Also reported on here in Irish Shooting Politics with slightly more verbosity.

A little while ago, I was sent a document with various redactions by a source who wishes at this time to remain anonymous. The document was quite disturbing in nature, and I sought to verify its authenticity through other avenues. At present, I'm waiting on a number of FoI requests from the PTB, but I have unofficial confirmation from them that the document is real and was submitted to the Department by the NASRPC in June 2009, during the final run-up to the passing of the Misc.Provisions Act. I have confirmed that the document did not go to the DoJ via the SSAI or via the FCP but was sent in directly to the DoJ. The proposals in the document were described by officials in the DoJ (again unofficially) as "untenable and illegal" - and I think that says a lot about the impact that the document had on our appearance at the negotiation table during a fairly sensitive and critical time. While the FoI requests are still pending, and I'll post the outcome of them here, I was able to source an unredacted copy of the document from other channels and a copy is attached to this post (it's only 12 pages of text, it's a short read).

There are a number of things contained in the document that are deeply unpalatable. I went into them in some detail in the blog post, but here's the summary:

• It is effectively an NGB (which legally is basicly a club and thus not bound by any part of the companies act and who don't even have to follow their own rules, let alone anyone else's) seeking to obtain control over a state licencing function, namely the licencing of centerfire pistols.
• It proposes new rules and restrictions on ownership of centerfire pistols that go far beyond those that even the Minister was proposing in the Act, including:
  • Mandatory safety training courses to be taken (run by the NASRPC)
  • Mandatory safety testing to be passed (again run by the NASRPC)
  • A smallbore or fullbore rifle licence held for a year to be a mandatory prerequisite for an application for a pistol licence
  • A mandatory 24-month apprenticeship programme to be subsequently undertaken by all applicants with a smallbore pistol under the NASRPC's supervision and evaluation (for a total of three years the applicants spend certified for firearms they ultimately neither want nor need)
  • Two safes to be installed, to a standard beyond that specified by [url=https://us.v-cdn.net/6034073/uploads/attachments/17587/87248.pdf[/url], the pistol to be broken into two parts and those parts stored in seperate safes
  • A steel strongbox to be bolted, welded or chained to the chassis of the applicant's car for storage of the pistol during transport, along with other related regulations
  • Mandatory entry into NASRPC-run competitions to be a condition of the licence
  • The kind of pistol sought must be "deemed to be a suitable target pistol" by the NASRPC (which would require that the NASRPC prepare and maintain a "list" of the only centerfire pistols anyone could licence) - and it specifically states it will prohibit the licencing of Glock pistols.
  • The official recommendation of the NASRPC required in the form of a letter of support for an application
• It segregates the target shooting community into a hierarchy of worthiness to own a pistol as follows:
  Where 'D. Others' are described in the text as 'dinner party Glock owners' and would be prohibited from owning a pistol.
• It sets up a framework which would make the repeal of the current de facto ban on centerfire pistols much more difficult than if it was solely set forth in the Firearms Act
• It explicitly gives a veto (and pledges the NASRPC to police that veto) over whether or not disciplines will be shot, to the Irish Sports Council as well as the DoJ and the Gardai
• It calls for a cap to be placed (at 800 licences) on the number of centerfire pistol licences which can exist in the State at any one time, relying on the "dead mans boots" procedure to issue existing licences to new applicants, who remain on a waiting list indefinitely until that happens, despite having invested three years and a lot of cash by this point
• It creates the role of Club Armourer, who would be given possession of a component part of every pistol owned by a member of that club upon their leaving the range, and who would be responsible for the secure storage of that component part until that shooter returned to the range, where shooting could only take place on designated days as a result; or to bring that component part to whatever range the shooter was going to for away competitions. There would also be a Deputy Club Armourer, and it would be a mandatory requirement of your licence that you be a member of a club which had both of these roles filled by appointed people. Apart from the obvious logistical problems that creates, it introduces the scenario where such a Club Armorer could be in possession of sufficient component parts to assemble a pistol from them which would be both unlicenced and almost untraceable. It also glosses over the legal requirement for a licence to be held by each Club Armourer and Deputy Club Armourer for each pistol -- as a component part is, under the law, a firearm in its own right and requires a licence to possess -- which means that despite there being an NASRPC Cap of 800 licences, there could only be 266 actual pistols in the country at any one time.
• It sets forth conditions on the ownership of handguns, but was submitted solely by the NASRPC, even though the NASRPC is only one of seven NGBs that administer pistol shooting sports in Ireland (the NTSA, the NASRPC, the Pony Club, the IBS, the ITS, the MPAI and the NSAI all use pistols in their events) and only one of five that administer centerfire pistol disciplines, and not one of the two which absolutely require centerfire pistols for all of the sports they oversee. And it was prepared in secret, never revealed to the community as a whole, either before or after its submission to the Department.

The procedure the NASRPC proposed in this document was as follows:



I think that given the questions and demands that were put to the SSAI Chairman in public meeting by NASRPC committee members recently (including those who drafted this document) -- as well as for other reasons which I can't divulge until the FoI requests are responded to -- this document should see the light of day, even if only to give context to the criticisms which I understand are to be raised at the upcoming SSAI AGM in order to support a bid by the NASRPC committee to take over that body. If the NASRPC committee members wish to run the SSAI and represent a large proportion of the shooting community on the FCP and to the Department of Justice, then an example of the kind of regulations they draft when given a completely blank canvas should be more widely appreciated.

It seems only fair.