For members information we quote below the HBSA response to the Home Office:-
We are responding to the above as Historical Breechloading Smallarms Association. You have our contact details below and on file.
We believe that we should respond to the questions raised in the usual spirit of co-operation but should state that we do so for the sake of good order and without prejudice, since other organisations have raised the issue that this consultation may not be legitimate due to the way that it has been formulated and expressed. We await advice in that respect. This refers particularly to Proposal H upon which we may comment.
We note that HBSA and other potential stakeholders appear not to have been consulted prior to this consultation, as has been the case in other firearms or collector related consultations.
In the “Background to the legislative proposals” there is identification of the type of firearm mentioned, large calibre (.50 cal) rifles and rapid firing rifles as being of concern. However there is no specific or detailed mention of why that is so, or of their having been involved in crime or terrorism in the UK.
The use of the term .50 cal caused us to write to the Home Office about historic and antique arms and large calibre sporting rifles being caught or included in the category.
We were glad to receive the Home Office assurance by email that :-
the consultation is in no way intended to include the section 58(2) antiques you have listed
recognising the need to avoid other established classes of firearms, such as those used for big game hunting and which share some of the same characteristics, being caught by the definition.
We were also pleased to note that:-
We are keen to avoid any unintended consequences and look forward to working closely with you and other interested parties to ensure against this.
The seeking of another potential yardstick was mentioned, such as muzzle energy, say of 10,000 ft lbs., being the limit imposed in relation to rifles fired at Home Office Approved Clubs. This too may present issues with historic and heritage arms (including artillery and armoured fighting vehicles) possessed by museums, collectors and re-enactors, but doubtless an exemption may be made for them. Even the largest calibre sporting arms do not generally reach that limit but exceptions could be made if necessary.
We believe the term “anti-materiel” rifle has been recognised as incorrect as such since this refers to the ammunition (armour piercing and explosive) rather than the firearm.
Knives and corrosive liquids used in crime and violence may be an issue.
However once again there must be recognition of genuine collectors, researchers, and museums who collect and study historic knives and bayonets, and to ensure that there are no unintended consequences in any new legislation. The same will apply to broad use of “working” knives across society for legitimate purposes e.g. kitchens, gardening, countryside, many industries, etc. and including training.
Subject to our comments above and in order to assist, we give below our duly qualified answers to the consultation questions.
Trading on line (Proposal A), as with any product or artefact needs to continue to be allowed with the requisite security element built in e.g delivery to a local shop or dealer allowing ID (and age) to be verified, and the legality of the purchase. Providing this can be achieved the the answer to Q1 is “no”. We have some concern about taking a step to create an offence which may produce unintended consequences so again the answer to Q2 in Proposal B is “no” . Turning to Proposal C Q 3 allowing for the broad use of knives mentioned above the answer is “no”. Proposal D, Q4 the answer is “yes”. and Proposal E Q5 the answer is “yes”.
It will no doubt also be recognised that acids and corrosive substances may be used by collectors and museums in various processes, including cleaning and preserving, and by the great majority of the population for legitimate purposes including health and hygiene. The situation is analogous to that of kitchen knives. Once again any unintended consequences should be avoided.
Allowing for these points then for Proposal F Q6 the answer may be “yes” subject to the qualification of “certain substances” and the same for Proposal G Q7 the answer is yes but subject to qualification as for Q6.
Our comments regarding proposal H earlier in this email lead us to answer “no” to Q8.
Regarding Q 9 to 25, HBSA does not own firearms or trade in them. Its members may. They will respond as individuals in relation to any business or trade issues. The same will apply to knives and corrosive liquids. Q 26 and Q27 answer “no” .
We trust that these comments are of some assistance in this matter and as usual remain at your disposal.
Historical Breechloading Smallarms Association