This letter was submitted to the Minister of Police and the NZ Police in response to a number of proposed changes in police policy around the secure storage of firearms. I believe these proposed changes to be illegal and ultimately ineffective and am disappointed by the way that the police treat law-abiding licensed firearms owners in this country.
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To the Minister of Police,
This submission is in reference to the documents put up for consultation by the New Zealand Police, namely the "April 2017 Draft Firearms Secure Storage Policy" and "November 2017 Draft Firearms Secure Storage Policy" documents, which can be found on the NZ Police website.
Prior to dealing with the specifics of the policy, I would first like to object to the scope of these documents and the handling of this situation.
Due to negligent behaviour, the police have effectively given license holders about a week to make a submission due to only alerting us of this policy a few weeks prior and then initially providing the wrong email address.
The police are also effectively using this policy to make their own law, by attempting to reclassify A Category semi-automatic firearms as needing security requirements different to that of all other A Category firearms. We live in a parliamentary democracy and the police should under no circumstances be attempting to override Acts of Parliament with their own policy.
Next, the police will require us to agree to their policy (and possibly all future illegal and ultra vires policies) by signing a contract. This is at the very least offensive and at the worst illegal behaviour by the police.
Lastly, the police have mixed policy with law giving the impression to licence holders that this document is the law. Policy and legal requirement should be separated clearly and concisely to avoid confusion. A situation now exists where police believe they have authority to implement their policy as law which they do not. I fear police will attempt to codify all policies such as the Pol67N and S43A mail order into law without following the correct parliamentary process. I strongly object to police policy making law.
Police are acting outside of their authority and attempting to circumvent due process.
With my concerns around the actions of the police above, I would like to add a few points of concern to the specifics of the policy.
Firstly, the policy targets A Category semi-automatics for additional security requirements, beyond that of other firearms and that which is required by law. There is no justification given for this move. Can the police cite statistics that show semi-automatics are more likely to be stolen from a rack, than say a bolt-action, lever-action, pump-action, or break-action? Can the police show that semi-automatics are inherently more dangerous or used in crime to justify their discriminatory policy? The police have presented this policy without any justification for it.
Next, the requirement for a safe can be an onerous one, especially for those who are do not own their own homes. This policy could lock many renters out of owning a semi-automatic, and eventually, all firearms. This policy also adds an additional barrier-of-entry to shooting sports and hunting. A safe is significantly more expensive than a rack or a solid cabinet. Likewise, this policy may see more buying cheap safes simply to comply, giving only the illusion of increased security. I would suggest that since safes are generally more visible, often located in garages, and easier to target than a firearm that is locked away in a more inconspicuous area of the house where it cannot easily be found. Do the police have any data to show that a semi-automatic firearm in a safe is more secure and less likely to be stolen than one stored on a rack or cabinet? The police have provided us with no such data.
I would reiterate that I believe this policy is harmful and will not help to reduce the issue of firearms theft. If the police do wish to solve this issue then I suggest that they consult with the firearms community from the outset, rather than giving us mere weeks to respond to proposals. Changes to the laws of the land should be make through the proper processes and not by police policy.
Dieuwe de Boer