13 Jan 2017 – A new government consultation reveals that the Home Office wants to destroy the sport of target shooting by punishing rifle clubs with £1,000 increases in approval fees.

The consultation, published yesterday afternoon, attacks museums, section 5 dealers, armed private maritime security companies (PMSCs) and Home Office approved rifle clubs.

In its introduction, the unnamed author of the consultation writes: “The costs of the firearms licensing regime should properly be attributed to the organisations benefiting from the licence, and not the taxpayer.”

Revealing that the real reason for these punitive costs is down to one or more out-of-control civil servants taking out their personal politics on the licensed firearms community, the very next sentence says: “Charging in this way ensures the real economic cost of safeguarding high risk activities is understood by licence holders.” (UKSN bold/highlighting)



The plans will result in an increase to Home Office profits of nearly £600,000 a year, from clubs, museums and section 5 dealers, with police netting extra profits of £69,000 a year.

The proposed increase for clubs is from £84 to £1,050 – an increase of 1,250%. £470 will be payable every time the named club secretary, or anyone else named on the approval, is changed – a serious concern for university rifle clubs.

Olympic pistol shooters will also be hit by a tax of £470 every three years to renew their section 5 authorisations for sporting pistols used to represent the country.

Approving rifle and muzzle-loading pistol clubs is nominally a Home Office activity and is funded through a fee payable by clubs along with general taxation. In reality what happens is the Home Office banks the cheque and a local police force does all the actual work of assessing approval applications, with the Home Office printing off a form approval letter with the club secretary’s name on it after police give them the green light to act. UKSN’s author has taken two rifle clubs through the approval process in the last 10 years and on the second occasion, last year, effectively had to set the Home Office on a disobedient Metropolitan Police until the service paid for was supplied.

The consultation webpage can be viewed on GOV.UK. The consultation itself and the flawed impact assessment with it are also there. It closes on

Get the consultation withdrawn

In its current form the consultation is unfit for purpose and must be withdrawn, with the fee hike plan accordingly halted. It is based on incomplete data, flawed assumptions and filled with language tending to suggest that its real motive is political, not financial. These are discussed in detail below.

Incomplete data

As the government department mandated by law to do so, the Home Office approves rifle clubs which apply for it. Approval allows club members to use club firearms without holding a firearm certificate of their own. To gain approval, the club must meet a list of legal criteria published on the authority of the Home Secretary.

With that in mind, it is a matter of very serious concern that the Home Office doesn’t know how many rifle clubs are approved. Footnote 10 from page 5 of the fees impact assessment (PDF) refers:

There is no need for the Home Office to estimate this data. The full number of approved clubs, their grants and renewals is (or should be) held centrally for the full 6 year period. Why has the full dataset not been used? Given the language used in the consultation and the impact assessment (see later), this tends to suggest a partial data range was used to give an undue advantage to the Home Office position on hiking fees.

Flawed assumptions

Under the crossheading “Appraisal – (costs and benefits)” on page 7 of the impact assessment we see the Home Office, in all seriousness, proposing a 1,250% fee increase and claiming that there will be no consequent reduction in the number of clubs paying that fee:

It is assumed that numbers of applicants for new licences, and renewals of and variations to existing licences, will be equal to the average annual number of applications in the previous three years and not significantly influenced by the proposed fee changes.

This is nonsense. Rifle clubs are not businesses and typical turnover levels range from £12,000 per annum for a medium-sized university club of 30 members to perhaps a million or so for a major Bisley club with hundreds of members complete with clubhouse, bar and restaurant. Major clubs may be better placed to swallow a £1,000 fee but the increase will kill smaller clubs, particularly ones run by and for young people, as they simply do not have the capital to meet the increased fees. It is notable that the Home Office deliberately ignored the knock-on effects of hiking fees.

It also seeks to charge the taxpayer twice for the Drugs and Firearms Licensing Section (DFLS)’s London HQ in Marsham Street, along with the centrally-contracted Home Office IT used by them and even the cost of the Home Office’s HR department. Marsham Street has been a Civil Service building for decades, housing civil servants from all government departments, and would firmly remain so even if the DFLS ceased to exist. Ditto the Home Office HR department. The costs of a fixed HQ owned by the Civil Service are totally inappropriate for inclusion in any proposed fees structure.

Political language

The rationale of the fees increase, as given in the impact assessment, is so it “ensures the real economic cost of safeguarding high risk activities is understood by licence holders.” (sic)

This ties into an ongoing campaign by Labour MPs over the last few years designed to demonise the peaceful sport of target shooting and stamp it out by driving up costs imposed on shooters by police and central government. This campaign was mostly successful last year, when FAC and SGC fees payable to police were hiked up following a disgraceful abuse of police PR resources over the preceding year in order to milk the shooting cash cow harder. It appears pressure has been brought behind the scenes on civil servants to comply with this political campaign by the Opposition, perhaps made easier in the power vacuum formed by a new Home Secretary and Firearms Minister taking post just 7 months ago, with both still getting to grips with their respective briefs.

The decision to ignore the obvious step of fee increases being passed on by certificate holders to end customers (club members, section 5 RFDs, dealers and shooters using licensed carriers and airlines for transporting guns) is baffling. One must assume this was done in order that the obvious negative effects on the shooting sports could be disregarded, easing the passage of these swingeing measures.

In addition, the presentation of a nonsensical “cost per year” (figure 2, page 8 of the consultation) is clearly intended to give campaigning ammunition to the minority who support these punitive fee increases by creating a false impression that the fees will be affordable over a period of time. None of the fees in the consultation are payable in annual instalments – they are all payable upfront only – and there are no plans for them to be offered in instalments by the Home Office. One does not speak of buying a passport as “only costing a tenner a year” and neither does anyone in the shooting community speak of Home Office fees in this way.

Singling out Olympic pistol shooters for a £470 tax each is disgraceful. These are elite athletes who represent GB at home and abroad. We as a nation absolutely must not be penalising our athletes financially in addition to starving them of access to the sporting equipment they need to train and compete.

What to do next

The obvious thing is to respond to the consultation. However, it is wise not to do so immediately. National bodies such as the NRA (who are aware of this) need time to write their responses so the rest of us can read them and be informed.

We also need to write to ministers to have this unfit for purpose consultation halted – specifically, the relevant ones at the Department for Culture, Media and Sport and also at the Home Office. DCMS is relevant because target shooting is a sport, and DCMS also controls bodies such as Sport England who in turn give funding towards the Olympic disciplines.

Relevant DCMS ministers

Culture Secretary Karen Bradley – https://www.gov.uk/government/people/karen-bradley – karen.bradley.mp@parliament.uk

Under Secretary of State Tracey Crouch – https://www.gov.uk/government/people/tracey-crouch – tracey.crouch.mp@parliament.uk

Parliamentary Under Secretary of State for Civil Society Rob Wilson – https://www.gov.uk/government/people/rob-wilson – robwilsonmp@parliament.uk

Home Office ministers

Home Secretary Amber Rudd (pictured at top) – privateoffice.external@homeoffice.gsi.gov.uk

Policing minister Brandon Lewis – https://www.gov.uk/government/people/brandon-lewis – helen.hill@parliament.uk (evidently his PA)

(It is notable that the Gun Control Network whinged in December that Lewis told them he wouldn’t authorise public money to be spent on their pet shop-a-gun owner hotline)