Mon courriel a été envoyé pour demander des clarifications et mes observations de la nouvelle loi.
[email protected]Subject: Proposed explosives regulations from Canada Gazette, March 17, 2012.
Please deliver this message to Christopher G.
Watson, Chief Inspector of Explosives, Explosives Regulatory Division, Natural Resources Canada.
Dr Watson,
I am writing to you as a concerned citizen regarding the proposed changes to the explosives act regulations that were published in the Canada Gazette part 1 on March 17, 2012.
I wanted to express how thankful and impressed I was that you sent a response and requested that it be posted on the Canadian Gun Nutz forum for those of us who are concerned.
I have re-read the proposed regulations, and an area I had missed before stood out as being of grave concern. That is the limits on ammunition that a seller can possess. The regulations as written would seem to indicate that any business can only possess 225KG at a time regardless of how many locations it was stored in. Even if the business maintained a retail location and a second storage unit across town, they are still limited to 225KG. To put this in perspective, 225KG of propellant is normally contained in a bit over 100,000 rounds of .223 ammunition. This is a very common sporting round and quite a small rifle calibre. My math was quite rough, so it is only an estimate. I emailed one of the larger retailers of ammunition to inquire how large his shipments are. He told me that each container of that one calibre is one million rounds. This means that even if he only wanted to carry a single calibre of a single brand, he would only be able to carry ten percent of what is currently in a single delivery.
This limit on retailers will raise prices to an unsustainable level if implemented, and will cause several retailers to go out of business in my opinion. It will also mean significantly fewer participants in many of the shooting sports as we must order and use ammunition in fairly large quantities to participate in our sports. I personally order 1000 rounds at a time, and I rarely get to practice. High end competitors tell me they regularly fire over ten thousand rounds in the week before a major match. Driving up ammunition prices by reducing quantities that a business can order will almost certainly kill several of these very fun and responsible sports.
I would invite you to attend a shooting match at your local range for any of the action shooting sports. I personally shoot in Ontario and Quebec. We're a very welcoming bunch and I'm sure all of the participants would welcome an observer.
If the explosives regulations are truly about safety, and there is a sound scientific reason for requiring no more than 225KG of powder in loaded ammunition in one place, then the regulations need to be written in such a way that larger amounts can be possessed by a seller as long as they are separated by a certain distance to ensure safety in case of fire, or theft at one location etc.
My next concern is with the regulations requirement that the owner of ammunition store it in a manner that protects it from theft. The FAQ page that your agency posted appears to indicate that ammunition can be stored in a business as long as it is either attended, or the business is locked up. This to me means that a similar requirement could be applied in a dwelling. The regulations could be revised to state that ammunition should be stored in a residence that is either attended or locked, or if unlocked, that the ammunition should be in a locked container. Basically to state that the ammunition must either be attended, or be protected by at least a single lock. This type of wording should provide the same security you are suggesting for a business without leaving vague wording that makes firearms owners afraid they might have dropped a round behind the work bench while reloading and could go to jail for it. It would also allow for storing ammunition in a vehicle while hunting etc.
My next concern is with the black powder amounts that are allowed, both for users and retailers. If there is a scientific reason for lowering the limit, then I believe publishing that reason would have a significant impact on lowering anger about it. If it was an arbitrary number, then it seems unfair to the black powder shooters.
The final concern I have at this time is the specific mention of not allowing the reloading of armour piercing projectiles. My understanding of these projectiles is that they contain no flammable or explosive properties at all. To me this means that the explosives act is an improper place for regulating them. I am not commenting on whether or not they should be permitted, only questioning whether this is the proper forum.
Thank you for taking the time to read our input, and for responding. It is greatly appreciated when our input is heard, and hopefully my concerns can be addressed in a follow-up draft of the regulations.
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