The fees payable for your firearms certificate (FAC) or shotgun certificate (SGC) were last changed in 2001, and while few disagree that they need to be increased, the question is by how much? Using retail price index (RPI) inflation, a grant would rise from £50 to £72, and a renewal from £40 to £57. That means a first certificate would cost about £14.50 per year and subsequent ones £11.40. Those are not unreasonable figures compared with the overall cost of shooting.
The police would like to see fees rise even further to cover a percentage of the cost of administering the licensing system. At present, the Association of Chief Police Officers (ACPO) reckons it only recovers 30 per cent of the total cost of licensing. When ACPO initially proposed that fees should be raised to cover the full cost of licensing, in 2011, the Home Office asked it to consider a more modest increase. On ACPO?s own admission, the service was (and still is) inefficient ? in 2011, more than 13,000 certificates were admitted not to have been renewed on time, and the true figure will have been even higher.
In July 2012, ACPO proposed an RPI increase for three years followed by a review which would lead to full cost recovery of some activities carried out by the licensing department. The precise nature of these activities and what they cost has not been made clear.
ACPO estimates the cost of running the licensing system in England and Wales in 2009/10 was £22.3million gross and £17.2million net of fee income. There must have been some guesswork in this, as my own research shows that some forces don?t keep easily retrievable figures, while others lump a variety of activities under ?firearms licensing?. In Scotland, for example, this includes pedlars? licences. Furthermore, 2009/10 was a fallow year in which there were fewer than normal transactions due to the five-year licensing cycle, but few, if any, forces did anything to reduce their costs for the year.
I made a freedom of information (FOI) request about the costs and was given a gross figure of £14million in England and Wales for 2009/10. However, seven forces were unable to provide the information within the stipulated 20 working days, two didn?t keep it and another pleaded commercial confidentiality. I found this amazing, as it?s the sort of information any management accountant should be able to retrieve in about 15 minutes. Clearly the costs of firearms licensing are not in the forefront of many commanding officers? minds. Extrapolating from the figure I was given, the total cost for the year would be about £16.8million ? well below the ACPO figure. However, the ACPO figure includes a 30 per cent rise to cover overheads, which were often omitted from the FOI responses. The extrapolated net cost is about £11.9million after fee income.
Using information from my FOI request, I worked out the cost per certificate of running a licensing department in 2009/10. The average in England (there were too few Welsh responses to be meaningful) was £27; the most economical was £14; and the worst was £76. Comparable figures in Scotland were generally higher, but it?s not clear why.
This average assumes that all the costs of licensing are borne by FAC and SGC holders, but there are other transactions which incur fees ? about 10 per cent of the overall cost can be attributed to explosives licensing, so the true cost per certificate is about £24.50. If all costs of licensing were borne by FAC and SGC holders alone, a certificate would cost £122.50 ? considerably less than ACPO?s calculated fee (see below). Moreover, the figure includes the worst performers, so excluding them would significantly reduce the average cost.
Sadly, because of the inefficiencies in the system, you can?t rely on the police figures to give a true cost of the licensing service ? the information is not kept in a standardised way, and each force attributes different costs to licensing.
Based on an analysis of the activities needed to process an application, ACPO calculates it costs £186 to grant a certificate and £106 to renew one. The figure of £186 is well in excess of a costing exercise carried out by Lancashire police in 2011 which showed the cost to be £101.
The last time there was an independent study into the cost of licensing was in 1991/2 by Ernst & Young on behalf of the Home Office. Then, the best practice cost for granting an FAC was £36.18 and for an SGC, £28.92. Indexing those by RPI would give £68 and £55 respectively ? well below the ACPO figures.
The main aim of the Firearms Act is to protect public safety. The granting of a certificate to any sane, sober and upright citizen who has a good reason is a right, not a privilege. It?s fair that applicants should pay towards the cost of an efficient system, but the taxpayer (which includes the certificate holder) whose safety is being protected should pay a significant proportion. It?s also fair that a charge should be levied for some activities, notably change of address to another force area and Section 11 permits, which are currently free.
There are ways in which efficiency could be improved. Certificates are valid for five years, but they can be valid for less at the discretion of the holder. Why, when a major change is made, such as a change of address or a variation, can the holder not be given the opportunity to cancel his old certificate and be given a new one? Depending on timing, this could save a lot of work and cost for all involved, especially if the certificate is three or more years old. If a charge were to be made for change of address, a renewal should be automatic.
ACPO has promised to make improvements to the system. There are plenty of signs that Chief Constable Andy Marsh, the current Firearms and Explosives Licensing Working Group chairman, is putting pressure on the backsliders. Changing the habits of a lifetime will not come easily to many forces, but there must be change if both the certificate holders and the wider public are to have confidence in licensing.
Forces that fail to apply the ?other lawful quarry? condition on FACs, that impose mentoring or want land inspections will inevitably cost more than those that don?t. That wouldn?t matter if there was a demonstrably beneficial effect on public safety, but there isn?t.
One promising initiative is e-commerce, which will provide an online application facility for certificate holders. It will streamline police procedures, reduce costs and make it harder for forces to deviate from the approved methods. Another option is privatising the service, as is being tried in Lincolnshire with G4S. My planned visit to see the system in operation has twice been postponed, which makes me wonder if they are trying to hide something.
When there?s a fair, effective and efficient licensing system countrywide, and when the cost of the various activities can be easily identified, we can consider a fundamental change to fee levels. In the meantime, I suggest fees of £72 for a grant, £57 for a renewal or change of address out of county (with the added bonus of a renewed certificate), and similar figures for Section 11 grants and renewals.