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SSANZ Submission: Supplementary Order Paper 408


Submission by: Sporting Shooters Association of New Zealand Inc. 28 November 2019


Submission on Supplementary Order Paper 408


This submission has been approved by the association’s elected executive committee.


We wish to speak to this submission.


The Sporting Shooters Association of New Zealand Inc, (SSANZ) was established in 1992 and is a voluntary advocacy group for licensed firearm owners; our members participate in a wide range of shooting disciplines and are located throughout New Zealand.


SSANZ is an active member of COLFO, Council of Licensed Firearm Owners and FSCANZ, Firearm Safety Council of Aotearoa New Zealand. Most of our members have a life time experience of shooting and safe firearm ownership.


Many were MSC firearm safety instructors who acted for New Zealand Police training new firearms license applicants in firearm safety and conducting the safety test, this face to face training was disestablishment in 2018.


We contend that arms control should be conducted in a spirit of cooperation between those who administer that control and those who own firearms. It is through cooperation that the best compliance with the law is achieved.


As a result of the first Arms Amendment Bill passed after the Christchurch attack on 15 March and the negative consequences to the well being, ability to participate in their lawful sport or hobby and even earn a living, there is now a deep sense of mistrust of the police hierarchy and government by many licensed firearm owners, who now see the police as their enemy.


This mistrust is further exacerbated by the Arms Legislation Bill 2019 which for many will destroy their opportunities and enjoyment of shooting sports. It is also disappointing to note that in drafting this SOP the declared purpose of which is public safety, the Minister did not consult with the Firearm Safety Council of Aotearoa New Zealand or the wider firearm community.


We oppose this SOP for the following reasons:

  1. It is premature, since the Royal Commission of Inquiry into the Christchurch terror attack on 15 March has yet to publish its report.
  2. The period set aside for public submissions is too short to allow for careful consideration and comment on an extremely complex Bill that is further complicated by this SOP.
  3. The Government’s stated intent to pass this Bill into law in time for the anniversary of the Christchurch terror attack is distasteful political grandstanding, which is likely to further reduce acceptance of the Bill as amended by this SOP by those most affected
  4. The stakeholders, the firearms community, were not consulted in any meaningful way in its drafting.
  5. It targets respectable and lawful licensed firearm owners rather than criminals who use firearms
  6. We have great concerns that under New Zealand’s Arms Act Police have a conflict of interest in that they are both creating, administering, policing and prosecuting the law. There is nothing in this SOP that addresses that issue.
  7. It confers too many powers to make regulations on the Commissioner of Police. Evidence of this is already being seen with more and more firearms being added to the “prohibited list”.
  8. Regulations associated with this SOP and its parent Bill have not been made public.
  9. This new Bill and its raft of new regulations is made even more complex by this SOP and will prove hard for the average person to comprehend all of its requirements, leading to many unjust prosecutions of firearm owners for genuine mistakes, particularly since even the police cannot answer questions put to them on technical matters.
  10. It is uncertain when the firearms prohibited by this SOP will be added to the buy-back list, or at what value.
  11. It does nothing to improve public safety.
  12. The 1983 Arms Act, which has served New Zealand well for the past 3 decades, only requires minor adjustments in order to keep New Zealanders safe.


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In addition to the above general comments we refer you to our opposition or comments on the following specific clauses:

In its attempt to control the proliferation and use of shoulder stocks (pistol carbine conversion kits) that can be used with semi automatic pistols the government has created more complexity and confusion with possible unintended consequences.


Clause 6 (1) the definition of air pistol carbine conversion kit and pistol carbine conversion kit is too vague as it captures butt stocks that may be fitted to historic pistols such as a WW I Artillery Luger and the Borchardt Self Loading Pistol, pictured below, as well as those fitted to many other antique and historical pistols, revolvers and flare pistols. Surely this can’t be what is intended by this SOP?


TOP: Borchardt Patent C-93 Self Loading Pistol valued at over $30,000. BOTTOM: WW I Artillery Luger with butt stock and holster.


We recommend the following alternative definition of a pistol carbine conversion kit: means a frame or shoulder stock that by its addition to a semiautomatic pistol of a type defined as a small semi automatic pistol allows it to be fired from the shoulder.


In its attempt to prohibit possession of a few hundred short MSSAs, which are classified as pistols by virtue of their length being less than 762mm and were overlooked in the first rushed legislation change, the government has created a new definition for a pistol (Small Semi Automatic Pistol). Again this further complicates the legislation and has further unintended consequences.


Clause 6 (1): The definition of Small Semi Automatic Pistol Paragraph (d) what does “suitable” mean and who decides what is suitable? What is the effect of this definition on semi automatic pistols that fall outside the listed parameters? For example a Webley Model 1906 or a Baby Browning, pictured below.


LEFT: Baby Browning, barrel length 53.6mm; Webley M1906 barrel length 86mm.


It should also be noted that this definition is a change to the long held legal definition of a pistol that has been used in 1000s of court cases, and could result in loop holes leading to acquittal of some offenders.


Clause 6A: Under the new definition of a Prohibited Firearm pistols that fall outside the definition of a “small semi automatic Pistol”, such as the two pictured above and many more collectable pistols, become prohibited firearms. Is this really what is intended? It should be noted that possession of these pistols is already restricted by requiring a C endorsed licence and a permit to import and procure/possess.


We recommend that the definition of a Small Semi Automatic Pistol should amended to be: a semi automatic pistol that - a) has an overall length of 400mm or less and b) has a muzzle velocity of 1,600 ft/sec or less. Thus allowing pistols that fall outside the original definition to be retained as C endorsed pistols and NOT prohibited.


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Clause 6A - Section 2A 1 (b): We object to the provision for any firearm to be declared a Prohibited Firearm by Order in Council. This effectively allows the Minister of Police to ban any or every firearm in New Zealand without reference to parliament. It is a step too far!


Clause 31 - Section 22 BA: This will require people who have up to now owned butt stocks for pistols (now termed carbine conversion kits), with out a need for a licence or endorsement to obtain one in order to retain these collectable and valuable items. The Crown should cover any additional licensing cost. As they should have done for all those people who were required to obtain P endorsed licences to retain prohibited firearms, magazines and parts.


Clause 74 - Section 59 A: We welcome the reinstating of this provision to provide a form of amnesty via dealers, which was removed by the first post March amendment to the Arms Act.


Clause 82A (2) - Section 74A (c): We oppose the provision to declare any pump action firearm a prohibited firearm by Order In Council. We have seen no evidence to suggest that pump action firearms are any more lethal than any other action type.


We also note and object to the fact that with all these additional powers to declare firearms prohibited and thus require their surrender to the government there is no mention of an amnesty to cover the transitional phase nor is there provision for compensation for seized property. A gross injustice towards lawful owners of affected firearms.



Reject SOP 408 in its entirety, or alternatively;


Redefine pistol carbine conversion kit to mean: a frame or shoulder stock that by its addition to a semi automatic pistol of a type defined as a small semi-automatic pistol allows it to be fired from the shoulder.


Redefine small semi automatic pistol to mean: a semi automatic pistol that - a) has an overall length of 400mm or less and b) has a muzzle velocity of 1,600 ft/sec or less.


Retain Clause 74 - Section 59A

Provide a mechanism for compensation to be paid for any additional firearms that become prohibited.


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