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February 24, 2004

To:NCPTWF Members as per conference call of Feb 24, 2004:

From: Darrell Crabbe, Executive Director, Saskatchewan Wildlife Federation

Re:The below noted proposed changes were forwarded to Albina Guarnieri,except for proposal 12 added subsequently. These 12 points reflect the position of the Saskatchewan Wildlife Federation. Thank you for your input today and we look forward to a successful conclusion to this matter.

I am writing you in regard to the current proposal to effect significant change to Bill C-68, the Firearms Act and its associated gun registry. The Saskatchewan Wildlife Federation, which represents 25,000 members in 128 communities across Saskatchewan, applauds the responsible direction taken by the Federal Government as reported to us by our colleagues at the Ontario Federation of Anglers and Hunters (OFAH). While we appreciate the efforts of OFAH the magnitude of this issue requires our direct involvement in deliberations and implementation strategies. Please contact me as soon as possible as to how this may be arranged.

It is important to understand the context for this discussion. Saskatchewan’s legitimate firearms owners deeply resent what is still known locally as Bill C-68, because it focuses on the average firearm owner, criminalizing all aspects of what is a routine part of our culture. It usurps the authority for gun control from the provinces, and moves it to Ottawa where all of our concerns to date have been unheeded. While it may appear that the list of required changes is long, one must realize that the level of grievance is severe and has been compounded by 9 years of conflict since the inception of this legislation.

It is also important to realize that firearms owners in general are law abiding citizens and wholly support gun control measures which ensure the safe use of firearms and penalize those who use firearms for criminal purposes.

In order to achieve the needed changes, the Federal Government must work closely with the firearms' community in a straightforward and transparent manner. The legislation has to re-focus on criminal behaviour while at the same time reinforce the responsible, safe use of firearms by legitimate users. As an example, failure to have a license or improper storage should be seriously discouraged but should not be a criminal act.

Our requirements for change are as follows:

  1. To secure the support of Saskatchewan firearms owners this initiative must be agreed upon and implemented, OR acceptable assurances of change and implementation provided and announced publicly in their entirety before a federal election.
  1. Registration of long guns must be immediately eliminated.
  1. The Firearms Act must be removed from the Criminal code. This includes re-visiting penalties, ending inspections of private residences, search and seizure provisions without a warrant, etc. to bring them in line with normal summary offence or “ticketable” types of offences which are not criminal code violations. A significant aspect of this is to remove the reverse onus character of the legislation which makes citizens criminals, not from the commission of an offense, but rather the failure to live up to the requirements of the Act. As well the ability of Cabinet to make changes to the regulations through Order-In-Council must end. Legitimate firearms owners are not to be demonized as criminals or the source of firearms crime in Canada.
  1. Licensing: There will be only 1 license form of certification for new or existing firearms owners. Existing holders of a Possession Only License (POL), Possession and Acquisition Licence (PAL) or Firearms Acquisition Certificate will be grandfathered in during an amnesty period. Renewal of this certification every five years would not be required. Individuals must remain eligible to own and purchase firearms unless they commit a criminal act. Associated cost is a one-time fee which must not escalate over time to become cost prohibitive.
  1. Training: It should be co-ordinated with the province so there is only one course to avoid duplication. This may be as simple as recognizing the Saskatchewan course as equivalent to the federal training. Federal funding must be immediately restored and maintained on an annual basis to ensure training costs are not discouraging entry by new users. This approach ensures the safe use of firearms which all parties support.
  1. Eliminate gun show regulations and re-examine onerous provisions for firearms ranges. These legitimate activities have been ongoing for decades without incident.
  1. Authorizations To Transport (ATT's) will be authorized on the individual’s license for Canada wide transport to shows, ranges and repair shops. This simplifies the process, avoids duplication and administration, thereby reducing cost for all parties. After all these folks were already cleared to own restricted firearms when they were licensed.
  2. Eliminate section 12.6 regulations regarding barrel length and calibre. If you are licensed by the government as a person who can own restricted firearms, it shouldn't matter if the barrel is only 4 " or it is a .25 calibre. Similarly demonizing firearms for their appearance, action type or magazine capacity must be eliminated (example; “military assault rifles” are restricted because they “look dangerous”). The transfer of firearms between classifications must end immediately. (example; moving additional longarms into restricted or prohibited status must stop).
  1. The Federal Firearms User Committee should be comprised of a majority of firearms users (nominated by firearm user groups). Inclusion of a member of the public at large is agreeable, however, a majority of interests representing anti-gun movements is not. The government must show serious commitment to implementing the Committee recommendations or demonstrate publicly why they are not.
  1. Eliminate unnecessary bureaucracy and cost by cutting the federal CFO positions. Firearms owners are more than adequately served and prefer to deal with their local RCMP as they did in the past.
  1. Enforce the laws which were on the books prior to the Firearms Act. It is well documented that existing stringent penalties for the use of a firearm during a criminal act, are the first to be plea-bargained away. New “tough” gun laws are not required. Use the ones that were already there, as firearms owners support them.
  1. Provisions of the act dealing with the disposal of firearms seized by public agents must be changed to allow for the firearms transfer to a non-governmental, non-profit organization.

Again I wish to congratulate your government on initiating a speedy process to address this serious issue.

I await your quick response and look forward to meeting with you and your officials.

Sincerely,

Darrell Crabbe

Executive Director

Saskatchewan Wildlife Federation

DC:cm