters, whether these are their members or not.

What I find strange (if I may?) is that you seem unfailingly to comment on my posts at some length, but without actually addressing anything in them.

The fallacy of popular opinion should not help you here - the view of the 'vast majority giving feedback to BASC' is not really relevant unless they are all correct in their appraisal on the situation - which seems to me unlikely.

'Begging the question' (as seen here in the true sense) also has no place: you shouldn't be asking me why BASC should not welcome so welcome a move when one of my points is that the move might not in practice be worthy of such a welcome as BASC (and, no doubt, the vast majority of its feedback-givers) believe.

 

[Conor O'Gorman]

It really isn't so strange: I've no beef with my current small insurance-providing organisation. For one thing, they don't appear to be yet again up to their necks in something the exact nature of which they are at risk of misunderstanding, and the outcome of which might have profound effects (and by no means necessarily good ones) on all UK shooters, whether these are their members or not.

What I find strange (if I may?) is that you seem unfailingly to comment on my posts at some length, but without actually addressing anything in them.

The fallacy of popular opinion should not help you here - the view of the 'vast majority giving feedback to BASC' is not really relevant unless they are all correct in their appraisal on the situation - which seems to me unlikely.

'Begging the question' (as seen here in the true sense) also has no place: you shouldn't be asking me why BASC should not welcome so welcome a move when one of my points is that the move might not in practice be worthy of such a welcome as BASC (and, no doubt, the vast majority of its feedback-givers) believe.

I think it's a positive development, as do most others on here and elsewhere, and I have read your concerns and warnings, and we shall just have to agree to disagree, until events unfold. As for your 'small insurance-providing organisation' do they undertake policy and advocacy work on firearms licensing and other key issues, or are they solely an insurance provider?

 

[Dalua]

As for your 'small insurance-providing organisation' do they undertake policy and advocacy work on firearms licensing and other key issues, or are they solely an insurance provider?

My main concern is that they refrain from sleepwalking the entire shooting community of Great Britain and Northern Ireland into further catastrophes: and I'm pleased to say that they have not spent a penny of my money on that kind of undertaking so far.

I think it's a positive development, as do most others on here and elsewhere

That is the fallacy of popular opinion again.

and I have read your concerns and warnings, and we shall just have to agree to disagree, until events unfold.

You might well have read my concerns and warnings, but you have not actually (unless I've missed something) responded to them with anything resembling an actual argument as to why it's sensible to presume it will all come up roses this time.

This makes me think that you, and consequently BASC, do not take them seriously.

 

[Conor O'Gorman]

My main concern is that they refrain from sleepwalking the entire shooting community of Great Britain and Northern Ireland into further catastrophes: and I'm pleased to say that they have not spent a penny of my money on that kind of undertaking so far.

That is the fallacy of popular opinion again.


You might well have read my concerns and warnings, but you have not actually (unless I've missed something) responded to them with anything resembling an actual argument as to why it's sensible to presume it will all come up roses this time.

This makes me think that you, and consequently BASC, do not take them seriously.

You have been clear about your concerns and I find your concerns speculative, pessimistic and unevidenced. BASC is not going to stop its lobbying efforts for improvements in firearms licensing on behalf of its members and you are content with the inactivity of your 'new representative body' on policy and advocacy work. So, there is nothing to argue about.