Combined Firearms Council of Victoria

Ronald Reagan once came up with one of the best quotes I’ve ever heard, which was:

“Government’s view of the economy could be summed up in a few short phrases:

If it moves, tax it.

If it keeps moving, regulate it.

And if it stops moving, subsidize it.”

As you might know, Victoria’s Firearm Regulations are in the process of being remade, which involves the setting or resetting of fees for the various licences and permits we need to go shooting.

In some ways, this is not unreasonable.  However there are instances where the value of permits is either unclear, or not justified.

We found an obscure one which threatens our own ANZAC and Remembrance Day commemorations.

Popular Place Permits

Under Victorian law, it is an offence to carry a loaded firearm, or use a firearm in a ‘populous place’, unless you have a permit.

Permits are often sought by food producers (to eradicate pigeons), seeding of sporting fields (to get rid of the Corellas), pest control businesses and re-enactment groups who support ANZAC, Remembrance Days and other such commemorations, often involving our RSLs.

Permits are currently free, however the Victorian State Government is proposing to introduce a fee of $333.90 for each permit.

Why this is being proposed

The justification given in the Regulatory Impact Statement (RIS) is that permit applications involve a site visit by Victoria Police and preparation of a report before the permit can be issued.  We’re reliably informed that some visits do occur, but aren’t always done.  What they do always do, is require the applicant to provide insurance details, detailed drawings and safety procedures.

The other part of the justification in the RIS for a fee is that the activities under a populous place permit is for the “benefit specifically for the applicant … as opposed to  … broader taxpayers”.

This is surprising, given commemorative events are held by volunteers for us all, as is the seeding of our sporting grounds.

Flawed logic in costs

As noted above, the permit fee is justified on the basis of police resources used to visit sites and write reports.  Apart from the fact these do not always occur, there is nothing in our Firearms Act or regulations which requires them to be done.  In other words, we’re being asked to pay for activities which have no legal basis.

Given that the ‘regulatory burden’ will fall on volunteers and others who are only trying to provide a community service, the prospect of high fees is a serious oversight.

The Yea & District Volunteer Memorial Rifles group is an example. They have advised us the proposed fee will stop them from being able to support commemorative services.

It’s probably the sort of thing Reagan had in mind when framing his famous quote.

Then you’ve got small businesses who need permits to do what they do.  If they need 10 permits a year, then they’ll be up for over $3k.   Given the pressures many small businesses are under to stay afloat, the high fees and the snowballing paperwork they need to provide creates a disincentive to comply with the law.

Our submission

Submissions to the RIS closed today.

While our draft submission (which many of you saw and commented on) did not include this, we have now added it to our submission – with a recommendation that there be no fee.  Other shooting organisations have done the same, so be assured we have this well covered.

Target shooting on private property – a new requirement to give 48 hours notice

Another item we added to our submission relates to target shooting on private property.

Currently, in Victoria, there is a requirement to notify Victoria Police of target shooting on private property that is likely to involve more than 5 persons and lasting more than 3 hours.  The argument put forward for having a notification requirement is that it helps police deal with complaints from neighbours and others.

The proposed regulations would, if adopted, require that notice to be given at least 48 hours before the activity occurs (to better enable the police to respond to complaints) – otherwise it’s a fine of $8,000 or a year in jail.

The advice we have received is that this proposed requirement is not only impractical, but ignores the impact which inclement weather or other changes in circumstances can have.

Putting aside the question of why notification is required at all, we’re arguing that this change makes no sense and is not supported.

We’re suggesting that if the regulator has any concern with how the current arrangements work, it should be referred to the Firearms Consultative Committee.

We’ll keep you posted on what happens with the submissions.