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Letter To The Ministers On Bill C-71

September 25, 2018


The Honourable Ralph Goodale
Minister of Public Safety and Emergency Preparedness


The Honourable Bill Blair
Minister of Border Security and Organized Crime Reduction


Dear Ministers,

Re: Bill C-71, An Act to amend certain Acts and Regulations in relation to firearms

I am writing on behalf of the Canadian Criminal Justice Association (CCJA). As you may know, the CCJA is one of the longest serving non-governmental organizations of professionals and lay persons interested in criminal justice in Canada. The Association, which now represents 700 members across Canada, began its work in 1919 and has testified before Parliamentary Committees on numerous occasions.

While the CCJA recognizes the steady downward trend in Canadian crime rates since the late 1960s, like many other organizations and individuals, we are deeply concerned by the apparent recent increase in national gun-related crimes. Although Canadian firearm data is murky and outdated, the RCMP estimated in 2016 that contrary to popular rhetoric, a large proportion of illegal firearms in Canada originate as legal Canadian firearms. While Bill C-71 begins to remedy this issue’s appreciably domestic nature, we believe it does not go far enough to ensure that legal Canadian firearms do not end up in the wrong hands.

Bill C-71’s outset is traceable to the current Government’s 2015 campaign promise to reverse the previous Government’s easing of gun controls. The CCJA celebrates the restoration of former safeguards – such as the reassertion of the RCMP’s prerogative to classify firearms and the requirement that individual licenses be corroborated before the purchase of a firearm. These time-tested measures will reduce the probability of legal domestic guns being implicated in criminal activities. The Bill fails however, to address other regressions in gun control that have occurred over the last decade, most notably, the Authorizations to Transport (ATT) rule. Currently, an ATT authorizes the transportation of handguns and assault weapons anywhere within provincial confines; a far cry from the original regulation which imposed restrictions to pre-defined locations. It is the CCJA’s position that access to accurate data on the precise whereabouts of these restricted weapons would empower law enforcement to take a proactive approach to policing gun crime, as opposed to a reactive one.

Beyond the promise to overturn changes made by the former Government, several amendments should be made to the Bill to meet its full potential in promoting a multi-faceted notion of public safety. In particular, we support a specific proposal made by the Canadian Gun Coalition that recommends strengthening the wording around licensing by broadening the firearm licensing eligibility criteria of the Firearms Act to include reference to a range of issues and circumstances that may raise red flags in respect to gun ownership.

One of the most positive aspects of the Bill is its jettisoning of the 5-year period for screening risk factors, however verification of an applicant’s entire life is only useful if it is meticulous and cross-checked. Without mandatory provisions for the RCMP to follow up with medical professionals, social workers and others where applications or family members raise concerns, the Bill will not fully align with the current Government’s stated public safety objectives.

After the divisiveness of the long gun registry debate, we appreciate the Government’s caution in legislating on gun control. In the context of the current concerns about gun violence however, we do ask the Government to meet its promises in enhancing gun control laws so as to promote public safety and the legally responsible usage of non-restricted and restricted firearms.



Irving Kulik

Executive Director

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