National Coalition of Provincial and 
Territorial Wildlife Federations




Presentation to: the Standing Committee
on Justice and Legal Affairs



Bill C-68





                                                              May 15, 1995.


                                                                           

  
                              TABLE OF CONTENTS
                                   
                                    
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1
  
Need For Additional Gun Control? . . . . . . . . . . . . . . . . . .  1
  
Consultation and Development of Federal Firearms Policy
   . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  7
  
Bill C-68:  Firearms Act  vs. Criminal Code. . . . . . . . . . . . .  9
  
Mandatory Licencing of Firearms Owners . . . . . . . . . . . . . . .  9
  
Universal Registration . . . . . . . . . . . . . . . . . . . . . . . 11
  
Benefits of Registration?. . . . . . . . . . . . . . . . . . . . . . 13
  
 Prohibition of Currently Restricted Rifles. . . . . . . . . . . . . 15
  
Additional Handgun Prohibitions. . . . . . . . . . . . . . . . . . . 16
  
Other Prohibitions . . . . . . . . . . . . . . . . . . . . . . . . . 17
  
Import and Export by Individuals . . . . . . . . . . . . . . . . . . 18
  
Gun Collectors . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
  
Powers of Inspection Granted to Police Officers. . . . . . . . . . . 19
  
Regulation of Shooting Ranges. . . . . . . . . . . . . . . . . . . . 20
  
Governing by Order-in-Council. . . . . . . . . . . . . . . . . . . . 21
  
Summary and Recommendations. . . . . . . . . . . . . . . . . . . . . 22
  
List of Appendices . . . . . . . . . . . . . . . . . . . . . . . . . 23
  
  
    Introduction:
     
Representing over 500,000 members across Canada, the National Coalition
of Provincial and Territorial Wildlife Federations (N.C.P.T.W.F.)
consists of all of Canada's provincial and territorial wildlife
federations or associations:  a unified voice of conservation minded
anglers and hunters.  All our organizations are committed to and
advocate the continued ownership, safe storage and use of all now
legally possessed firearms by Canadian citizens, including hunting
rifles, shotguns, handguns, other restricted and registered firearms,
and grandfathered prohibited firearms.

Membership in our organizations is voluntary, and open to anybody who
participates in the conservation and wise use of  Canada's natural
resources and supports sporting activities related to these natural
resources such as hunting along with other shooting sports.  Members
join our organizations individually, or through organized local member
clubs.  They come from both urban and rural areas,  have varying
economic status, different cultural backgrounds, but overwhelmingly,
own and use firearms legally and responsibly.

Individual members of the organizations that make up the National
Coalition come from both urban and rural areas of the country, in
varying percentages.  In the more rural provinces,  the vast majority
of our membership base is, understandably  from the more rural areas of
the province.  In the provinces with large urban centres, the
urban-rural membership division moves closer to 50/50: indicating a
strong dedicated interest in conservation and the shooting sports among
urbanites. There is not an urban centre in Canada without strong,
vocal, informed and active members and affiliated clubs.

Established  in the summer of 1994 out of concern for Mr. Rock's
apparent intent to target law- abiding citizens with even more
restrictions and unnecessary laws, the National Coalition developed and
presented its policy statement based on the preceding paragraphs to
Members of Parliament, Members of Provincial Legislative Assemblies,
and to the public.

On November 30, 1994, the Federal Minister of Justice, Allan Rock,
announced the government's proposals for changes to the federal
firearms control regime.  The proposals entail changes to virtually all
aspects of Canada's firearms control system, including those aspects
amended as recently as 1991, and implemented as late as 1993.

Those aspects of the proposals which target law-abiding firearms owners
are a breach of a Liberal Party election promise that expressly stated:
"We will ensure the criminal use of firearms is penalized but
legitimate users are not."


Need For Additional Gun Control?

It is the position and submission of the N.C.P.T.W.F. that further
amendments to Canada's firearms control regime cannot be justified on
the basis of strong directives from an informed society, or failure of
our existing controls, or a pressing need to address rising crime
rates, or a reasonable expectation of cost effectiveness, or any
expectation that toughening up the controls on Canada's legal firearms
owners will have any impact on crime.

Canadians, those who own firearms and those who do not, are
increasingly questioning the basis for the proposed changes in the
legislation affecting the ownership, possession and use of firearms by
the non-criminal majority of Canadian firearms owners, particularly as
more Canadians become aware of the content of the draft legislation,
and the laws and regulations already in place.

Although the government claims wide-spread support for the proposed
amendments, polls of uninformed people are no basis to govern.  When
asked, virtually everybody will say we need "gun control" or "better
gun control" simply because there are criminals perpetrating crimes in
Canadian society with firearms.

Those who do not own firearms or have not been exposed to the
non-criminal aspects of responsible firearm ownership have very little
conception of what actually is involved in legally obtaining and using
even a non-restricted firearm in Canada.

This government, along with previous governments, has done a dismally
poor job in public education of Canada's firearms laws and the polls
relied upon by the Minister of Justice to indicate support for his
proposals show only the degree of ignorance of Canadian society.

A national public opinion survey just recently conducted by Canadian
Facts, Inc., for Simon Fraser University (S.F.U.) reveals that
Canadians know little about existing gun control laws and that their
support for firearm registration weakens as they become more
knowledgeable about the issue. This knowledge includes the "hidden
costs" associated with firearms registration.  The S.F.U. study also
reinforces the findings of other surveys indicating that Canadians
place a very low priority on stricter gun control laws as a method of
combating violent crime.

Only eight per cent of Canadians describe themselves as "very familiar"
with current gun laws, while 27 per cent stated they were "not at all
familiar."  A number of "skill testing questions" verified this lack of
knowledge.  Only three per cent knew the maximum penalty for having an
unregistered handgun is five years. Less than half (47 per cent) knew
that a police permit is required to purchase a rifle or shotgun. Only
21 per cent knew about the existence of a mandatory government firearms
safety course, just two per cent knew that letters of reference were
required from gun purchasers or that gun shops must keep a record of
their names and addresses.

Canada's gun control program seeks to reduce accidental, intentional
and criminal misuse of firearms, to keep firearms out of the hands of
those who should not have them and to encourage and ensure responsible
firearm ownership and use.  Such aims and objects are fully supported
by the N.C.P.T.W.F, as they are by all responsible firearms owners
across Canada.  The current program however is complex and expensive,
and may not be yielding an appropriate return with respect to
measurable decreases in firearms crime or other firearm misuse, along
with measurable increases in public safety.

In 1993, the Auditor-General of Canada's Report to the House of
Commons(ENDNOTE 1) contained a detailed review of our gun control
program and found that the gun control regime instituted in 1978 has
never been adequately evaluated, either prior to or subsequent to the
amendments contained in Bill C-17.  The Auditor-General believes it
"essential that the Department of Justice evaluate the effectiveness of
the program again.  Members of Parliament  and the Canadian public need
to know whether the means the government has chosen to achieve the
program's objectives are working".(ENDNOTE 2)

Although written in 1993, these comments are still valid.  The
Department of Justice still has not publicly reviewed the effectiveness
of Canada's firearm control regime.  It therefore has no reasonable
basis for any further restrictions.

Included in the published Auditor-General's Report is the response from
the Department of Justice which states in part (in defence of the
changes that were implemented as a result of Bill C-17 without adequate
justification), "... the legislation and regulations were driven by
clear public interest considerations, which needed to be acted upon
despite the absence of precise data."(ENDNOTE 3)

It appears that this government is attempting to proceed, in Bill C-68
with additional amendments to legislation and regulation to again cater
to an uninformed public with total disregard for the precise data that
does exist.

The Department of Justice does know that Canadian women are as likely
as men to be victims of violent crime; however, weapons are used
against 31% of men compared to 19% of women.  (ENDNOTE 4) The most
common weapons used in violent crime are "other" weapons (such as motor
vehicles, fire, poison, hot water), followed by sharp
instruments(ENDNOTE 5).  Firearms of all types are used in only 5% of
all violent crimes in Canada; handguns less than 2.5%.(ENDNOTE 6)

Restrictive gun control in Canada has had no perceptible impact on
violent crime since its introduction in 1978.  The American states
bordering Canada have homicide rates similar to ours despite easier
legal access to firearms and liberal handgun laws.  There is absolutely
no evidence which supports the hypothesis that the types and
availability of firearms are directly related to increasing violent
crime rates or the criminal use of firearms. In the absence of
firearms, criminals switch to other weapons or other sources of
weapons.

The Department of Justice has not been able to establish that increased
gun controls or laws in any city, state, or nation has ever reduced
violent crime or slowed its rate or growth compared to similar
jurisdictions without such laws.

Statistical reporting by the Canada Centre for Justice Statistics shows
that two-thirds of all Canadian homicides do not involve
firearms(ENDNOTE 7). Stabbing, beating, and strangulation account for
the majority(ENDNOTE 8).

In 1991, two-thirds of all accused murderers had prior criminal
records, of which 69% were prohibited from acquiring or possessing
firearms due to previous violent offenses.(ENDNOTE 9)

Firearm homicides typically represent less than 2% of all unnatural
deaths in Canada and between 1961-1990(ENDNOTE 10),  and less than 1%
of all homicides involved firearms legally registered in Canada.
(ENDNOTE 11)

Alcohol and drug use was evident in over 50% of all homicides in
1993(ENDNOTE 12).  Historically, alcohol abuse has been estimated as
the most important contributing factor in two of every three homicides
in Canada, and accordingly, efforts to reduce homicide should
concentrate on reducing alcohol abuse.

Domestic homicides by firearm comprise only 11% of all the homicides in
Canada.(ENDNOTE 13) These "crimes of passion" are almost always
preceded by a long history of domestic turmoil: in 1991, 44% of all
domestic murders had a previous record of violent conflict, committed
between the hours of 10 p.m and 2 a.m with any object close at hand and
by persons under the influence of drugs or alcohol.(ENDONTE 14)
Existing laws, properly enforced, should be used to prevent this 11%.
They do already exist.

Between 1974-1992, over 60% of all domestic homicides in Canada
involved weapons other than firearms, with alcohol and drug abuse a
relevant factor in 64%.(ENDNOTE 15)  Between 1974-1987, the use of
firearms in domestic homicide fluctuated with "gun controls" having no
effect on the level of domestic homicide in Canada.(ENDNOTE 16)

The Department of Justice has already studied and reported(ENDNOTE 17)
on police responses to domestic disputes and the involvement of
firearms.  Clearly, homes with a long history of violent conflict are
known to police agencies. Under the existing law, a police officer is
allowed to immediately seize any firearm from such homes, without prior
judicial approval.  

The study documents that police are typically already in possession of
information relating to the presence of firearms in the home, and where
there is no prior knowledge of firearm presence, police overwhelming
inquire and are prepared to immediately seize any firearms.(ENDNOTE 18)

The Minister of Justice has often been heard citing the statistic that
a Canadian women is killed every five or six days by firearm.  This is
a shockingly true statement but it needs to be framed with the equally
shocking statistic that a Canadian woman is killed every 2 days by some
other, i.e. non- firearm, means, and that every 2 hours a Canadian
woman dies of breast cancer.(ENDNOTE 19) These numbers are reflective
of the total number of women in Canada:  13,840,000 according to the
1991 Census.

Reducing homicides in domestic situations can not be rationally cited
as a reason for proceeding with Bill C-68, not without substantial
proof that public and private moneys are better spent on firearms
control than directly combatting domestic violence in general.
Similarly, the government must clearly establish that more women's
lives would be saved by investing time, money and resources in gun
control rather than host of other more frequent causes of death.

Between 1976-1992, two-thirds of all robberies in Canada involved
weapons other than firearms.(ENDNOTE 20) The armed robbery rate for the
period 1974 (prior to restrictive gun control legislation) and 1988
remained the same and any decrease in robberies involving firearms has
been counterbalanced by the increasing use of physical force, knives
and blunt instruments.  These weapons require close personal contact,
and victim injury is much more frequent and substantially more serious
when armed robbery does not involve a firearm.(ENDNOTE 21)

Between 1969-1991, suicides accounted for 75% of all gun-related deaths
in Canada; however, over two-thirds of all suicides are committed by
methods other than firearms. (ENDNOTE 22) Aboriginals are noted as
being especially likely to select firearms as a suicide method in a
recent research report. (ENDNOTE 23) Aboriginals, however, are the
single identifiable group that are most likely to be exempted from the
majority of the provisions contained in Bill C-68: exemptions that are
to be decided upon by the Minister of Justice, not Parliament.

That same government report also notes that firearm suicide attempts
are only marginally more successful than other methods such as hanging,
carbon monoxide poisoning and drowning: all freely available
methods(ENDNOTE 24).  The same study notes that restrictive gun control
has had no effect on the suicide rate(ENDNOTE 25). The suicide rate in
Canada remains higher than the United States, but is still
substantially lower than the majority of European countries which have
extremely restrictive gun control laws. (ENDNOTE 26) The government
should look to the causes of suicide and not the implement used, if it
is serious about reducing suicides in Canada.

The accidental injury rate by firearm declined 27% between 1982-1991,
with the accidental death rate by firearm dropping 80% between
1966-1991(ENDNOTE 27).   Alcohol abuse is a significant contributing
factor in 50% of all gun "accidents" and suicides.(ENDNOTE 28)

Section 85 of the Criminal Code of Canada currently allows for
mandatory sentences of one year for the use of a firearm in crime.
However, a Department of Justice report (ENDNOTE 29) clearly
establishes that a half to two-thirds of Section 85 charges are
withdrawn, discharged, stayed or dismissed; and that those Section 85
charges that do result in convictions most often lead to sentences that
really do not contain any incremental imprisonment(ENDNOTE 30).  Any
deterrent effect of the present provisions of the Criminal Code is lost
if charges are not laid in the first place, or not prosecuted, or do
not result in additional imprisonment where charges are laid and
prosecuted.   The current laws need to be enforced.

Faced with this information,  Canadians are becoming increasingly aware
that there is no basis, justification or need for further amendments to
Canada's firearms control regime.  The Department of Justice is failing
to take responsible action against the root causes of crime in today's
society and instead, are proposing largely ineffectual amendments that
will do little to address crime.

This is amply demonstrated by the recent Maclean's / CTV poll that
found that only 5% of Canadians believe that their perceived increase
in violent crime was caused by an absence of stronger gun control
laws.(ENDNOTE 31)

We ask that this Committee do everything in its power to prevent this
unfair, unnecessary and improper process from continuing.


Consultation and Development of Federal Firearms Policy

The N.C.P.T.W.F. believes that the government was not given the mandate
to proceed with the proposed changes when it was elected, nor has it
seriously consulted with Canadian firearms owners while developing its
Action Plan and subsequent draft legislation.

  The Liberal Party's pre-election  platform, as detailed in the "Red
  Book" stated:

	"In order to combat crime, a Liberal government will work in a
	broad range of areas.  To strengthen gun control, a Liberal
	government, will among other measures, counter the illegal
	importation of banned and restricted firearms into Canada and
	prohibit anyone convicted of an indictable offence from owning
	or possessing a gun."(ENDNOTE 32)

  A Liberal Party background policy document from 1993 states:

	"The Liberal Party believes it is vital that we maintain the
	type of restrictions on firearms which have been in place in
	Canada for close to a century.  While supporting the
	government's most recent reform of gun control legislation, the
	Liberal Party fought hard for amendments which would have made
	this legislation more effective and stronger."

  and makes the following recommendations:

     1.   Those convicted of an indictable drug related offence should
	be prohibited from owning or possessing a firearm.  The Liberal
	Party moved such an amendment during the debate on Bill C-17
	(Gun Control).

     2.   Anyone convicted of stalking type offences and/or any violent
	act against a person would be prohibited from owning or
	possessing a firearm.  At the urging of Liberals, such a
	provision was included in the governments's recently passed
	anti-stalking legislation.

     3.   The federal government would work with the provinces to
	establish a system of mandatory training so that in the future,
	no one is issued a firearm without proper training.

     4.   Make it mandatory to report all lost or stolen weapons.

     5.   Take measures to counter the illegal importation of banned
	and restricted guns into Canada."(ENDNOTE 33)

On September 29, 1993, the National Liberal Caucus,  through its
Research Bureau, gave the Ontario Federation of Anglers and Hunters and
Liberal candidates for election in Ontario a statement promising:

	"We will ensure the criminal use of firearms is penalized but
	legitimate users are not."

There is absolutely no indication in the Liberal pre-election platform
that the government would proceed with the sweeping changes to Canada's
firearm control system as it now proposes.  There is no mandate given
to this government to proceed and in fact, the proposals put forward in
the draft legislation actually break the Liberal promise not to
penalize legitimate firearms owners and users.

The government's document, Background Information on Firearms Control,
was released in November of 1994, along with the Governments Action
Plan on Firearms Control.  The background paper lists groups that the
Minister of Justice has met with on the issue of firearms control.

The groups listed that are affiliated with the N.C.P.T.W.F.  through
its member organizations do not support or condone the content of the
Government's Action Plan,  and remain opposed to the draft
legislation.  With the tabling of Bill C-68, it is abundantly clear to
those firearms owners who had previously met with the Minister of
Justice that the Minister was completely unwilling to alter his
preconceived notions and proposals to address the legitimate concerns
of responsible firearms owners.

The N.C.P.T.W.F. maintains that the government has no mandate from the
Canadian people to implement the proposed amendments nor did it
seriously consider and address the legitimate concerns of firearms
owners while developing the Action Plan and subsequent draft
legislation.  The Minister did not even meet with representatives from
at least one province.


Bill C-68:  Firearms Act  vs. Criminal Code

On February 14, 1995, Justice Minister Allan Rock introduced Bill C-68
to Parliament; giving form to the Government's Action Plan on Firearms
Control, which was released in November of 1994.  The draft legislation
creates a new federal Act: An Act Respecting Firearms and Other Weapons
(Firearms Act), and completely rewrites Part III of the Criminal Code
of Canada, largely removing all non-criminal aspects of Canada's
firearm control system from the Criminal Code.

The Firearms Act establishes a licensing system for persons wishing to
possess firearms, and specifies criteria that must first be met before
such licences can be issued.  The Firearms Act also establishes a
system for the registration of  all firearms.  The content of such
legislation is however, of great concern.


Mandatory Licencing of Firearms Owners

The N.C.P.T.W.F. is opposed to the proposed mandatory licencing
provisions on the basis that the provisions are an unjustified,
expensive, ineffectual intrusion into Canadian's lives.

The draft legislation enables the limitation of firearms possession
solely to those who have licences, registration certificates and
authorizations, notwithstanding the fact that the majority of firearms
presently possessed by Canadians are possessed legally and responsibly,
but without government permits, like any number of other items of
private property.

In Canada, we licence people to drive cars, trucks, and motorcycles,
but we do not require people to be licenced maintain their rights of
possession of these articles of private property, nor is failure to
maintain a licence to use these articles a criminal offence.

The overwhelming majority of legal, legitimate, active use of firearms
already occurs under government licencing arrangements: either federal
or provincial hunting licences, or permits to transport restricted
firearms from their place of storage to government approved ranges for
target shooting.

The establishment of such a government licencing system is an
unparalleled intrusion into the private lives of Canadians:  one that
should only be allowed with the expectation of great strides in
improvement of public safety and with the clear knowledge that the
devotion of private and public moneys, resources and efforts is best
spent in this manner.

There is however, neither the expectation of improvement of public
safety or the knowledge that this is the best way to expend resources.
These deficiencies have been widely noted and documented by
individuals, researchers, academics, groups, organizations, and lower
levels of Canadian governments. (ENDNOTE 34)

Despite requests for a logical, rationally defensible justification for
imposing a mandatory licencing system,  the Minister and Department of
Justice can not provide this information to Canadians, to Parliament or
to this Committee.

The current Criminal Code allows all Canadians the opportunity to
possess firearms that they have legally acquired, in perpetuity unless
they pose a safety risk to themselves or to others.  The current
provisions of the Code allow for the immediate confiscation of firearms
from those that pose a risk, and the establishment of prohibition
orders for those who pose a continuing safety risk.

To force legitimate, responsible firearms owners into a licencing
regime that must be followed to maintain legal possession of firearms
is costly, unnecessary and wrong; and completely contrary to anything
done for any other item of private property.

The N.C.P.T.W.F. would agree that individuals who have criminal
convictions for violent offences or who have exhibited a history of
violent behaviour should not be permitted to possess firearms, but the
existing provisions of the Criminal Code already accomplish this
through prohibition orders.  Enforcement of prohibition orders will
still be required regardless of the presence of a licencing system, nor
will enforcement be easier.

The imposition of the licence requirement is an unnecessary layer of
law, bureaucracy, and red tape that will cost Canadians millions of
dollars,  and will continue to cost Canadians long into the future.

This Standing Committee on Justice and Legal Affairs should not allow
this change, requiring mandatory licencing of all firearms owners.  It
is a waste of time, money, and effort that will not produce measurable
improvement in public safety.  The N.C.P.T.W.F.  remains opposed to the
establishment of a mandatory firearms owner licencing system.

Beyond these considerations, the National Coalition requests that the
Standing Committee seriously and consciously consider the fundamental
changes that this legislation would bring about in Canadian society.
Never before have responsible Canadians faced the possibility of having
to justify their need or desire for any other item, on an ongoing
basis, just to be allowed to retain ownership.

These concerns go far beyond the issue at hand, and strike close to the
centre of Canadian concepts of personal choice, rights and freedoms.
We, as responsible Canadians, who come from every walk of life, from
every region of this county, are not prepared to allow this change to
happen.

	"... in a free society, we have never had to justify owning
	guns.  I do not "need" a car that can go three times the speed
	limit.  I do not "need" a powerboat.  There are social costs
	and security costs attached to both these items,..."(ENDNOTE
	35)


  Universal Registration

Section 13 of Bill C-68 states that one must be licenced to possess a
type of firearm before a registration certificate can be issued for a
firearm of that type.  This section is coupled with the proposed
amendment to the Criminal Code Section 91, which makes it an offence to
possess any firearm without both a licence to possess that type of
firearm and a registration certificate for the particular firearm.
Punishment upon conviction can be up to 5 years imprisonment.

Possession of an unregistered firearm by an unlicenced individual who
knows such possession is against the law can result in imprisonment for
up to 10 years upon conviction for a first offence.  Section 14 of Bill
C-68 requires unique serial numbers for each firearm that is
registered.

Coupled together, the user licencing system and the proposed
registration of all firearms held by Canadians will cost hundreds of
millions of dollars, either to taxpayers in general through funding
from federal general revenue, or from those taxpayers who are forced by
law to register themselves and each of their firearms.

The Minister of Justice can not accurately forecast the potential cost
of the proposed registration system, largely because no one knows the
actual number of currently non-restricted firearms currently held by
Canadians.  The Minister of Justice is proposing to institute and
establish a plastic card type registration and licencing system
supported by a network of computer systems to operate and maintain the
national database , at unknown cost.

The federal Department of Justice does know, however, that in 1992, it
cost about $82 to register each restricted firearm under the existing
system and $5.4 million was spent registering only 65,812 restricted
firearms.  (ENDNOTE 36)

It seems highly improbable that any new firearms registration system,
requiring capital outlays in new computer processing equipment, and
staff and officer training of R.C.M.P., Provincial Ministries of
Solicitor General, Provincial Police, Regional Police, and Municipal
Police, etc., could process a permit for much less.  Currently, there
are over 1.2 million firearms registered in Canada that are recorded in
the Restricted Weapons Registration System, maintained by the Royal
Canadian Mounted Police (R.C.M.P.).  Bill C-68 would require the
registration of an additional 5 to 20 million firearms at immense
government cost, assuredly more than the $85 million forecast by the
Minister of Justice.

The proposed universal registration and licencing system will also have
cost implications to every police service that is involved with
firearms control: provincial, regional, and local police services.  A
mandatory licencing system and universal firearms registration will not
be able to function without massive increases in staffing levels.

The proposed licencing and registration will require the hiring of more
police officers along with clerical support unless it is the intention
of the Government to subject Canadians across the country with
substantially reduced crime fighting and prevention capability.

The proposed registration system will also have costs to each firearm
owner established by regulation but for some firearms owners costs will
be much higher.  This stems from the requirement that all firearms must
bear a unique serial number.  Some manufacturers used the same serial
numbers year to year, while historic firearms and replicas rarely carry
any serial numbers at all.  Owners of these firearms presumably will be
forced to have an arbitrary serial number engraved as some direct cost,
and for the owners of historic collections, at great loss of value in
their firearm collection.

The firearm registry system is proposed to be accessible for updates
from direct entry computer terminals located at both gun dealers and
police stations.  Any computer-based record system that allows access
from several locations can not be secure from hacking or tampering, and
therefore the confidentiality of the system records can not be
assured.

Presently, owners of non-restricted firearms across the country feel
reasonably secure that they will not be specifically targeted by
criminals seeking firearms,  simply because their ownership is not
recorded and is not accessible.  An insecure listing of all the
firearms in Canada, along with their location, will end this.

Similarly, the non-firearm owning public that are indirectly receiving
benefits stand to lose out as well.  Presently, criminals when they
choose to burglarize a home, face roughly a 25% chance that the
homeowner possesses a firearm.  An insecure listing of all the firearms
in Canada, along with their location,  will allow criminals to pick and
choose which house to break into, with absolute assurance that
registered firearms are not present.

This alone is reason enough not to proceed with a universal firearms
registry and licencing system.


Benefits of Registration?

In The Government's Action Plan on Firearms Control, a number of
benefits are linked to the proposed system of universal firearms
registration.  A universal registry system is supposed to:  deter and
control theft, diversion and smuggling of firearms; ensure compliance
with transfer and safe storage requirements; assist in police
investigations;  better prepare police as they respond to domestic
disputes; enable police to enforce prohibitions orders by ensuring
surrender of all firearms owned by the individual;  assist in
international small-arms control; and gather statistical information
about firearms owners. In all but the last, the supporting arguments
are specious and worthless.

Handguns have been registered and their legal possession strictly
controlled in Canada since 1934, yet  the use of handguns by criminals
continues unabated.  Registration certainly has not done anything to
reduce the theft and diversion of handguns from commercial shipments,
and smuggling remains the largest source of illegal handguns in
Canada.

There is absolutely no indication that Canadian firearm owners are not
complying with the storage and transfer requirements established by
law.  The claim that universal registration will assist in police
investigations unjustly and incorrectly assumes that registered owners
are the individuals that will be committing crimes:  the Canada Centre
for Justice Statistics reports otherwise.(ENDNOTE 37)  Less than 1% of
the homicides that occurred in Canada involved a registered restricted
firearm and there is absolutely no indication that these firearms were
used by their legal owner.

The claim that a universal registration system will allow police to
better prepare themselves when responding to domestic disputes can not
be supported either by past study or common sense.  A Department of
Justice study in 1991(ENDNOTE 38) showed that when police respond to a
domestic dispute call, 7 out of 10 officers were typically already
aware of firearms presence in the home, 8 out of 10 officers typically
asked about the presence of firearms, 19 out of 20 officers typically
asked about threats of violence, and nearly all exhibited or expressed
a willingness to seize, with or without warrant, any firearms present
in the home.

Common sense would surely dictate against reliance on any registration
system by police officers responding to a call . To do otherwise would
create the risk of making a deadly wrong assumption that there are no
firearms in the home, when in actuality, there are indeed firearms that
may be used against the officers.

Prohibition orders filed against a criminal are currently enforced by
the police by confiscation of firearms on hand, along with the strict
prosecution of violations of the prohibition order and prosecution of
the associated offence of wrongful delivery.   These two offences will
still require strict enforcement,  and there is no documentation  to
indicate that firearms are not being confiscated when prohibition
orders are placed.

It goes beyond reason to argue that registration of all  the firearms
owned in Canada by individuals will assist in international small-arms
control when laws in the majority of the United States allow for
completely unrestricted access to almost any type of firearm and
commercial and retail firearm business in Canada is only a fraction of
the American business volume.

Surely improvements to the tracking and control of large commercial
shipments of firearms through Canada would yield better results and
control.  The firearms now owned and those likely to be purchased by
Canadians are not the type of firearms that the international community
is concerned about: Canadians, under the current law, can not purchase
fully automatic firearms.

As previously mentioned, the draft legislation causes great concern
that the refusal to renew licences and registration certificates will
be improperly used in order to prevent law-abiding Canadians from
retaining firearms they now legally own and possess.  Legislation that
allows the usage of the registration certificate or licence refusal to
current owners of restricted firearms who acquired their firearms for
the purpose of target shooting, but for various reasons, are presently
unable to target shoot should not be supported by the Standing
Committee on Justice and Legal Affairs.

Providing these firearms are stored safely, and there is absolutely no
indication that they are not stored safely in accordance with the
current law,  there is no reason for preventing their continued
ownership and possession, even though their originally stated purpose
for acquisition is not currently applicable.

While provision for appeal of such refusal is provided elsewhere in
Bill C-68,  forcing responsible Canadians to the Courts to make them
justify their continued possession of their legally acquired and
possessed property runs against any common conception of fairness and
decency,  nor can such measures be rationally supported by any
expectation of increases in public safety.

Registered handguns and restricted rifles are not used in crime by
their owners nor are they specifically the target of thieves who
subsequently use them in crime after they are stolen.  Studies of the
origin of firearms used in crime demonstrate this point clearly.
Project GunRunner found that 86% of the handguns it removed from the
hands of criminals had never been registered in Canada and thus were
not stolen from legitimate owners.(ENDNOTE 39)

The N.C.P.T.W.F. rejects the governments claims that a universal
registration system will provide benefits.  A universal registration
system will not be beneficial.  The proposed registration system will
only be costly: both in terms of reductions in public safety and
increases in direct financial costs.


Prohibition of Currently Restricted Rifles

Section 12 of Bill C-68 sets out in law, who may legally possess
particular types of firearms, and again, largely repeats the existing
status and laws:  people who now legally own and possess fully-
automatic firearms will be allowed to continue to possess these
firearms, as will owners of converted semi-automatics, and owners of
other firearms declared prohibited under Prohibited Weapons Order
Number 12.

Section 12 does contain some differences from the current law by
prohibiting the future possession and ownership of a class of firearms
that, up until January 1, 1995 were classified as "restricted" and as
such, possession was strictly limited and controlled.  These firearms
are now classed as prohibited weapons as a result of Prohibited Weapons
Order Number 13 and Canadians who legally possessed these restricted
firearms prior to January 1, 1995 will be allowed to retain possession,
and transfer ownership only to other current owners of similar
firearms.

The draft legislation will prohibit further acquisition of these
firearms by current non-owners of this class of firearms, so that
eventually, there will be one single person in Canada that can legally
possess this class of firearms which consists mainly of semi-automatic
rifles.  This one person could potentially own over 13,000 of these
firearms.

The prohibition of the firearms specified under Prohibited Weapons
Order Number 13 (Semi- Automatic Rifles) cannot be logically supported
by the government as it seeks to improve public safety since these
firearms were already under strict restriction and regulation.  The
owners of these firearms maintain registration permits, permits to
transport, and comply with increased storage requirements, while these
firearms are functionally no different than hundreds of thousands of
other firearms legally owned in Canada.

There is absolutely no indication that these type of firearms are used
disproportionately in crime, or that the owners of these firearms have
not been complying with the existing laws and regulations that controls
and places limits on their ownership and possession of these firearms.

There is no basis for the change in status of these firearms, and no
basis for the prohibition of these firearms.  The controls on these
firearms prior to the passing of Prohibited Weapons Order Number 13 was
more than sufficient and public calls for prohibition of these firearms
is based on a erroneous assumption that these firearms are fully
automatic: an assumption that this government is unwilling to correct
through public education.

Although this Committee does not have the authority to revoke
Prohibited Weapons Order Number 13,  the Committee should not give
legislative substance to the Order and therefore, Section 12(5) of Bill
C-68 should be withdrawn.


Additional Handgun Prohibitions

Section 12(6) of Bill C-68 establishes, through legislation, an
additional class of prohibited firearms:  handguns with barrel lengths
under 105 mm (4.14 inches) or in .25 or
.32 calibre.  This prohibition
will affect over 555,000 handguns now legally owned and registered by
Canadians across the country.

While current owners of these handguns will be allowed to retain
possession, they will only be permitted to transfer ownership to other
current registered owners of these firearms but not to their heirs.
Effectively, these firearms will lose all their monetary value, and any
sentimental or cultural significance these firearms hold will be lost
upon the death of their current owners.  This is delayed confiscation
without compensation, of legally acquired private property.

The prohibition of .32 calibre handguns will also effectively destroy
any future involvement of Canadians in Olympic and other international
competition, since this calibre is commonly used in these
competitions.  Canadian shooters are currently among the best in the
world,  and shooting is one of the few sports where Canadians
consistently rank at the top.  It is unacceptable that the government
should seek to wipe out  the future of our competitive shooting
sports.

We understand that this Committee will be examining the feasibility of
allowing some additional new acquisitions of .32 calibre handguns in
order to allow the continuance of Canada's competitive shooting sports
participation.  The N.C.P.T.W.F. believes that this Committee should go
further than just exempting particular models of handguns in .32
calibre;  this Committee should strike out Section 12(6) of Bill C-68
entirely, as well as the proposed change in definition of a prohibited
firearm in the Criminal Code  Section 84.

This Committee must bear in mind that the future of Canada's
competitive handgun shooting program is not entirely dependant on the
sanctioned acquisition of a few models of highly specialized and
expensive handguns.  Canada's competitive handgun shooting is dependent
on allowing Canadians to continue to become involved in the shooting
sports, at an entry level.  This means allowing, with only minimum
government interference that otherwise would effectively discourage
involvement,  the acquisition and use of inexpensive handguns by
responsible Canadians that comply with reasonable laws.

The classification of .25 and .32 calibre handguns along with handguns
with barrel lengths less than 105 mm (4.14 inches) as prohibited
weapons cannot be supported:  registered handguns (including the
555,200 that would be declared prohibited) in the hands of legitimate,
legal owners account for less than 1% of the homicides that occurred in
Canada from 1961 to 1991(ENDNOTE 40).  Clearly, additional police
effort needs to be directed at enforcing prohibition orders and
stopping the black market smuggling operations.

The prohibition of handguns with barrel lengths less than 105 mm (4.14
inches) cannot be justified with the statement that such handguns are
not "suitable for organized target shooting".  These handguns have been
used competitively for years, and in fact, a specific competition is
dedicated to the .38 calibre "Chief's Snub-Nosed Revolver", which has a
2 inch barrel.

These firearms have been issued to Canadian police officers for decades
as service revolvers to protect the public and enforce the laws of
Canada.  Surely a handgun that is sufficiently accurate for these
general police uses is accurate enough for sporting uses.

Further, it was the recognized shortcomings of the particular cartridge
that these firearms are chambered for, i.e. .38, that has prompted the
recent calls for their replacement with more modern, powerful,
semi-automatic handguns, many of which are furnished with barrels under
105 mm (4.14 inches), but still seemingly accurate enough to protect
the public, as were the firearms they replace.


Other Prohibitions

Section 12(7) seeks to prohibit ownership or possession of any firearm
that is declared prohibited by the Governor in Council , subsequent to
the passage of Bill C-68.  Reference to proposed amendment to Section
117.15 of Criminal Code shows the intention to enable the Governor in
Council the ability to declare any firearm prohibited or restricted, if
in the opinion of the Governor in Council, the  particular firearm is
not reasonable for use in hunting or sporting uses.

All Canadians should be greatly concerned that the government is
seeking to confer authority to determine what is reasonable and what is
not on the Minister of Justice.  It should be hunters who determine
what firearms are "reasonable" for use for hunting,  and target
shooters who determine what firearms are suitable for target shooting.

We understand this amendment is needed to allow the Minister of Justice
to fulfil his promise to prohibit the future acquisition and legal use
of the Ruger Mini-14 by responsible Canadians who hold valid Firearms
Acquisition Certificates, solely for symbolic reasons.

Clearly, this prohibition has nothing to do with improving public
safety.  Currently, firearms cannot be declared prohibited through
Order-in-Council if they are "commonly used" for hunting or sporting
purposes and this particular firearm is indeed commonly used in Canada
for small game hunting, and for predator control.

The Ruger Mini-14 is commonly used for target shooting and to control
predators in rural areas across Canada by members of the N.C.P.T.W.F.
and should not be prohibited.

Beyond concerns relating directly to the Ruger Mini-14,  the enabling
of the prohibition of any firearm for any reason, without public or
legislative review, as long as the Governor in Council approves,  is
completely unacceptable.

This Committee should oppose such a provision that potentially would
affect the culture, economics and recreation of a quarter of the
Canadian population directly without specifically requiring detailed
public and legislative review.  Anything less runs contrary to every
principle of participatory democracy.

Surely, Canadians have a right to expect logical , rational rule by
their governments, not symbolic gestures.  This Committee should strike
Section 12(7) and the proposed amendments to Criminal Code to create
Section 117.15.



Import and Export by Individuals

It is the position of the N.C.P.T.W.F. that the sections of Bill C-68
that seek to regulate the import and export of firearms by individuals
needlessly complicates the process of bringing firearms across the
border for personal use.  These sections should not receive the
approval and sanction of this Committee.

Surely the existing laws and restrictions are sufficient to control the
legitimate importation of firearms by Canadians.  For instance,  many
Canadians already check their photographic equipment and firearms with
Customs Officials prior to leaving Canada so that they can prove prior
ownership upon their return.  Firearms not so checked, could be
detained at the border if the individual possessing the firearm cannot
produce a valid F.A.C. or restricted weapon registration certificate.

Non-residents are already prohibited from possession of restricted
firearms, without prior approval of the chief provincial firearms
officer, and checked upon leaving for possession of their restricted
firearms.

Any requirements over and above this will seriously endanger the
hunting-based tourism which contributes millions of dollars annually
directly to the Canadian economy.

Gun Collectors

The N.C.P.T.W.F. is concerned with the proposed formal definition of
the term "gun collector" along with the conferring of increased
regulatory power over collectors to the Minister of Justice.


The Standing Committee must recognize that all collections start with a
single item and collections of restricted firearms are no different,
and that family heirlooms have great historical relevance to the
individual involved, even though the particular firearm in the
collection may not be particularly significant in terms of technology
or science. Such nuances should be reflected in the legislation.


The proposed regulatory power includes the authority of the Minister to
regulate collections of currently non-restricted firearms, not just
collections of restricted firearms.   The potential exists for the
Minister to declare, without public review, scrutiny and approval, that
anyone owning more than a single shotgun or rifle is deemed to be a
"collector".  The people affected could therefore be subject to
additional rules forbidding additional acquisition without undergoing
mandatory inspections, or mandatory storage of the "collection" in a
dwelling in some prohibitively expensive storage system.

The Standing Committee should not approve the formal definition of "gun
collector" nor the expanded authority to enact regulations regarding
collectors.  The documentation of need for such changes has not been
provided by the Minister and the current controls on gun collectors are
more than adequate to ensure public safety.


Powers of Inspection Granted to Police Officers

The N.C.P.T.W.F. is greatly concerned with the content and effect of
the draft legislation respecting powers of inspection, search and
seizure.  The additional powers granted are not only unnecessary, they
are an unsupportable and dangerous intrusion into all Canadian's civil
rights and liberties.

Section 99 of Bill C-68 would institute a major change in the search
and seizure provisions in Canadian law and police practice.  A police
officer would no longer require a reasonable expectation that a crime
was or will be committed to search without warrant or even need to
subsequently seek a warrant,  any place other than a dwelling house.
Beyond that,  Bill C-68 would require that anyone present give all
assistance to carry out this search and seizure even though no crime
has been committed.

Canadians rightly expect to be considered innocent until proven guilty,
and expect that their rights to privacy and security, to remain silent,
and the right to seek legal council be maintained.  Bill C-68 strips
these rights from all Canadians, but in all likelihood, it will only be
the firearms owners that experience the effects of the loss of these
rights.

It has been stated recently that this draft legislation is about the
type of country that we want Canada to be.  This is exactly true:  we
do not want a country where responsible citizens are forced by law to
render all assistance to police officers as they search without
warrant,  for any sign or indication that there is a firearm or
ammunition present in any vehicle, or place when there is absolutely no
indication that a crime has been committed.  We do not want Canadians
to be considered guilty without proof,  nor should Canadians be forced
by law, to freely volunteer information or assistance that could be
subsequently used against them, their spouses or their families.

These sections of Bill C-68 are an affront to all Canadians, and should
be opposed by this Committee.


Regulation of Shooting Ranges

The N.C.P.T.W.F. objects to the proposed formal regulation of
government approved shooting ranges and clubs as unnecessary and
inappropriate.

Bill C-68, in Section 28 in conjunction with Section 110(e), seeks to
control under federal law and regulation, the operation of  shooting
clubs and ranges throughout Canada.  Standardization of such control
through federal regulation will prevent the application of regional
appropriateness of such regulations by provincial authorities.

Clearly the rules governing shooting ranges in rural Canada should
indeed be different than the rules governing ranges in urban centres,
and thus, should be a matter for each province to decide and regulate.

It appears that Section 110(e), which enables the Governor-in-Council
to make regulations respecting all aspects relating to the
establishment and operation of shooting ranges,  will in practise be
coupled with the periodic and ongoing review of restricted firearms
licences.   When a provincial minister is forced to revoke a shooting
club's approval to operate for violating a federal regulation that was
imposed without public review  and scrutiny, club members will lose
their stated purpose or rationale for the possession of their
registered restricted firearms, and accordingly,  face confiscation of
their firearms without any compensation.

At a bare minimum,  any revocation of a provincial minister's approval
of a shooting club or range must be appealable to a court with
competent jurisdiction for impartial judicial review, and lack of
access to a government approved shooting range should not be an
acceptable rationale for not renewing an individual's restricted
firearms registration certificates.

The N.C.P.T.W.F. objects to the proposed restrictions and granting of
regulatory powers relating to shooting ranges and clubs.  As stated
above,  firearms owned by responsible Canadians and stored in
accordance with the law need not be further regulated, and the
operation of government approved clubs is better controlled at the
provincial level where regional variations can be accommodated.



Governing by Order-in-Council

The N.C.P.T.W.F. is opposed to the sweeping departure from governing by
legislation evidenced by the content of the regulations listed in
Section 105 of Bill C-68.  The draft legislation will empower the
Minister of Justice to directly control virtually all aspects of
Canadian firearms ownership through regulation, not legislation.

The legislation will allow Canadian's activities to be controlled
through regulation, although most of these people will not have ready
access to the Canada Gazette, the only place where these regulations
are published.

Failure, by an average Canadian, to read, understand, and abide by a
regulation that he or she has no access to, and often have great
difficulty understanding, could potentially result in criminal charges
being laid which could result in a jail term of up to 5 years.  It must
be remembered that these potential breaches of regulations result in
victimless transgressions,  and the associated penalties are far beyond
what would be reasonably expected.

When balanced against the proposed sentencing structure that will call
for a mandatory 4 year imprisonment for using a firearm while
committing one of 10 violent crimes,  the potential for a longer jail
term for an administrative offence fosters disrespect for the law and
the criminal justice system and rightly leads firearms owners to
notions of persecution.

The draft legislation requires the Minister of Justice to lay before
the House each proposed regulation which in turn is referred to an
appropriate Committee that is empowered to hold inquiries or public
hearings.  The Minister is not required to wait for the Committee's
report, or even to heed the recommendations of the Committee, but is
allowed to proceed to implement whatever regulation desired,
notwithstanding the fact that the final regulation made is completely
different than what was originally proposed.

Provisions such as these, if implemented, will seriously impair the
democratic functioning of the House of Commons,  and run directly
contrary to the federal government's own Citizen's Code of Regulatory
Fairness(ENDNOTE 41) which requires public review and input.  The
Standing Committee on Justice and Legal Affairs should not allow this
delegation of authority from the House of Commons to the Minister.


Summary and Recommendations

The Citizens Code of Regulatory Fairness requires the federal
government to adhere to and conform to certain principles:

     to interfere as little as possible with individual freedoms, while
protecting the interests of the community;

     to enable individuals, businesses and other governments to provide
input to the federal regulatory process;

     to fully explain regulations and their effects in clear language;

     to ensure that the regulations do not affect particular people or
groups unfairly;

     to match the penalties for not complying with the regulations with
the seriousness of the violations;

     to ensure that the decisions of regulatory agencies and
departments are made in an efficient, prompt, and predictable manner;

     and to regulate only where there is clear evidence that a problem
exists,  government intervention is justified, regulation is the best
alternative, and the benefits exceed the costs.

Bill C-68 violates all these principles.

On behalf of over 500,000 members of our component federations and
associations,  we ask that this Committee request the dropping of all
aspects of Bill C-68 which would impact on law-abiding citizens.


  List of Appendices    (NOTE:  ORIGINAL SUBMISSION TO THE STANDING
  COMMITTEE CONTAINED COMPLETE COPIES OF ALL THE LISTED APPENDICES,
  ALONG WITH COPIES OF OVER 130 ONTARIO MUNICIPAL RESOLUTIONS OPPOSING
  C-68)


  Appendix A:  Report of the Auditor General to the House of Commons,
  1993.

  Appendix B:  Domestic Homicides Involving the Use of Firearms. Dansys
Consultants Inc., March 1992.

  Appendix C:  Police Responses to Domestic Violence:  A Study of the
  Use of Criminal Code Provisions Relating to Firearms. Colin Meredith,
  Chantal Paquette, Abt Associates of Canada, June 1991.

  Appendix D:  The Impact of the Availability of  Firearms on Violent
  Crime, Suicide, and Accidental Death.  Thomas Gabor, 1994.

  Appendix E:  Research on the Application of Section 85 of the
  Criminal Code of Canada.  Colin Meredith, Bruno Steinke, and Sherilyn
  Palmer.  December 1994.

  Appendix F:  Gun Control is not Crime Control.  Gary Mauser. March
  1995.

  Appendix G:  Much More Than Gun Control. Shafer Parker, Jr.  April
  24, 1995.

  Appendix H:  Various Municipal Resolutions.

  Appendix I:  Review of Firearms Registration.  Terence Wade and Roger
  Tennuci. November 1994.

  Appendix J:  Project Gun Runner Report.  Const. Geoff Francis.
  Undated.

  Appendix K:  Citizen's Code of Regulatory Fairness.

  Appendix L:  Arguments Against Further Gun Control At This Time.
  William Bartlett. September 1994.




  1.   Desautels, L. Denis,  Auditor General of Canada.  Report of the
Auditor General of Canada to the House of Commons.  l993. November 23,
1993.  Pages 644 - 655.  Attached as Appendix A.

  2.   Ibid. Page 650.

  3.   Ibid. Page 654.

  4.   Juristat  Service Bulletin,  Volume  12,  Number  21,  Gender
Differences  Among  Violent Crime  Victims,  Statistics  Canada,
Canadian Centre For Justice Statistics, November 1992. Page 5,9.

  5.   Ibid., Page 10.

  6.   Juristat service Bulletin, Volume 11, Number 12, Weapons and
Violent Crime,  Statistics Canada,  Canadian Centre For Justice
Statistics, August l991, Page 2, 11.

  7.   Juristat Service Bulletin, Volume 14, Number 15, Homicide in
Canada - 1993 ,  Statistics
Canada, Canadian Centre For Justice statiStics~ August 1994. Page 1.

  8.   Ibid., Page 12.

  9.   Juristat Service Bulletin Volume 12, Number 18., Homicide in
Canada 1991.,  Statistics Canada,  Canadian Centre  For Justice
Statistics, October 1992, Page 15.

  10.  Causes of Death. 1991., Statistics Canada, Canadian Centre For
Health Information, 1993.  Pp. 176 - 180.

  11.  Number of Restricted Guns Used in Homicide Offences by Year.,
Statistics Canada,  Canadian Centre For Justice Statistics,  Law
Enforcement Program. Pp. 1 - 8.

  12.  Juristat Service Bulletin, Vol. 14, No. 15., op.ci Gordon
Gallant Land Use Specialist Ontario Federation of Anglers & Hunters


13.  Dansys Consultants, Inc., Domestic Homicides Involving the Use of
Firearms, March 1992.  Page ix.

14.  Juristat  Service  Bulletin,  Volume  14,  Number  8.  Spousal
Homicide,   Statistics  Canada, Canadian  Centre  For  Justice
Statistics, March 1994. Pp. 6 - 7.

15.  Ibid., Page 5; and  Juristat Service Bulletin, volume 12, Number 18.,
Homicide in Canada 1991., statistics Canada, Canadian Centre For
Justice Statistics. Pp. 1 - 5.  16.  Juristat Service Bulletin, Volume
9, Number 1., Homicide in the Family, .Statistics  Canada, Canadian
Centre  For  Justice Statistics, May 1989, Page 2.  Number and % of
Female Homicide Victims by Type of Intimate Relationship, Canada and
Provinces, 1961-1990, Statistics Canada, Canadian Centre For Justice
Statistics, Pp. 1 - 5.

17.  Meredith C.,  and Paquette,  C.,  Abt Associates of Canada. Police
Responses to Domestic Violence: A study of the Use of Criminal Code
Provisions Relating to Firearms.,   Department of Justice, June 1991.
This document is attached as an appendix.

18.  Ibid., Pp. 16 - 17.

19.  Causes of Death 1992, Statistics Canada, Health Statistics Division,
September 1994,   and Method of Committing Homicide Offences: Canada
and the Provinces, Statistics Canada, Canadian Centre For Justice
Statistics, 1992.

20.  Juristat Service Bulletin, Volume 12 Number 14. Robbery in Canada,
Statistics Canada, Canadian Centre For Justice Statistics, May 1992.
Pp. 1 - 5.

21.  Juristat Service Bulletin, Volume 11 Number 12., Weapons and Violent
Crime.,  Statistics Canada,  Canadian Centre For Justice Statistics, August 1991. Page 12.

22.  Causes of Death 1991, Statistics Canada, Canadian Centre For
Health Information, 1993. Pp.  168 - 180.

23.  Gabor,  T.  The Impact of the Availability of Firearms on Violent
Crime. Suicide. and Accidental Death., The Department of Justice,
Canada.  1994.  Page 76.

24.  Ibid., Page 45.

25.  Ibid., Page 79.

26.  Ibid., Annual.,    and  Understanding Crime: Experiences of Crime and
Crime Control, United Nations Interregional Crime and Justice Research
Institute, United Nations Publication Number 49, August 1993.

27.  Firearm Statistics (Updated Tables), Department of Justice, Statistics
section, November 1993, Table 13;  and Causes of Death, Op.Cit.

28.  Waller, J., and Whorton, E., "Unintentional Shootings, Highway Crashes,
and  Acts  of Violence",  in   Accident  Analysis  and Prevention,
Volume 5, 1973, Pp. 351 - 356.

29.  Meredith, C., Steinke, B., and Palmer, S., Research on the Application
of  Section  85  of  the Criminal  Code  of  Canada. Department of
Justice,  Canada,  December  1994.  Attached as an Appendix.

30.  Ibid., Pages ix and x.

31.  McDonald, M. "Crime, The Perception Gap", Maclean's, Volume 108, Number
1, January 2, 1995. Page 28.

32.  Extracted from:   Creating Opportunity: A Liberal Plan for Canada.
(The Liberal 'Red Book'), September 1993.  Page 84.

33.  Extracted from:  A Liberal Perspective on Crime and Justice Issues,
August 1993,  Pages 4-5.

34.  Mauser,  Gary.  Gun  Control  is  not  Crime  Control.  Fraser
Institute, Canada. March 1995.  Attached as an Appendix.  Parker,
Shafer, "Much More Than Mere Gun Control", Alberta Report, Volume 22,
Number 19.  Attached as an Appendix.  Various Resolutions Passed by
Ontario Municipalities. Attached as an Appendix.  Bartlett, W.
Arguments Against Further Gun Control at This Time. Library of
Parliament, Law and Government Division. September 29, l994.  Attached
as an Appendix.

35.  Maclean's, April 3, 1995. Page 11.

36.  Wade, T., and Tennuci,R.  Review of Firearms Registration, Department
of Justice, Canada.  November 1994. Page 27.  This Report is attached
as an Appendix.

37.  Number of Restricted Guns used in Homicide Offences By Year, Statistics
Canada, Canadian Centre For Justice Statistics, 1961 - 1990 .

38,  Meredith, C., and Paquette, C., l99l, op.cit.

39.  Peel  Regional  Police,  "Project  Gun  Runner  Investigative Summary",
Constable Geoff Francis,  Badge #748.

40.  Number of Restricted Guns Used in Homicide Offences by Year.,
Statistics Canada, Canadian Centre For Justice Statistics.

41. Citizens Code of Regulatory Fairness,  Canada, Minister of Supply and
Services, 1987.





Gordon Gallant
Land Use Specialist
Ontario Federation of Anglers & Hunters