Help/Advice Sought: Open FAC Withdrawal Without Land

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It may be that the FEO is treating this FAC holder [with proven AOLQ history in another U.K. county] as an " unknown" entity by invoking this section:

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If so, I feel sure this can be robustly challenged by showing (1) length of FAC ownership (2) evidence of previous U.K. stalks - unguided would be useful, previous permissioning letters from contactable land owners, cull records, etc (3) receipts from overseas uses of rifle including .375
 
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It may be that the FEO is treating this FAC holder [with proven AOLQ history in another U.K. county] as an " unknown" entity by invoking this section:

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If so, I feel sure this can be robustly challenged by showing (1) length of FAC ownership (2) evidence of previous U.K. stalks - unguided would be useful, previous permissioning letters from contactable land owners, cull records, etc (3) receipts from overseas uses of rifle including .375
That may well be the case.
When my daughter was (briefly) under Northamptonshire jurisdiction they imposed closed conditions on a calibre that she had previously had listed as open.
 
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