Help save BC gun ranges. BCWF wants your help to stop the BC government from forcing gun ranges to shut down.
Enforcing the Firearm Violence Prevention Act [BC Bill 4] will cause many if not most of BC gun ranges to close. Simply put, the requirements force small volunteer clubs to commit to costs they cannot afford.
BC’s Firearm Violence Prevention Act [BC Bill 4] is badly written and was imposed on BC gun clubs without adequate consultation.
Please forward this draft letter to someone responsible at a gun range near you or you personally write Cole Winegarden and tell him to fix the regulations.
Here is a draft letter.
We need to stop the BC government from destroying our heritage and endangering firearms safety.
Policy and Security Branch
PO Box 9258 Stn. Prov. Gov.
Victoria, B.C. V8W 9J7
Attn: Cole Winegarden – Acting Director Legislation and Policing Programs
Re: Your letter of June 17/21 – the Firearm Violence Prevention Act
Dear Acting Director Winegarden
The ….. Club welcomes the chance to comment on the Firearm Violence Prevention Act.
Provide background on the club.
Under the Bill, verification of multiple pieces of ID will now be mandatory at all ranges on entry. This would require dedicated “commissionaires” to inspect and verify the ID and person IDs at the range entrance; well beyond existing Range Safety Officers (RSO) required on the actual shooting range (vice the main gate), as currently required by law, and paid staff and volunteers doing work. These new staff requirements could add an additional $150K a year employee cost to operation, plus costs for infrastructure changes, plus record keeping & storage for up to 6 years. Such costs are unaffordable for many if not most BC clubs. Most clubs just have an unmanned locked gate (with keys issued to members), and few staff on site. Many clubs do not even have a gate. And how does the government propose to define “duty staff” in the context that most staff are volunteers?
While some larger gun ranges could survive this substantive increase in operating costs, it is almost certain that most small and many medium sized ranges in BC will not. Gun ranges contain significant quantities of lead from spent ammunition, that accumulates pending recycling. The Ministry of Environment is developing a code of practise for such recycling, that is consistent with current regulations. If ranges are forced to close because of financial consequences of this Bill, they will become abandoned, orphaned sites that are contaminated with lead, which will in turn become a major challenge for the Ministry of Environment; burdening regulators, and science staff with up to 150 small abandoned, contaminated sites as per the current regulations. Ministry of Environment staff already have too much more important issues to address than a government created problem.
It will also result in degraded shooting skills, which result in more wounding of hunted animals, vice a clean harvest. Hunters will end up using sub-optimal locations to use firearms, e.g., hunters sighting in their guns and practicing in locations that are not intended for that purpose. This is a public safety risk, and results in environmental degradation, i.e., lead contamination. And is something that the BC government has been trying to discourage for many years.
Most police train on club ranges to conduct mandated training. As ranges and clubs close; this leads to the unintended consequence of law enforcement agencies (Municipal police, RCMP, Sherriff services, Conservation Officers, Federal Fisheries Officers, Park Wardens, private security firms such as Brinks) not having a location to train at. Less routine practise under controlled circumstances, leads to degraded shooting skills. Was it your Minister’s intent to degrade the shooting skills of BC Federal, Provincial and Municipal Law Enforcement Officers?
It is strongly recommended that administrative burden be kept to a minimum cost, and that clubs only be required keep a sign in register of members who attend on a given day, and that the provision of ID only be required when becoming a member or purchasing a day pass. That way, just an open register could be set up, with just the member’s name and membership number, as well as guest names required when signing in and out.
In addition, $5,000 + fines for volunteers, or low wage paid staff will deter people filling these positions. A $100,000k fine could break a club. Both will deter volunteer Directors and Executives who keep ranges and clubs operating.
Types of identification to be produced might not be an issue for an adult guests, but that is not the case for minors. We have many junior members, and host many youth groups (Scouts, Guides, schools, and various Olympic shooting sports) as guests. Many of these ages do not normally have government ID cards. Section 27 (3) requires a non-member who does not possess a PAL to provide Name, Address, Phone number and date of birth. What parent would not be concerned that this type of information is being recorded, as well and the burden of the organization to keep it safe for the required time?
It is strongly recommended that minors should not be required to produce ID.
Overall, the requirement to keep and store records raises concerns protection of personal information, privacy, and access. As most ranges and clubs are not-for-profits, they have limited funds and space to securely store the type of information that may be required. Identity theft is an ever increasing and substantial challenge. You are creating more targets for such crime.
It is strongly recommended that only information that has concrete evidence of being useful to reduce violent crime be required to be collected and stored by clubs and ranges.
Part 3 Designated Property raises separate concerns. Members of our clubs regularly engage in hunting and firearms safety training with students at schools and in church-based meeting spaces. This includes Environmental Education, the BCWF CORE course (required to obtain a hunting licence). And the Canadian Firearms Safety Course. The training is often at the request of the school and such event are normally sanctioned by the teachers, parents, school board and the local RCMP detachment. This is a valuable pre-range day experience for the students to understand the principles of firearms safety. It makes the actual range day much easier to facilitate and increases the safety of the participants on range day as they have a clearer understanding of firearms use.
It is strongly recommended that government certified firearms instructors be granted an exemption for bringing DISABLED firearms and ammunition into various schools and places of worship with the permission of the school or church for the purpose of providing CORE, Canadian Firearms Safety Course, and related instruction.
Asking ranges to comment on regulations that are not available in draft form is not real and substantive consultation, especially as your staff have minimal to zero experience in range operations. Club members need to see draft regulations as they are being developed before, we can provide substantive, meaningful and useful feedback.
Finally, there should be at least one year for ranges to implement the regulations, after they have been developed and gazetted.
We trust that you will read and strongly consider all the above information that we have provided.