Combined Firearms Council of Victoria

With the Victorian State Election now less than 5 months away, the CFCV has issued an election wish list to the major parties. 

At the top of this list is an ‘efficiency review’ of our firearms registry.

Should we have a registry?

The fact we even have a registry is one of the hottest topics around for shooters.

One can argue against a registry on the basis of the erosion of shooters’ rights and a distrust of government, but the argument for one is about the responsibility that comes with owning firearms, and their traceability.

Both have merit and you will even find differences of opinion on the topic within the CFCV.

The efficiency of administration

However, the more common concern shooters seem to have with the registry though, is the way it is administered.  The quality of decisions they make, the amounts they charge, data errors, the complexity of forms and the way they engage with the shooting community, are second rate.  No longer do they provide over-the-counter service.    This would not be tolerated of other regulators, such as VicRoads, but it is what has been served up to us.

Its not the fault of the ‘foot soldiers’ who work there, but those who have the ability to change things for the better.

The costs we pay for the registry are based on what is called ‘full cost recovery’.  In plain English, it means we pay for everything the registry does.

If they are efficient, then we pay a price which is arguably fair.  If they are inefficient, then we pay anyway.  Who can explain why the fees we pay are set at the levels they are?  Why should we pay for database errors, when we have provided the registry with the correct information?

Other things we pay for

While they might be seen in a disproportionate light, there are other activities Victoria’s registry have been engaging in are questionable, but which we have been paying for.

Examples include the wasted effort it spent on the ‘transportation’ guidelines which misrepresented what the Firearms Act requires us to do when transporting firearms.  They’ve embarked on a projects to increase storage inspections, when there was no data or explanation given.  They’ve had policy discussions with the Department of Justice and Regulation without involving the shooting community and lobbied the media on the adequacy of our firearm storage laws.

While each of these are activities which could be legitimate for a regulator to do, the approach they have taken has led to wasted resources and angst. Which we pay for.

Where are their policies?

The other element of administration is the policies our regulators have in place to discharge their duties.  If a regulator has no policies to guide it, then they’ll never make good decisions.  Instead the decisions they make will be arbitrary and unfair, and always open to challenge.

Attempts over the past few years to identify what, if any, admin policies exist, have gone unanswered.

No wonder shooters are irate at this.

Transparency of our registry 

Given shooters are the ones who pay the bill, you would think we would be entitled to test this, but we aren’t.

Our registry does participate in the “Firearms Users Group” with industry – and we appreciate that they do this – bit it hasn’t ‘lifted the veil’ on what efficient regulation looks like, or fixed the problems we have.

Part of the reason we haven’t been able to do this is obvious.  Shooters are not experts in registry processes or have worked there (other than one person I know of) which means we don’t know what the right questions to ask are.

We don’t know “where the bodies are buried”.

If we did, we wouldn’t be paying the fees we are paying now.

The CFCV’s proposal

The concerns we’ve heard about the registry have been around for at least twenty years.

The proposal the CFCV has put to the major parties to address this is for a parliamentary inquiry into improving the efficiency of the administration of the Firearms Act.  There are a few aspects to this.

1. We don’t want the review to backfire on us: A more open review invites opposing interests to call for more regulation of what we do. That’s not what we’re seeking.  The proposal is for the review to be on ‘efficiency’, which no reasonable person can possibly argue against.

2. We want open debate on the findings: If the review is conducted by a parliamentary committee, then it has two advantages. First, is that it provides more open opportunity for shooting industry interests to propose questions for the review to answer, and the second is that a parliamentary report is more likely to be considered by parliament and subjected to open debate. We need this to end in real action, not just a report.

The review is about the administration, not the Act

Importantly it should be understood that this review is about the way the Firearms Act is administered.

It is not about the Act.

While we could have long debates about how the Act can be improved – and there is no doubt that it can – that would be a distraction which would take us away from the fact it needs to be administered efficiently.

We just want what we have to work better.  We just want our regulator to ‘stick to its knitting’ and do what it can to be efficient and lower costs for all shooters.