22 February 2013

The Right Honourable Stephen Harper
Prime Minister of Canada
Office of the Prime Minister
80 Wellington St.
Ottawa, ON K1A 0A2

Dear Mr. Harper,

RE: Chief Firearms Officers

The BC Wildlife Federation (BCWF) is concerned about Chief Firearms Officers
(CFO) arbitrarily imposing new and onerous interpretations of firearms
regulations for legal, law abiding firearms owners. I am writing to you on
behalf of BCWF members to object to the seemingly arbitrary expansion of
power behind closed doors. A few examples are troubling. In BC, the CFO,
without announcing any justification, changed the conditions of the
Authorization to Transport (ATT) to restrict transportation to only one
club; the Ontario CFO arbitrarily imposed an onerous new requirement on
firearms owners.

BCWF members are concerned that CFOs can arbitrarily impose additional
paperwork. Are there no limits? Does anything go as long as a government
official asserts "public safety?" Can CFOs unilaterally impose whatever
paperwork they dream up, however unnecessary or burdensome? Who in Ottawa is
responsible for setting policy for the country's CFOs?

It is unacceptable that CFOs can impose these new requirements and have done
so with no prior notice or even adequate justification. The new requirements
are unnecessary and are not mandated in the Firearms Act. Neither the BC nor
the Ontario CFO cited a public safety problem with the previous regulations.
Previously, an Authorization to Transport (ATT) allowed law-abiding permit
holders to transport a prohibited or restricted firearm to any qualifying
shooting range for the purpose of recreational sport shooting or to a
gunsmith.

The new conditions in Ontario require target shooters who visit a range that
is not their home club to obtain a personal letter of invitation from that
range before being allowed to transport their firearm. To my knowledge, BC
has not yet specified the necessary conditions to visit other ranges than
their home range. The new paperwork is of course in addition to the ATT they
already have and will increase the amount of paperwork necessary for
shooting ranges. Most ranges are largely staffed by volunteers, who will
have now to process more paper for shooting competitions. Competitions are
the life's blood of the shooting sports. This is another burdensome
requirement on law-abiding sport shooters and is yet another blow to a
traditional Canadian activity.

In a letter to shooting ranges and clubs dated January 28, 2013, the Ontario
Chief Firearms Officer outlines the new changes, without providing any
rationale for the change. The letter refers to the vested interest that
clubs and their members have in ensuring that shooting sports are pursued
safely and in accordance with the law. In fact, these same clubs and members
have been conducting their activities for decades under the previous rules,
and doing so in a safe and responsible manner. What is missing from the
equation is any justification of why the changes are necessary.

Every trained and licenced firearms owner who uses firearms for recreational
shooting at ranges is already subject to a stringent set of rules governing
the use and transportation of their firearms. Authorizations to Transport
(ATTs) have been in place since 1978 and are already more than sufficient to
monitor law-abiding citizens. There has not been a problem with ATT holders
committing crimes, and even if they had been, these rule changes would not
in themselves deter anyone with criminal intent.

To conclude, I am writing you on behalf of BCWF members who hold restricted
weapons to request that you urge the CFOs to withdraw these arbitrary new
ATT requirements. Indeed, given that the police already vet holders of
restricted weapons, it is not obvious what legitimate public safety concerns
the ATT itself serves.
Instead of wasting scarce resources on increasing the paper burden on
law-abiding citizens perhaps public safety would be better protected by
targeting criminals. If you are looking for ways to reduce bureaucracy, we
respectfully request that budgets for the CFOs should be considered.

Thank you for considering my requests and I look forward to your reply.

Respectfully yours,


Bill Bosch
President BC Wildlife Federation

CC: Honourable Vic Toews, Minister of Public Safety Canada
Public Safety Canada

Candice Bergen, MP
Parliamentary Secretary to the Minister of Public Safety

Gary Mauser, Ph D
Professor Emeritus
Simon Fraser University