Committee for Justice, Thursday 28 May 2026

Can I declare the meeting open to the public? What are you using? I'm going to get my Oh, >> you are using >> No, that's no, I've got my own I've got my own plugin. >> Can I welcome members to the 76th meeting of the Committee for Justice? Can I advise members that the committee meeting will be recorded and broadcast throughout Parliament buildings [clears throat] and online?

two different scan it when I'm here. Oh my. Can I advise members and those in the public gallery that they are welcome to use mobile devices as long as they are on airplane mode and all devices are muted. Attendees can also connect to the assembly Wi-Fi and password details are available on the gallery roles. It is not permitted to take photographs or record any part of the meeting.

Can I advise members that it is proposed that the oral evidence sessions with the department of justice and with the British association for shooting and conservation on the department's proposed amendments uh to the firearms licenses fees and the bandit system will be recorded by Hansard and can I seek your agreement for this? Agreed. >> Agreed.

Can I remind members in that they are obliged to declare any financial or other relevant interests that might reasonably be thought by others to influence their approach to the matters under consideration. So can I ask have any members got any interest to declare in relation to today's business? Should uh they should do so now? >> Sure. >> Y have an insurance policy with BASC in relation to my firearm. So that's that's my connection there. >> Okay. Thank you Paty. Any others want to declare an interest at this stage can also remind you you can do so during the meeting if if need be.

Okay. Agenda number one then is apologies. I have we have received no apologies. Uh but can I say that EA and Doug are joining us remotely today virtually on our screens. Uh but there are no that's everyone catered for. Yeah.

Agenda number two then is draft minutes. Can I inform members that the draft minutes of the meeting held on Thursday the 21st of May 2026 are at pages 5 to13 of your meeting pack. And I ask members if they're content with the minutes and that there are true reflection of the proceedings of the meeting held on the 21st of May. If so I will sign all agreed. Thank you.

And it number three then is matters are rising. Can I ask members if there are any matters rising from the minutes that they wish to raise at this stage? No.

Okay. That brings us on then to agenda item number four. Uh firearms licensing fees. Consultation on proposed amendments to firearms licensing fees and the bandit system. Department of Justice Oral Evidence.

Can I refer members to pages 16 to 120 of the meeting pack and pages 2 to nine of the table pack for all relevant papers. Can I remind members that at the meeting on the 26th of March 26, the committee considered the department's paper giving notice of its intention to launch a public consultation to seek views on its proposals to amend two schedules of the firearms northern armed order 2004. The proposed changes will make amendments to the bandit system and increase the fees payable for licensing and related services. The committee agreed to request oral evidence from the department on the proposed changes which will be followed by oral evidence from the British Association for Shooting and Conservation commonly known as BAS BASC.

Members will be aware that the minister issued a written statement yesterday advising that the consultation has been withdrawn following feedback and responses received. Questions on the options considered and concerns about the consultation process itself.

Can I inform members that the department officials providing evidence today are Christopher George, head of firearms and explosives branch, Dr. Jennifer Stewart, Firearms and Explosives branch, Claire Duncan, Firearms and Explosives Branch, as well as Mark Roberts, uh, chief superintendent of the PSNI. You're very, very welcome to the committee. So, thank you very much for your attendance. I suspect you have an opening statement. Uh, and so, uh, Christopher, if you want to lead off, thank you very much.

>> Thank you, Chair. Chair, members of the committee, thank you for the opportunity to appear before you today on the matter of the department's consultation on proposals to amend the firearms licensing fees and the bandit system. My name is Christopher George and I was appointed head of firearms and explosive branch in April 2026. I'm joined today by my colleagues Jennifer Schuert and Claire Duncan and also as you stated Chief Superintendent Mark Roberts from the PSNI. I'd like to acknowledge at this stage that the committee will be now be aware of the minister's decision to withdraw the consultation. I want to take this opportunity to apologize for any inconvenience that this is may have caused the committee and will aim to answer any questions on this.

By way of background, firearms licensing in Northern Ireland is governed by the firearms Northern Ireland order 2004 and the chief constable is responsible for a majority of firearms licensing under that order. The firearms licensing service is a critical component of public safety. It requires robust assessment processes to ensure individuals who are granted firearms certificates are fit to possess those have good reason to do so and that such possession does not present a risk to the public. Fees for firearm licensing in Northern Ireland were last amended in 2016 and have not kept pace with the rising cost of administering the service. Over time, this has led to a significant gap between the income generated through fees and the actual cost of delivering the service. This deficit places increasing pressure on the firearms licensing branch within PSNI. Critically, it diverts valuable resources away from the mainstream policing budget, raising follow questions regarding the long-term sustainability of the current model.

In light of this, the department wants a public consultation to seek views on proposals to amend the current licensing fees. The consultation also saw fuse on proposed to add additional calibers of rifles within schedule 1A of the 2004 order. Uh the bandit system as it's commonly referred to sets out the firearms that may be exchanged in a one-off one-on-one transaction carried out by a registered firearms dealer. The consult the consultation has provided an important opportunity to seek the views of a wide range of stakeholders including certif certificate holders representative organizations rural and sporting groups and the general public. The department has received a sub substantial number of responses close to 1,000 which reflects a high level of interest and engagement with the proposals.

I recognize that proposals to fee increases can be of concern to certificate holders and other stakeholders. It is therefore essential that any changes are implemented in a transparent evidence-based manner with clear communication about the reasons for doing so. I'm aware that many respondents have expressed strong views about the relationship between proposed fee increases and the standard of service that they receive. Stakeholders have highlighted concerns around processing times and delays. While many have questioned whether an increase in fees will accompanied by a demonstrable improvements in these areas. In reality, moving to full cost recovery will sufficiently fund the current FS PSNI FEB staffing model, essentially allowing the service to maintain its current practices. Any desire or plan to increase the capacity and capability of that branch would likely require additional funding beyond the current full cost recovery levels. That being said, the department fully acknowledges these concerns and Chief Superintendent Roberts may wish to address some of these mis some of the misconceptions regarding the operational delivery of firearms licensing service separately.

The minister has carefully considered the strong and consistent concerns expressed since the launch of the consultation and following recent advice from officials, the minister has taken the decision to withdraw the consultation at this time. This decision reflects the minister's commitment to listening to stakeholders and ensuring that future proposals are developed on a more informed and balanced basis. The department will now take time to fully evaluate the issues raised. As part of this process, we intend to engage with key stakeholders to better understand their perspectives and to inform the development of any future proposals. The department intends to bring forward a consultation in due course supported by clear evidence and proactive engagement so that those who wish to respond are better informed to do so. This approach will ensure that any future proposals are robust, transparent and capable of commanding broader confidence among stakeholders and the public. The department remains committed to maintaining a firearms license system that is not only fair but also sustainable. The outcome of any future consultation will play a key role in shaping the next steps in achieving these objectives. I look forward to assisting the committee with any questions they may have and I will now invite Chief Superintendent Roberts to provide his own opening remarks. Thank you chair.

>> You Christopher going to hear. >> Thank you chair chair members of the committee. Can I add my thanks to those uh of Chris for the opportunity to appear before you today? Uh, I am Mark Roberts and I'm the temporary chief superintendent in charge of protective services in the PSNI's operational support department. As part of this role, I am accountable for firearms and explosives branch and the delivery of the service that they provide. I recognize that as well as the proposed amendment to the firearms licensing fee and changes to the bandaid system which were put forward under the now withdrawn consultation, this committee will, as with many others, have an interest in the performance and efficiency of the branch. And I'm happy to address that today.

Firearms licensing is one of the high-risk risk matters which the PSNI deals with and even the most effective process of assurance before authorization will always result in a residual risk as firearms enter the community. Our processing is always a balance of timeliness against the risk to the public uh public safety and one which I and my team take very seriously. We are all acutely aware of the impact of misuse of firearms in our community and our responsibility to keep people safe. [snorts] Addressing the criteria outlined in the firearms order in relation to fitness to to be entrusted to hold a firearm and having good reason to do so makes it often necessary to carry out complex checks and seek additional information often from third parties to make the right decision. We are incredibly grateful for the partnership we have developed with those who represent the firearms community who assist us in this task.

Turning to the proposed amendment of the fees from the outset I wish to make clear that the PSNI seeks nothing more than a costneutral basis for the delivery of the service. This position is wholly in keeping with that laid out in the department of finance document managing public money in Northern Ireland which states charges for services provided by public sector organizations should normally pass on the full cost of providing them. The FEB funding gap in 2025 to 26 financial year was approximately 1.75 million made up of payroll overtime and non-pay items including postage and medical fees. That substantial figure is drawn from the PSNI's main grant budget and has an inevitable and direct impact on our ability to fund other critical functions, including tackling the unacceptable level of death and serious injuries on our roads, violence against women and children, race hate, and the threats from terrorism, and serious and organized criminality. The chief constable has been crystal clear with the policing board and the public about the PSNI's stark financial position. As a service which has not yet received confirmation of our budget for this financial year, we are operating with a predictive shortfall of 57 million pounds this year, rising to 92 million and 149 million over the next three years. You will appreciate that the shortfall in licensing fees is a significant sum of money which we seek to recover.

I note that this matter is also being addressed in England and Wales where on the 14th of May this year, the Minister of State for Policing and Crime laid a statutory instrument in Parliament to increase licensing fees from the 4th of June with a range of fees based on the transaction type and to concurrently introduce more regular inflationbased increases alongside a comprehensive review of costs to take place every 3 years.

On the matter of efficiency, I would like to start by saying that as the individual who's accountable for the delivery of the service, I recognize the inconvenience that delays cause to the community that we serve. The position we find ourselves in, which is reflected across many other areas of public service and government, is not one in which we would wish to be. And I apologize to those who are affected by the length of time some of our applications are taking to process. For context, I have a team of 63 staff who not only process applications, but provide a wide range of other functions laid out by regulation. They provide a service to approximately 54,000 license holders, receiving between 18,000 and 25,000 applications annually. As a snapshot of their work, between July 25 and December 26, they processed 6,636 firearm certificates, made 1,66 complex case decisions, processed 3,117 dealer variations, and made 132 seizure decisions. In addition, they also answered 952 9,052 queries to their help desk and dealt with 1,955 other matters which included the time emotion study completed as part of the consultation process.

As a function, FEB has been subject to five inspections over the last seven years which have raised recommendations in relation to compliance around audit trails, application targets, performance reporting, online service enhancements, and the move towards cost recovery. The majority of these recommendations have been addressed and have enhanced our service. At the request of the Northern Iron Policing Board, we are currently subject to a further deep dive review, which is being conducted independently of me and our branch by our transformation team within the service. The terms of reference agreed with the board are wide ranging, and I can assure the committee today that if recommendations arrive from this review, we will act to implement them. The team have come a long way, and both they and I have an absolute desire to provide the best service possible to our firearms community.

As the committee may be aware, her majesty's inspector, his majesty's inspector of Constabary fire and rescue services are in the final stages of completing a review of firearms licensing in England and Wales. We're engaged with them and will work with them to assess how their recommendations can be applied here where they are relevant given the legislative difference between us. As part of the current deep dive review, HMIC FRS were asked to provide contextual benchmarking of the PSNI's workload and timeliness against national data for police forces in England and Wales to support interpretation of our performance. The initial findings they have presented to me state, "Taken together, the available evidence provides reassurance that the PSNI's FEB is operating at a level of efficiency that compares favorably with national experience in England and Wales. The PSNI processes a high volume of firearms licensing applications, equivalent in scale to that handled by large metropolitan police services elsewhere within the UK. The overall average completion time is below the national average in England and Wales for the year ending 31st of March 2026. While timeliness varies by application type with initial grants and renewals taking longer to complete than variations, this reflects the greater complexity of these cases and their reliance on external dependencies such as medical information. This pattern is consistent with what is understood nationally, although comparable application type benchmarks are not published in England and Wales. Overall, the evidence suggests that the PSNI's firearms licensing function is managing its workload effectively, performs at least in line with comparable police services elsewhere in the United Kingdom, and demonstrates a higher degree of transparency through its routine publication of its performance data. any remaining delays appear to be driven primarily by case complexity and third-party dependencies rather than inefficiencies in its internal processing."

Now, I fully understand and appreciate that for individuals who are waiting for extended periods for their applications to be processed, this assessment by HMICFRS will not bring them comfort. However, given the nature of the service we are providing, I must ensure that timeliness is balanced against the risk to public safety and it is in the interests of all the community we serve that our work is carried out with the utmost diligence and professionalism. Thank you, chair.

>> Thank you very much, Mark. No further comments at this stage. Okay, we're going to go straight into questions then and I'm going to ask Connie. You're the list first.

>> Thank you um for for coming in. Obviously, this has changed significantly in the last 24 hours. Um, I think every MLA here be conscious of the position of public finances across the executive and our public bodies. Um, but you know, I do think that this place works best when people work together. Um, so I'm very conscious that you said going forward now the consultation's been pulled. Um, you're looking to find clear evidence and proactive engagement before next steps are taken. Can I ask what that proactive engagement will look like and what those interested groups can expect?

>> Yeah. Um, thanks for the question. Um sure the the the intention um as you you' be aware this is all came about relative relatively fast with the the minister making the um statement last night that the consultation was being withdrawn. However, it's the department's intention that we will work collaboratively with the PSI and stakeholder representatives to gather evidence and practical in insights that that will inform any future policy. Um we want to proactively engage with those key stakeholder groups um possibly targeted meetings, roundt discussions um and so that we can maintain open dialogue. We also hope to and will provide regular updates as we move through this to keep stakeholders informed um on possible policy development and the next steps. And um we also want to demonstrate that our responsiveness by ev by demonstrating what evidence we will use as we move forward. Um I'm keen that um that we are now taking the time following the minister's decision to reflect on where we have got to. I think it's important for the branch to do that and once we have done that hopefully then we can move to reaching out to stakeholders and and begin that process of that engagement as we move forward. Um, no, I I think that that's important and I don't think any groups that that have an interest in this never expect for prices to never go up when it comes to licensing, but it really is about that approach and that engagement. Um, so I think that'll be a positive way forward and do you foresee that happening before the end of this mandate, before the consultation's relaunched, um, or how long you expecting this process to take?

>> Um to be to be clear um I think that the the timings with this um this is going to impact upon the the obviously the delivery of any changes and the timings um the introduction of any amended legislation is highly unlikely in within the current mandate. Um this in turn is going to impact upon the department's ability to consider other firearms other aspects sorry of firearms and explosive legislation. Um the the current 2004 order provides limited powers with regards to regulations. Um as a result more substantial policy changes are likely to require primary legislation in a future mandate. Um but this this decision by the minister represents an opportunity for investors um to essentially assess assess what resources will be required how we can address the concerns and whilst you're you're right in that and fee increases are are are essentially no one wants to see it. However, I believe that if the branch can demonstrate that how we have arrived at those figures and the evidence supports that, then we hope that that that will provide a better conversation and and gain more support from from the stakeholders as we move forward.

>> No, I know I appreciate that. Um, and then that last question, chair, if you don't mind there, I think you'd mentioned that this could impact on other firearms legislation. Um, what what other firearms legislation are you looking to do?

>> Well, it it's it's essentially I believe that the the PSNI we we have ongoing engagement with the PSNI and we have for a long time and I I'm sure that there are wider policing issues um maybe uh outside of the firearms uh issues but again we are very focused on the firearms fee as it is a priority for the department and it's a priority for the PSNI and for that reason our focus is going to be solely on how we can look reflect on what we have done and how we move forward with regards to launching a a future consultation.

>> Well, thank you. >> Thank you, Connie. Thank you, Christopher. You said about policy development and next step. What is the next step?

>> What is the next step? >> Is the next step? >> Yeah. When you leave here today, what is your next step on this?

>> Um I think um when we return um to the branch, uh we we need to review how we've arrived at this stage. Um I understand it's not ideal. We we understand that this is a wide ranging um topic that affects a lot of people um I also just from a personal point of view um having having joined the branch really in midappril um it's clear to me that firearms ownership is not simply a regulatory matter um it's one that's closely tied to people's identity to their heritage um and obviously to their rural life um I recognize the strength of feeling across that so it's important that the branch takes the time to listen to the stakeholders to see what we could have done differently um that uh how we can address those concerns. Um how that looks right now, chair, I think it would be I'd be reluctant to second that, but we we want to begin the process of of reviewing how we've got to this position and take it from there.

>> Okay. You said that the the minister whilst it's the minister's decision here to withdraw this uh consultation, you said it was from uh recent advice from officials. what officials advise the minister?

>> Okay, so the we um we have been listening since the consultation launched. We obviously have received quite a lot of responses. Um the um we have had consistent responses um with regards to the concerns that have been raised. Um the advice around that is that we we have we we have felt that there are some some ways that the consultation could have been more transparent with regards to um the publication of some of the data collection exercise that that um was referenced. Um we also believe that there there have been some issues with regards to the consultation document itself. Um so we we we are concerned that this this has not um provided respondents with all the information to make an informed decision and and whilst we we want to reflect on that and we want to see how we can do that better in in the next uh if there is another consultation that's constant future. I suppose why I asked that question is usually you'd find with the consultation launch the consultation finishes then you assess the information you've collected from the respondents >> but this seems to be really strange that we're basically just stopped and withdrawn a consultation days before it was to end anyway.

>> Yeah. >> It it is it isn't unregular to do a consultation on something and then decide to do another consultation on it again. >> Yeah. Why would you not take that route as opposed to withdrawing a consultation when it was going to close in two days time?

>> Yeah, chair I think that sorry not I think but the reasoning behind that is that we we following following our review of the processes that we've gotten to us and again we we decided that it would take it would require us amending the consultation sorry pausing the consultation then launching amended documents having to go out consider the the respondents that we have already contacted um launching sharing those additional documents. We just felt that that that would be messy. And whilst that was a viable option and potentially extending the closing date of the the consultation for a period of 4 weeks, um whilst it was a viable option, we we also presented a viable option to the minister to withdraw the consultation and essentially start a fresh. Um we felt that that was the cleanest option. And >> so to be clear that came from firearms and explosives branch officials. >> Yes. >> Y okay. Thank you Paty. I'll bring you in now.

>> Thanks very much for that. and we're we're getting a we bit of um light on matters now. Um just just picking up on that, did did nobody kind of red flag these issues prior to the consultation happening?

>> I I can speak to um that when when I joined the branch and when we met as a team to review the con the issues as they come in and the responses as they come in, the branch worked as a team to review this and in hindsight we believe that we we could have possibly done things differently that to address those concerns.

>> I appreciate that. Just just by way of of fact, um, Chief Superintendent, I was checking the figures there from from GB and the the initial grant of a firearm certificate over there is £24 and a renewal is £135. >> Yes. On the fourth. Yes. >> Yes. So the the proposal here is to an initial grant 250 quid and renewal £250 quid. So there's a brief disparity there and if they're going with as good as full cost recovery, I don't know don't know what's going on there. But if I could please just come back to there's some figures here. Would maybe like to to drill down on them. So um maybe you could explain to me please. The department um had a shortfall which went from £267,000 in in 2018. Now adjusted for inflation today that would be about 383,000. How did that leap from potentially when we say 400,000 rounded off there up to 2 million?

>> Um are you okay if I speak chief superintendent? >> Yes. Go ahead. >> Um just from working on the consultation I'm aware that uh the firearms inquiry officers the costs were attributed to the local districts in 2018 when the Northern Ireland audit office report was published and they are now part of firearms and explosives branch model. So therefore those costs are now. >> So do they account for 1.6 million? >> Oh that's the full costs of running. So that's the deficit of yes between the receipts that are >> No. My point is sorry if you could just explain that the shortfall back in 2018 was 267,000. >> If you adjust that for inflation that would today be almost 400,000. So subtract 400,000 from almost 2 million that's 1.6 million. Is that the cost of running the firms the firearms officers in each district? >> That's the deficit between the receipts and the cost of running or providing the service. >> There is a increase. >> Why is there such a huge increase? That's why I'm saying >> yes. I couldn't speak to that because I don't work for but it would be helpful if we heard that because that seems pretty huge to me. There was a big difference and um we are aware that the farms inquiry officer salaries were not included back in 2018 in that deficit figure but are now. >> How many firms and quiry officers are there in total then? >> I don't know. You you can appreciate the reason why if there's been a huge leap in figure there up to that point you're saying well why should that be the case? Um especially now people are working from home. I know that and um there I just don't know. It's for you to come back to us and explain to us why that should be the case. Now if you want a bit of latitude you come back to us on that. Don't expect an instant answer today. You may well not have been anticipating that question but it would be helpful chair if we could have an answer to that. Um >> chair I would be happy to to provide some measuring if it would assist you. >> So since 2018 the structure of the branch has changed. done now have 63 people who work within the branch and the the difference between the initial sum which was chargeable with an operational support department and the figure that you see now is the difference between what was costed to the function at that time and the figure that we have now arrived at which is the full cost of the firearms licensing process we have so the figure that you have today the deficit that we have of 1.75 million reflects the difference between what we need for a fully costed service and what is being subsidized by the rest of the organization and you made reference uh in relation to the firearms fees in England and Wales from the fourth to £24 and £135. >> Uh we operate in a very unique circumstance here. We have significant differences in legislation. >> We also have significant difference in the number of people who hold personal protection weapons. So the comparison as HMIC stated between England and Wales and here is one that in some ways is not an equivalent because of the differences in the legislation and the type and nature of the firearms that we license. >> To get that in PPW's account you'll appreciate for a small number small percentage of that 50 odd thousand. Um but you still have a renewal fee of almost half of what they're proposing here. So um I just I just don't understand that. Uh and it would be helpful to come back on that. Now um one other thing the with the implications of people and you've heard you've heard the evidence and I'm sure you've heard a lot of it coming in um Mr. George in the responses about people having to wait so long for variations to their FEC and this is people who already have a firearm certificate. So therefore any security issues or else that would normally have been flagged up at an earlier stage and they may not even have been any longer in retention of those firearms. But there there's that one there's that one thing the slowness there but if I could come over to the the other aspect of it is people have to run businesses and sell these firearms and if you have as I've been with a number of RFDs registered firearms dealers and they say come to you see this and they show their store and there's banks upon banks of firearms sitting which have been uh sold or had a deposit placed on them for sale. all has been the paperwork and all has been done and it's just sitting there. Now, the implications of that are and you you're more than aware of this that if they're at or about the the quota under the ministerial directive, they can't bring in any new firearms to put them in the shelves to sell. So it's it you're sitting there, you have stuff sitting downstairs or wherever it is in the store on their lock and key that it might be that can't be moved because the deposit the deposit sitting on it or maybe even the full amount of money pending the person either getting their firearm certificate the first time or getting a variation on it. meantime someone could say I fancy a new whatever it might be over and under or a new uh target whatever it is that person that dealer can't bring them in because it takes them over their kota so um has there been any thought given to um a bit more not latitude but a bit more understanding of the the restrictions that the ministry elota places on the functionality of a business because they they have to they have to turn a wheel they have to try and earn money from this. They are a business, the the RFDs. Has there been any consideration given to that at all? Because if one end isn't working properly and the firearms aren't been turned out properly and the the FACs aren't been turned around, that has a consequential effect on the business, particularly so if they can't bring in what the person fancies as a new item or uh a new a new gun for for target shooting or whatever it may be.

>> Yeah. Uh ch I I answer that with um based on my knowledge and cla can correct me on this if this isn't correct. We we engaged and we carried out a survey of RFDs in 2021 >> 2021 and I think 30% of those dealers responded to us. >> Um the the department acknowledges that our dealers represent a key group of businesses and that there's over 80 within Northern Ireland. Um the department has engaged with PSNI to seek reviews on that matter. However, at present the clear priority was the recovery or sorry was the the fees issue um and the move to full cost recovery. Um I aware that there's concerns that that some within the the dealers around the the holding limits in the context of application backlogs and um we as I've said we have engaged with the PSNI on this and um I'm not going to speak for Chief Superintendent Roberts um but um we we're happy to continue engaging on that front >> but it is whatever you engage with chief super no disrespect to you superintendent but it is the ministerial directive that the clues in the title >> so Um if have you been in a position chief superintendent to give advice to uh the DOJ on this matter? >> Uh yep sir it would be the opinion of the police service that at this time we would not support that. We recognize the impact that this has on the dealers, but our priority has to be to ensure that the system and the process works effectively around protecting public safety and placing more firearms into secure pro premises in the community is not a position that we wish to take. We would like to see an acceleration of our processes. We've talked about cost recovery today. We will take part in the reviews that are taking place. As I've said, if we get from the deep dive any suggestion about how we can accelerate the processes to ensure that we can get licenses issued faster, we will take it. But at this time, it is not our view that placing more firearms into the community into storage would be a beneficial process.

>> If I just that would be a criticism of the DOJ itself because they're the ones that sign off on the adequacy of the storage. >> It's not a criticism of anybody. It is our position that firearms going into the community present a risk to the community and those firearms will be sitting because we have been unable to fulfill and complete the licensing processes for the individuals who will hold them. So until we can assure that the individual to whom the firearm will go to is a fit and proper person to hold that firearm and has good reason then we would not be supportive of increasing the storage in the community.

>> We're going way off in two different directions here. Okay. a person's ability to hold a firearm. And most of those, incidentally, are variations. So therefore, you've already said that they're a fit person to hold a firearm, right? Uh unless there's some uh newer young person taking it up. You've already said that. But that's a totally different argument to this one that I have here by the ministerial directive. And they're not going into the community. They're going into a fit and secure premises which has been signed off by the officials of the DOJ following many scrupulous inspections in some instances. So, they're not going out into the community, lest that be misinterpreted by maybe someone listening here.

>> No, they they are being held within a an armory within the community. And when you say that variations from somebody who has um already held a firearm, a significant amount of our work is when we carry out those variations, seeking further medical advice, >> providing further background checks and quite often when firearms, particularly in the complex queue, go into that queue, it is because of the unique circumstance of the individual who is seeking them. So one of the things that we worked closely with other partners within her majesty's inspector of conabary from conversations we had with them recently is the renewal process in itself looks different in England and Wales. So that's one of the things that we'll be looking at with them. But underpinning all of this is man is managing public safety. >> Yes. >> And the prevention of firearms going into communities unless we know that the people who hold them are appropriate to hold them. That is no criticism of the dealers whose current armies as inspected by the Department of Justice are fit for purpose and I recognize the impact that this has on them. But at this stage it is our view that this process for licensing needs to change and that making I have to balance timeliness against the risk to public safety >> and changing make making a sticking plaster fix by saying you can hold more firearms rather than pushing through legislation and changes to regulations which will accelerate this process to everybody's satisfaction is not a solution that I would wish to pursue at this time.

>> Now that's simply That's that's simply [snorts] our advice to Department of Justice. >> You you invite the obvious question then of those number of firearms currently waiting for variation at FEB, how many of those have question marks over them? >> I I would I I couldn't the finger and I'll I'll come back to you. >> You've invaded you've invaded that question by the logic that you were taking. >> And and I'm happy to do so. And I did say earlier that we I think there was something like um we made 166 complex case decisions. at 3,117 [clears throat] dealer variations which is a significant number but if if there's a specific figure that you're looking for we would happily bring it back. >> The way I say that chief superintendent is if I followed the logic of your argument to its conclusion and I go back to the RFD and I look at those maybe 40 50 60 guns that's sitting in their armory that can't be moved on. By no stretch of the imagination are those 50 or 60 firearms all complex cases. >> No. >> So that's where the no the problem is. >> Yes. >> And if the if there has to be a further inquiry made by whoever it is by medical or MI5, whoever it might be, I get all that and understand all that. But it's for the rest of those that are not complex cases that could be processed that could alleviate it for the dealers who are having a problem with the quota of firearms that they can retain at the moment. That's the issue and it's probably a management issue to say let's structure these. Let's see what are complex. Let's see what aren't complex and those that aren't complex that maybe already have a firearm certificate a good reason to hold it and clean bill of health and everything. Let's go with those. I I just don't know. It intrigues me how that could be the basis of your argument whenever I know from the dealers [clears throat] that all those firms that are sitting there are not all complex cases. And I would just be reluctant to allow that message to go out from here today.

>> And I and I'm not saying they are all complex cases. When you look holistically about the issues we have with firearms licensing, the key piece that we were here to discuss today was the consultation on the fees. Yes. >> And that would make us costneutral. HMIC have stated to us that they see our service as efficient and in line with the rest of the United Kingdom. To accelerate that process, we will look at the deep dive. We will take any of the recommendations that come from it. Although I should state we have been reviewed five times in the last seven years with no significant process recommendations change changes made. We're told by HMIC we are comparable with the rest of the United Kingdom. To accelerate the process at the minute will take additional staffing and at this time as the chief constable has said repeatedly we are significantly below the resourcing levels we should have to deliver a service in a comparable policing area. So at this time putting a solution like increasing the numbers that can be held which would very quickly with the processes that we have be filled will place us in the same position within a period of time that I wouldn't want to put put a measure on. So the process of firearms licensing is running effectively in efficiency. HMIC have say stated that the timelines relate to staffing and at this time we simply don't have more staff within the service because if I drew more staff from anywhere else in the service I would be drawing them from other critical functions to deliver this.

>> So one one just final and then Mr. Chair I'll drop this for the moment anyway. Um, HMI I see you're saying you're comparable to other constabularies. I would dip in and out now and again of the other stuff and I see similar queries, similar complaints coming about and read the the shooting news and B see similar complaints about constabularies with maybe the one occasional uh good comment here there similar complaints similar issues been raised about delays. But the one thing I would just caveat everything and just I'm more or less marking your card rather than anything else. The last time and the chair and I were both in this committee. The last time we went through all this before, increased fee in will definitely lead to increased efficiency. It didn't. And you can understand there's a body of people out there who are shooters who really enjoy their sports and all that is saying this is Groundhog Day. We're going through this again. We were we were promised efficiencies. The dealers were promised efficiencies, all that sort of stuff. And are we going to have to pay more to get more of the same? That's a concern out there. And it's important that you and the department are aware of that >> and and I and I'm fully aware of that and I and I said and I I meant it in in my opening statement that I apologize for the delays that this is this is causing and the inconvenience that it's causing. And we do have I'm grateful to say since 2023 under the team we have we have seen a significant change in the relationship between the police service and the communities that shoot. >> Yes. >> We have seen a significant improvement in the work that that that team do. uh and and the manner in which they do it often in the face of quite significant abuse um from individuals. If anybody's watched online, the responses today to the withdrawal of the um consultation process, some of that abuse is directly pointed at members of my team who work very hard delivering the service they do, often on overtime to try and maintain the relationship we have with with the communities. And I I can only come back to we are committed to the review the policing board are doing. We've seen what HMIC have said. We will adopt anything that will improve this service, balancing public safety against timeliness. And I know I'm a bit of a broken record with that, but but that is where I am. And it is absolutely in my heart and the team's heart that if we can improve this in any way, we will. And as we spoke of the dealers, I understand the impact on them. As we speak of the shooting community, some of whom have waited in a complex queue for an extended period of time, we understand that. And and and I'm happy to have my card marked because the relationships that we have now are not the ones we had when we were here before and we are more than willing to listen and to work with people to deliver service.

>> Just would be associated anybody who's abusive towards public servants going about their their daily work. That's a disgrace. And they also they also should be concerned that if they're seen making abusive commentary, it could call into question whether they're a f person or not. >> It has not escaped us. No. And thank you for your comments. Thank you, chair.

>> Okay. Okay. Thanks, chair. >> You're deputy chairperson. >> Thanks, chair. Thanks to you all for coming in. Um and I suppose this conversation is I mean the the situation has changed. So um it feels almost a little bit um I don't know late in the day to be having this conversation after the decision to pull the consultation. And I I'm mindful that you you you're rescheduling that um which will be cause for concern um because I think the the lack of consultation with rural communities and the fact that even in the rural needs assessment, the fact that some of the the questions were were disregarded is is cause for concern here. Um, I can declare an interest as the the daughter of a sheep farmer in the in the Spar who has a a firearm because he needs it for his livelihood. And I suppose there's a growing um feeling within a community like that. Hill farmers are more likely to need to control pests because of the the nature of the land that they're operating on and the fact that like my father lands outside. So he he will lose lands every every season um as a result of that. So it almost feels that that particular group are being the victim of increasing pressures at the minute

And and we see the cost of living increases, the price of fuel, all all of the pressures that are on them and this was something that was causing serious anxiety. So I suppose my primary concern here would be how is that going to be considered um ahead of this next consultation? What what what is going to be done differently?

And the second question that I would have, and I note the the reference to the the system going online, and I I I don't know, maybe I missed it, around what um efficiency it said that that decision was made in order to um provide efficiencies. I don't what level or if that has been measured in terms of what saving there has been from the system going online. But I would again uh make the comment that a a huge percentage of the population who need guns to manage livestock um are increasingly, and we see this from the Department of Agriculture as well, where every single thing it is is online for for a cohort of people who do not work with online systems as part of their job. And um it feels often like a barrier. And I know as a constituency MLA, I would very often have people coming into me for help with these applications, both for DRA and for the the um firearms licensing. So I would I think that in order to justify that the this the saving would have to be significant because really an awful lot of the time it feels like this um turn over to an online system just um isolates a rural community who are already isolated and I think that point needs to be considered by the department.

>> Yeah, sure. I I would I'd say that the the minister, the department, and certainly the branch ourselves, we are very conscious of the impact this is having on all license and soldiers and those that require the the firearm for legitimate p purposes. Um whether that's uh for obviously their employment, personal protection. Um what I would say is that um the it's essential that the the reason for applying for a firearm certificate, that the license fee remains the same for all applicants as as as per the legislation. The each person must be assessed to be a fit person to hold that firearm and they must must have good reason to uh for having that for having that firearm and and any ammunition that is applied for. So I I'm not going to speak to PSNI's processes, but we are aware of the the concerns um as part of this pause so to speak with regards to the consultation. It's the branch's intention that we will again consider the documents that were that were put before as part sorry that were published as part of the the consultation process to see if we can be clear with those what we can do differently with regards to those. Um but I I will I'll possibly pass over to uh chief superintendent to address the the online application system and that's delivered by the PSN. But our our we are aware of those concerns. But it's it's very much our position that the each individual regardless of why you need the firearm, you have to go through the appropriate vetting and and procedures.

>> Of course, but I and I don't know these figures off the top of my h head, but I am assuming that the vast this this is seen as a rural pursuit or something that people the vast majority of people who need this for their livelihood are rural dwellers, so it has a disproportionate impact on a rural community and I think that that's something that has to be.

>> We are aware that people use firearms for sporting purposes, for farming, also for collection purposes, target shooting, for a whole range of activities. Um, and we have we have provided the rural impact assessments, but we have also seen the feedback that's been coming from the consultation responses to date. And as Christopher says, we'll be taking that on board as we prepare further impact statements.

>> Is that you? I >> think were you going to Yeah, go ahead. Um going to the the use of firearms uh for business purposes. Uh one of the things that we do do is where concerns are raised to us by uh elected representatives or other individuals around delays for issuing a firearm for a work purpose for for farmers, for vets, we we've had this uh we will seek to move them through the queue uh quickly to address them as as quickly as we can and appropriately. that does have an impact because if you're seeking a weapon for a a leisure purpose, there's no mechanism to accelerate that. So when we accelerate a queue for firearm through a queue for a vet, that means that we're not dealing with somebody who may have applied an earlier date, but we are alive to that. We do detail that and and we're grateful when people bring them to our attention. uh in relation to the online system and I I will come back to an answer on that in terms of the overall efficiencies, but we have been challenged a number of times about access to this system. Uh to date, to my knowledge uh and it is recent knowledge, there have been no complaints to the equality commission in relation to the accessibility of the system. We've worked very hard with the firearms community. We did a lot of road shows and things like that and and as you've spoken of your own experience. Um, we we we ask people where necessary to seek help if if they find themselves in a difficult position. And the overwhelming feedback we've had about that online system is that it is welcomed, particularly in relation to renewals where the system will automatically complete forms uh and documentation for you based on on previous information. So we will provide a written response to the overall benefits. But our experience of feedback in relation to that system has been overwhelmingly positive and we will look to move other parts of firearms licensing uh onto uh an electronic system um to to try and achieve efficiencies. But we recognize that with that we have to understand that there are some communities who it's more impacted on than others. and we're more than happy to listen and we're more than happy to work with them to to prevent there being any harm.

>> Okay. Thank you. >> Just before I bring Brian in next, can I ask on that question that Emma asked around rural needs? Uh and Claire, you did talk about the rural needs impact. Uh can you give us any update on them and can you tell us any material differences those rural needs impact assessments have made in your consideration?

Well, it was a draft consultation rural needs impact assessment. As Christopher says, we are going to look at the concerns that have been raised, including one of the questions in the consultation was directly about, please look at our rural impact assessment or section 75 impact assess or screening form and please give us you know information so that we can understand the impacts um on certain members of the community.

>> And we will take that on board.

>> Okay. Thank you Brian. Hey, thank you chair and thank you for your attendance today. Um certainly I think we can all uh understand the importance of firearm licensing the interest of public safety and and the outcry there is if any legally held weapon is used in crime or for an atrocity and how uh questions would then be would then be asked that uh would put everything in perspective. Um, can I just ask in terms of the the fees not increasing for 10 years, why has that been the case? from the previous constitutions.

Sorry.

>> From fees have not increased since 2016.

>> Yes.

>> Why has that been? Is that because ministers when they were in in post didn't took a decision not to increase them or or did it need legislation to actually increase them?

It needs legislation and since 2016 there have been a number of periods where we didn't have a sitting assembly as well and there have been other issues in the mix. We had a U exit and things like that as well. Um, so this has really been the first opportunity to have a further look at fees.

Right.

>> It's not like like Translink fees or housing executive rent fees that a minister can make a decision or.

>> No, we if we wanted to make more significant change beyond what's currently in the firearms order, we would need primary legislation. [clears throat] We can use secondary legislation to increase to vary the sums that are in the current structure, but anything wider would require primary legislation, which would be much more in-depth, longer piece of work.

>> Um, so at the moment we have been consulting just on proposals to change the amount within the current structure.

>> Yeah. Okay. I mean, just as with any fee, if it goes up gradually with a round of flation, it's less of a shock. When it goes up by 150%, obviously there's going to be a reaction. Uh, we catch the general comment. Um, and from my own understanding, how often does a license last for? Is it 5 years for all firearms? Is that right?

>> Or I think it's the majority of the licensing. There might be one visitor permits, maybe one year, but I might stand corrected on that.

Okay. But most are five years.

>> Mostly the general firearm certificates. Yes. And the dealer certificates.

>> Okay. And will Mark uh in particular uh what is your view? You said the HMIC concludes that the time scales are similar to other constabularies. Um, but I understand the the target has gone from 56 days to around 120 days. Is that right? For the uh FEB. So can you say more? What is your view on the time scales and the time being taken?

>> My view on the time scale and the time being taken is that it it takes us too long.

>> Yeah.

>> That is that there is no I I'm not here to to to try and pretend that I am satisfied with the timeline it takes. But the timeline which we are achieving at the minute is a measure of success of what that department are doing, not a measure of failure. And that is reflected in what HMIC have said. They're saying that overall we turn around all licenses faster than they do in England and Wales. Now that's obviously a huge bell curve and there are some very long delays and there are some turnarounds particularly around variations which are much faster, but I think that the timeline that we have at the minute is a reflection of the very best that the department can achieve and HMIC have been clear in their statement that they do not see inefficiencies in what we're doing. In an ideal world, I would have significantly more staff, which would enable us to address the cues. But at the minute, as a service, we simply don't have the staffing numbers that we require to deliver the service that we want to achieve. Um, and as I said earlier, we've we've looked at AI and all sorts of things to help us to to to try and manage the cues down.

Um, and we will adopt any any of the recommendations that come to us. But I apologized because I'm not satisfied the time it takes. But I think it's really important to say to those who are watching and to the committee that is not a reflection of inefficiency in the team who [clears throat] as I said earlier often work on overtime to clear some of the backlogs that we have. It is a reflection of how we are currently structured and the funding sits separately from that because the additionality around the 1.75 million that has been subsidized from main grant is further taking resource from the service which could be delivered which could we could be putting against some of the things I spoke of earlier.

>> Okay. And is it currently largely a paper based process?

>> The the electronic system has provided great benefit because it's moved most of it to an electronic system which assists us as well, which means that we're not moving through large amounts of paper. But when it comes particularly to the complex queue, you'll be aware that we use the national decision model uh as a a basis for all policing to review um threat risk and harm. Um, and that process is completed on forms um which my seniors uh complete.

>> And would relic renewal of applica of licenses they fasttracked if there's no issue has been flagged up or.

>> So the the there are various parts of the team and if if you would like a written response in in who exactly does what we we'll be happy to provide it, but the seniors take the complex cues and other staff within department will look at the more day business ones. But if you move from a renewal where we are satisfied that there are no change and no differences in circumstances, whilst there is a res risk and a residual risk that we can't mitigate, that is appropriate that members of the team uh who sit in the main office would deal with that. But when we move to the complex cases, they will move to the seniors because the risk escalates in that process.

Okay. And um, yeah, in terms of the whole issue around full cost recovery, no one doubts the pressure the police budget is under uh and every section is under. But the police and the department provide various services in the interest of public safety. You know, access and eye checks, um policing at public events, you know, parade applications. So I mean I'm not making suggestions, but there's there's various things in in the interest of public safety that don't operate on a full cost recovery basis. Um, so that would be the argument back you know on on something which is.

>> And you speak to a matter close to my heart around events. um because uh one of the I'm a gold commander and a silver commander and one of the functions that we look at repeatedly is around cost recovery and we would not be along with a lot of policing across the rest of the UK satisfied that that is appropriately structured uh where individuals have to ask us to provide a police service before we can charge for it [snorts] and we are very alive to the impact on the rest of policing as matters such as those and And most of the things that you mentioned are areas in which we are also seeking to address the cost deficit.

>> But the events is one I can speak to clearly because it's one that I'm often involved with having just been the gold commander for the Northwest 200. And there is a balance to be struck between the ability to provide the events for the community because that you know that event itself brings in something like 21 million pounds a year for Northern Ireland. So there are benefits in that, but it also places a significant re impact on policing resource and demand um which we need to be alive too.

>> Yep. Yep. I know and and I realize that's ultimately it's a political decision you know um um I just want to ask to um yeah you said earlier Mark uh that the police I don't know if I'm misrepresenting you, the police view is that it is desirable to reduce the number of firearms in the community in the interest of public safety, is that is that your position or what is the.

>> I said earlier that the placing firearms into the community has a residual risk.

>> Mhm.

>> And it is our desire that those firearms go into the hands of people who truly meet the definitions that we we have around fit to hold and good reason to do so. Um, we sit I think uniquely compared to quite a lot of the UK in that we have quite a considerable number of people who have a very considerable number of firearms. uh often they are collectors who state an interest and within the current legislation and we spoke you spoke earlier what legislation would would you be interested in looking into, one of the things is getting a clearer definition on good reason for whilst it's not my intention or my desire to get into anybody's wish to collect firearms uh all of which are held and secured I accept that, but there are a number of people in the community who are collectors who hold a significant number of firearms and any large number of firearms in the community carries a residual risk with it and we are all fully alive to the consequences of that. So um that that would be my position.

>> The storage arrangements a responsibility of the department. Is that right? Or or who inspects that?

>> It's PSNI.

>> It is the police also PSI.

>> We inspect them.

>> So and when a license is renewed, do you have to go out to inspect it or is it inspected once and then not again?

So we we have changed our process recently where we will ensure that every location that holds a firearm is inspected at least every 10 years.

>> Okay.

>> Um, it would be my position that ultimately we would increase that, but at the minute.

Increase the frequency.

>> Increase the frequency because this is a key matter for public safety. I am satisfied with the position that we have at the minute. We have made that change in response to recent events that have taken place in Northern Ireland. Um, but we keep these matters under review all the time.

>> Okay. Thank you.

>> Can I just add to that because you raised something uh for topical mark there and I think important with regards to the good reason element. When you say good reason, that means good reason to enter a premises to inspect.

>> No.

>> Or good reason to have farms.

>> Yeah. There there are two criteria in terms of the firearm. One is that you must be a fit person to do so. The other must be that you have a good reason to do so.

>> And at the present time, what are the good reasons to have one?

>> There there is no list uh there's no definitive list of good reason. And that's why some of the firearms end up in the position with my seniors because particularly in relation to so so farmers in particular in relation to vermin control, that's a good reason to hold a firearm. We see quite often significant changes within the sporting community who often change type and nature of um shooting classification that they undertake. And when that comes into us and they they require an additional firearm um, we will then have to work with and as as I said earlier and I mean it, the relationship we now have with with the community, the firearm community and some of those who are sitting behind me is exceptionally good now. um, and and we rely on them to to help us to understand the sport and understand the good reason. But we we see new shooting criteria, new classifications of sport are they're being made all the time. Um, and we have to assess is is this a good reason for this new type of shoot that you wish to take part in. So the good reason is not to to access it. The enforcement sits entirely with us in terms of legislation. That's that's something that we deal with. But the good reason and a fit person is to own the firearm.

>> Okay. Before Ranken, you want to eat small one Brian on this?

>> I just want to clarify Christopher, I think it was yourself said earlier in terms of the decision, the statement from the minister that went out yesterday evening. Uh can you can you just clarify again uh how that that decision came about? Did you say it was a recommendation from officials within the fire firearms?

Yeah. So um as the the consultation has progressed um the branch has be has been monitoring the the responses from um stakeholders also the views of this committee um and also the wider sentiment around it. Um we we have been looking at the responses and and based on that and based after reflecting on the the process we have carried out and the the documents and evidence we have presented to um to the public for their views. On that basis we we presented a submission to the minister with a range of options and and that obviously at the end then was upon the minister then to to take her decision based on the information we provided to her.

>> And did you say the officials made a recommendation or just made a range of?

>> We had we had presented um a series of recommendations um with possibly two as viable recommendations. The first being a pause in the consultation and officials then work to amend the documents provide more information to [clears throat] uh as part of the consultation process and extend the consultation for a further period to allow those responses to come in. And the other fable recommendation was that we uh take the decision to terminate the the consultation and with a view to engaging constructively with with the shooting community with stakeholders to better understand our views to so that we can inform our proposals and present clear data possibly going forward. But um but yeah, those those were the two recommendations essentially.

>> Right. And the second one is the decision the minister took then.

>> Yes.

>> Yeah.

>> Okay. Thank you.

>> Kira.

>> Um that's just nicely because that would be my first kind of area Christopher I'd like to focus in on is the consultation itself and I'm conscious you're only in in April but what actually went wrong.

Um I I I can speak to my view is that we we believe that the this is a priority for the department. It's also a priority for the PSNI with um Chief Superintendent Roberts has clearly stated the pressures that the the team is facing and with the mandate approaching we we felt that we wanted to consult with the intention if if appropriate and amendable we could bring forward legislation within this mandate to address the funding concerns as soon as possible. Um we upon again as of with the risk of repeating myself upon reflecting on the comments concerned um we took a step back and we looked at the concerns that I raised and acknowledged that there were areas that we could have done differently.

>> Did you highlight them areas because I think it's useful that everyone that did you can highlight them. we know what they are so we know what not to expect next time around because it's about building confidence now and I'm a strong advocate of pre- early engagement that helps design your consultation process that's giving you because that's my background so.

>> I think that's one of the things we identified was it was our intention to launch a consultation to seek fuse and and we welcomed any engagement throughout that process in hindsight um maybe it was it was it would have been a better route having that engagement early and then um you might being able to listen to the stakeholders, set out the issues, set out what essentially the government department can and can't do and but also to provide a detailed evidence for the the proposals that we have come up with. We identified that that was an issue with regards to the consultation as it's been previously to with regard to the impact assessments as well. Possibly we we could have made could we have made those clear.

>> Can you drill down? Why did why did all that not happen? Because the departments are around a long time. their consultant. Why did none of that happen? Now, I know maybe Christopher because you're quite new in and you're you've come in at the tail [snorts] end, but I just Is it because it was rushed? Is it because it was just focused on increased fees for full cost recovery? Why did none of that happen? Because we would not be here in this place, pull in a consultation two two or three days before it closes.

>> I understand the concerns of the committee with regards to that. As you pointed out, I I've been I've worked with the team. I want to also put on record that the team put tremendous work amount of work into this over the the last few years they've worked with the PSNI. Um, there's been a lot of evidence gathered um whether why that wasn't presented. Again, I I think we can hold our hands up and be accountable and say that at times we we could have done it better. We we I'm not going to speak to what happened before my time within the branch. Um, but I I do believe that I've noticed that the the work ethic within the team, the the passion as well to try and deliver what is best for respondents. But again, we have to understand our duties as officials and with regards to budgeting to the pressures. But again, I don't I think that it possibly could be that we we just on this occasion could could have worked and done things differently which wouldn't have led us to this situation that we now face. I understand that this I I I also want to just given context in that this was um this on the basis I'm keenly aware that there the department's previous consultation in 2016 is freshening the memories of of of some of the members but with some of the members but um I was very conscious coming into the branch that I didn't want to go down that process again um I didn't want to have that issue so I'm very conscious that this is a chance for the branch Now that the decision has been made, we we learn from this. We also then take a step back, start the allegation process with with our stakeholders to better inform and hopefully be more transparent and and also avoid a repeat of the issues not only from 2016, but the issues that have led us to to come to before you today essentially.

>> Yeah. Because I think it's quite clear you need to have a clear reasoning as to why you're increasing the fees. So the general public, a lay person like me who knows nothing about rifles or licensing can clearly understand the reasoning and likewise the banded. Can you throw light on the bands and >> where where what was the issues with that?

>> Yeah. So um the proposals sought to add additional calibers of rifles to schedule one a 2004 order. Um the bandit system permits the number of firearms that may be exchanged in a oneoff oneonone transaction by a registered firearms dealer. Um the system was introduced in 2016. Um the PSNI have advised that there's approximately this figure I'm not sure but we have a figure here 400 per month possibly. Um however the the uh sorry the the proposed additions to the calibers and rifles per minute by a bandit system reflected desire within the shoot shooting community to have possibly more modern popular rifles included in in the transactions that they can carry out with a dealer. Um the bandit system was originally intended for firearms for purposes of pest control and hence why the the quarry bans, but the system was not intended to facilitate one oneonone transactions for target shooting. Um the department again considers the concerns that have been raised for example that this adds unnecessary complexity and administrative burden. And we again based on those concerns and the feedback we've received we're happy to engage with with stakeholders to address those and see what again how how we can work this out to to make it clear um what form that might take.

>> Okay. Just I just then secondly want to move on the whole forecast full cost recovery stuff. So just some other things. See before you go into full cost recovery, can I just say having been part of that and have the scars still with regards to 2016 along with Pat say.

>> We're practically the the authors of the bandit system.

And at that point whilst there was all the scars and all the bad faith at the start, we actually got to a really good position whereby there was great engagement by this committee, by the officials and by the firearms fraternity to really produce something really really good that has now led to efficiencies in the system. Now somewhere along the line that has failed with regards to I expect the capacity of the PSNI one way or the other, whoever's fault that is, money and everything else goes with it. But we were at a really really good place, we were a really really good place and then Basque wrote to this committee in 2020 January 2020 asking about variations around the bandit system and it took the PSA 5 years, five years to respond. So that's just an example of where we had got to a really good place and then within months it broke down.

>> Chair, I I understand that and again when we presented the consultation to the committee, I I noted the concerns of yourself and some of the members. Um, I'm very conscious that we don't repeat that again. I'm I I'm keen to build relationships not only with this committee but also with the the stakeholders as we move forward so we don't have a repeat of the issues and and that scarred issue that you experienced.

>> Sure. I apologize for Bing in there.

>> Just cla you had mentioned 2016 is the last time the fees were increased. 2018 you'd mentioned that staff the inquiry staff that were not included are now included. Could you give clarity on that and how many staff and is that part of the 63 staff that are now in place that's caused the team for full recovery or prior to 2016 many was in the team so many was in the team prior in 2016 and post 2018 how many staff's in the team the staffing levels.

>> What I what I would prefer to do if I may provide that in a written format because if I gave you the numbers off the top of my head they would be wrong, but the the the overall premise of this is that we have now moved all of the firearms and explosives work into one team. And it's important when I say explosives that this is not explosives blasting. This is the manufacturer of ammunition. So people have have thought we've added that explosives blasting as a plant. It's not carried into it as well. Um, we'll provide the answer in writing. But now we have one dedicated team who look after everything that is required under the firearms licensing and explosives legislation.

>> That would be useful. So what was 2016? Cuz I was getting a bit confused at all of a sudden this influx of 30 staff being included into the team and now that's the difference of the 1.5.

>> The the the key changes is wages. It's pay costs for individuals. But we will clarify that and we'll provide that in.

>> Oh that's good to know. And then regarding he says the biggest delays is third party.

>> So what's the issue there and what have you been doing with your third party to try and improve it? I'm assuming it's department of health. Medical records.

So.

>> The the third party checks are the ones which sit outside of something that we would do. Some of them will be internal. So we would have to go to um some of the teams within crime branch and others to go and to to seek information which takes time. Some of them are external partners in relation to intelligence information. But one of the things that we do differently here from from the rest of the UK is we're responsible for seeking and paying for the medical certificate for someone who wishes to have a a firearm. And we have no control over the manner, the timeliness of those of those responses. Um, one of the things that was recommended in an earlier review which we were not able to progress is uh that we would stop the clock in terms of how long somebody's been waiting when we write out for a medical certificate. Um, but as it stands differently from the rest of the UK, we ask for it and we pay for it.

>> And what's the cost and what have you been doing along with as the department of health for this to improve this process given that it seems to be a huge barrier and has been for years.

The cost varies between as as it does with any medical certificate letter. Different surgeries will charge different prices. Uh again, we'll come back to you in writing around what the standard fee is, but I know from personal experience depending what you want in the letter for you get a different charge. But in terms of working with the department of health, we have engaged with them, they are aware of it, but they have a significant number of other priorities as well that the department of health are working on. So accelerating provision of medical letters from GP surgeries is a matter that you need to take up with them. But I understand why we receive the delays that we do with some of the issues that we see going on in the health service.

>> The fees always been there post 2016.

>> Um charges.

>> It's always been. Yeah. That would be useful to know what correspondencies have had and see it and what correspondence back the department to health is because it is about working collaboratively with departments to improve services and that cross party across um departmental working which is something that we're strong advocates of here and we are doing a joint meeting with the department of health on other stuff but I'd like to see what correspondence you have had, what work ongoing work you have had do you remedy this delay because that's what's causing the whole delay because if you're reducing the delay you're building confidence in a system that people will pay for good quality service, but if they're not getting a good quality service and the service is is going up by 150%. Like I'm I'm being simple. The dog in the street would have to bark very loud, you know. So, you know, I welcome you coming today. Um, I welcome that it has been paused. I welcome that are reviewing the whole process. I welcome that there's going to be proper early engagement with all stakeholders in this whereby everybody's working collectively together. And I welcome that it's going to be way more transparent and open and clear and everyone can have a better understanding. And likewise the consultation process I went on it myself to be honest, the actual survey. [gasps] Were you capturing who was actually falling in these surveys?

>> Were you capturing actually who was falling in these surveys? because I didn't have to put my name address or nothing in it and it was optional if I wanted to put an email address in or maybe I done it wrong but.

>> Obviously we considered.

>> No, I only went in to actually see what they were asking.

>> We have to consider data protection and obtaining information that we maybe don't feel is necessary in order to uh inform the proposal. So um, while we did ask were they a firearm certificate holder or registered firearms dealer, we didn't feel that we needed their personal information and that obviously and that lets people off give their view without fear of maybe having their identity um also known.

>> I think that's something you should kind of review from a consent to give their information, you know.

>> We also asked if people wanted to keep informed and it was optional if anybody wanted to keep informed and they could provide their personal information, but yes, that I'm just trying to explain that.

>> We felt like we were taking information that we maybe doesn't didn't necessarily need and that we were mindful of data protection as well. I I'll just add to that that again as we move forward and and work to introduce a future consultation [cough and clears throat] the documents, the the method of the consultation and and the questions that have asked, we will consider those and see if there's any way this this can be done differently. Just finally, just one I think it would be pertinent as well because you're talking about the processes at the minute and if you want to accelerate the processes you're said you need even more so I would like a clear picture of if you had the ideal service and an efficient service and you're meeting targets, what what would it look like in the future, you know, as you mentioned additional staff, but we need to see the pre what you proposing and the future plan as well.

I If I may by measure of assurance to you, the deep dive into that we've been asked to perform for the policing board, that is one of the questions, what what would be the ideal service, what would it look like uh so we we will capture that and and that report will will go to the board. I think one of the messages I want to really leave the committee and anybody who's watching this online is we are providing a good quality service, we are keeping people safe in relation into that service. I am not content and I've apologized for the timeliness of that service. And one of the key takeaways that I would like people to to have from this is we are simply seeking a cost neutral position at this time so that we don't have to draw funding from other areas of policing to pay for firearms licensing, which is the position where we found ourselves in.

Chair, I I didn't speak earlier and and I waited for uh there is no excuse for it taking five years to get a response from the police service. It's unacceptable and I apologize to you and to the committee who who bear the the scar tissue from that. The team that I have now are very capably led and through me and I know I can assure you through them that you will not wait five years for a response from us. And I I I use the word accountable in my opening statement because I am accountable and I'm happy to be held accountable for it as well. So that's one of the reasons why I thank you for the opportunity to come today.

>> Just just on that because you you do say that the fee increase the rale for the fee increase is all about the full cost recovery of what the system is. Now in 2018 the audit office report which has been presented by the department as a motivating factor for the fee increases states that the fe had set a target of 56 days for progressing applications. What I'm hearing today is you just need this fee increase to stand still on the system that you have now.

>> That is it. We need the fee and keys to be in a cost neutral position and that's that's why and HMIC have said in terms of how we operating, they have found that we perform in line with comparable police services elsewhere in the UK, demonstrate a high degree of transparency and and any remaining delays appear to be driven primarily by case complexity and third party dependencies rather than efficiency in internal processing. Now, if I had more staff to deliver this function, then that would necessarily speed up the processes because the delays are I only have a certain number of seniors. I only have a certain number of individuals to to to assess the um when they come in. The cost neutral position is about the impact on the police service as a whole and the impact on our communities as a whole. the wider piece around speeding up the system. We'll take any recommendations that we receive that say we could do it faster. But the reality is in the operating environment in which we find ourselves with a 57 million pound deficit and at least a thousand and a half officers and several hundred staff less than we would perceive that you would require to police the environment of Northern Ireland. We simply don't have the staff to add to that.

Why is it then that FEB has set a target of 56 days if that is that not a pipe dream?

>> It's it's not a pipe dream. But where we will go now in consultation with HMIC FRS in particular when they publish their review is we will look to set a realistic target that we can work towards. Now I know having spoke to the head of my department that their vision is that we can significantly reduce the backlog in delays, but that is going to change take significant process change and more staff. Now, one of the things that has been an issue for us is that we have seen a high degree of staff turnover and we have seen a number of impacts around introducing the online system um and a number of other process changes that we have undertaken within the service which have impacted on the cues because when I talk about those 63 people now, they answered 9,000 queries from people. I would say as a chief superintendent, the majority of [snorts] paperwork that comes to me to approve in terms of responses or to write responses for relates to individuals who have concerns about the firearm system. So that that that team are not just doing firearms licensing, they're doing a whole range of other functions at the same time to ensure that we maintain public safety. And when cases come in that that require urgent action, that means that the work for that individual for that day will cease. So there is not one group of 63 people who are just doing firearms licensing and then a whole other group who are doing all sorts of other things. That group is doing everything in relation to firearms licensing. frequently engaging with partners at this table and and with the the firearms community uh to uh provide updates to consult on legislation to consult on regulations to answer queries. So we are doing our level best to reduce the impact of those functions and bringing the FEOS into firearms licensing has provided significant benefits for us. Um, but the the timeline that we have in the minute whilst I wouldn't say it's a pipe dream, I would say it was aspirational at the time it was published, it is something that we will look to review under the deep and and we could have said it's very diff difficult for a team who work as hard as my team do and they genuinely do to be reviewed five times in seven years and then be told you're inefficient and we would like to do a further deep dive in relation into the work that you do. But nobody turned their noses up. They welcomed it because they more than anybody else. If we can make this process faster, recognizing that timeliness, public safety issue, we will gladly take it and we will gladly do it.

>> Okay. Are you finished?

>> No, I was just going to come in. There was a workforce issue and the staffing issue um and they've taken on all these additional responsibilities, but are they solely prescribed in the legislation? the responsibilities that they're doing that's prescribed for the fee, are they doing additionality as well? And then with regards workforce because we've worked across all the departments workforce issues regarding sick leave and stuff like that, is that something within that department is challenging regarding the workforce?

>> We we've faced quite a lot of challenges in that department, but since since 2023 uh we have seen significant improvements within that department. Uh we have seen the the team that I work with, I Can't say it enough. They're really good. They're really dedicated to what we do. But as a public service where people get promotion, where people get transfers and take them, it's really important to recognize that those people have really key skills and operate in a really high-risk environment. So this is not something that somebody can come into and in a week I can say off you go. If you're going to manage complex cases, you're looking at a minimum of six months, possibly even a year's training before somebody is able to do that on their own. And when I have a small team of seniors who are training new seniors who come on board, that means that their time is taken up by training them. So the complexity of the risk that they carry is something that impacts on the training times as well. And that goes right from those who do the daily work on the simple reg grants all the way up. And we cannot step back from that because one wrong decision could have a really profound impact on public confidence in policing.

>> Sorry. What's your establishment for senior team that deal with complex cases? What's your number?

>> Um, I will have to come back to you.

>> And then your number then for ordinary applications and variations.

>> I >> if I may chair, I'll come back to you to give the right figures. And one of the reasons is that has changed recently.

>> And I I I have my staff establishment right now at 63. A breakdown of that I'd prefer to give you in writing so that I giving you the.

>> Understand Morris badly. Thank you chair and thanks for your presentation. Bank my questions were really based consultation which is now no longer. But I remember in the early '70s I bought a gun and my license was verified in the local police barracks within a fortnight. Uh after a while I sold it and bought a new one. That was done at the dealer. And I think 10 years later when I had no longer a safe place.

Just to keep it, I give it up and I give up the firearm because the dog died as well and just no didn't need it anymore. But it was all done locally.

So, what were your numbers, including officers at the local stations who could verify firearms in 2016 compared to what they are now when they're centralized? Now, your system is inefficient. Your officers are very efficient, but centralization of anything creates inefficiency and backlog. It doesn't matter what it is. You centralize it, you're automatically going to destroy it. So, while you have an efficient team, your methodology is inefficient.

So, how can you not spread the workload out across the rest of the police stations in Northern Ireland? Why have you had to centralize it? And the other question I wanted to ask was on finance. Your premise of how much money you need at the minute to service the certificates and the firearms is based on high-earning officers. It's based on, you said yourself, and overtime, and it's based on centralization. In other words, you have more work coming in for less numbers.

So, if you, when you're giving back numbers, if I could have the numbers of officers who were fit to verify firearms certificates or licenses in 2016 compared to the number now, and also the cost of overtime, the cost of the backlog, has it been factored into what you need now to clear all this up? Because I think the mathematics is skewed because of centralization. So, respectfully, I would disagree with you about centralization.

"I'm just in my opinion on experience."

"Yeah. And and..."

"...not of the police, a whole range of..."

"...centralized..."

"...but if I may, this is placing firearms into the community is probably one of the highest risk functions that we undertake. And the benefit around centralization is not just cost efficiency around process time, but it brings single consolidated decision-making around a clear structure within the national decision model in relation to the allocation of firearms. So, whilst I agree with you, centralization is not always the solution. By having a single team who make decisions, which, for example, they would meet once a week, the team to discuss context, complex cases, to make sure that our decision-making is consistent. If I place that decision-making into the hands of individual officers who happen to be working at the front desk of a station, then you would get a significant variation in the decisions and the risk tolerance that this group would have. So, we know from the joint emergency services interoperability principles that risk-based decision-making is best done by people who clearly understand the risk that they're dealing with."

[clears throat] "And who work together. So, they all have shared situational awareness, and that's delivered through a central group who work and meet regularly together to provide consistent decisions in relation to that high-risk work. Now, there are no officers in the FEB team. There are no police officers. It is entirely staffed. I lead it, but it is entirely staffed. Both those that work in the district are staffed by police staff. Um, there are, we have no police officers who are in there. So, as I say, respectfully, I would disagree with your view that in this case that centralization has led to inefficiency. And as HMIC have said quite clearly in their response to us, they have not seen inefficiencies in our processes. And the point around the firearm being obtained in 1970, the operating environment in which we operate now is significantly different from then, not just in relation to the obvious issues around terrorism and things like that that have taken place since then, but the firearms community would tell you as a sport and a hobby, shooting, target shooting has developed beyond all measure in relation to a pursuit that people want to undertake in terms of leisure. And somebody at the front desk in an inquiry office, I struggle to understand some of the use of firearms for target shooting. It's a really specialized subject now, in a way that requiring a firearm for vermin control or something like that simply isn't and wasn't."

"Through you, Chair, somebody as you described sitting at the front desk of a police station knows their community, knows the people within their community. It's not somebody sitting in Belfast who doesn't know Adam from Paul that makes a decision based on what's written down. So, you've got the local knowledge which you don't have now. And by your own admission, you're now way behind time in your firearms. It's now not cost-efficient since you centralized it."

"The, the, again, I would have to disagree with you. There are no officers, or there are very few officers consistently sitting behind desks in front office inquiry offices. And the investigations that we're required to undertake, particularly in complex cases, are really, really significant and often require reviews of not just where somebody lives, but who they live with, the circumstances pertaining with them, how the firearm is stored. We have moved to a system that, whilst it is not perfect, is much more secure and much safer for the community than it was all those years ago. And the HMIC have said to us today, they are not finding inefficiencies in the processes that we have. We have said if there was a, when the review completes, if the deep dive says you're doing this all wrong, do it this way now, we would of course look at it. But we have had five reviews in seven years, and none of those reviews, I said earlier, we have implemented almost all of the recommendations. And I kept it out, the one that we haven't, because the one that we haven't is as far back as 2018. The reviews were telling us to move to a cost-neutral position, and we have not achieved that."

"Yeah, to you, Chair, just one other point. When you are being compared with other police forces across the UK, most of those police forces are operating within a city that has a population far greater than the whole of Northern Ireland. So, you're operating in a whole rural raft centrally in Belfast or wherever. And you can't compare that. And HMIC said in their documentation that one of the things they found was that we deal with an extraordinary number of firearms, equivalent to a metropolitan environment, which few other forces operate in that environment. So, HMIC noted that and they said, you are doing the work in a community that is both rural and urban, that is reflective of the largest metropolitan area."

"Yes. There, I make my point. You're dealing with the whole of Northern Ireland, which is a vast area, in a metropolitan area. You people know each other. You don't know. You don't need to know who I live with. You don't even know if I live with anybody. You know nothing about me. So, how can you say whether I'm a fit person to hold a firearm or not?"

"Because we have systems and processes in place in which we review that if you apply for a firearm, and every step that we take is based on public safety. And I would say that none of us around this table want to see a firearm going into a community to a person who is not fit and proper or doesn't have good reason to do so, because the consequences of that happening, and I can assure you that when incidents happen, every single one of my team feels it. Did we push that certificate through? Are we responsible for that? The consequences of that are beyond measure in terms of the risk to public safety. So, I have apologized, and I gladly apologize again for the delays that people are experiencing, but I must put public safety first, because the impact of a firearm being misused in the community is beyond appalling."

"Yeah, I would agree with you about public safety, but I do not agree. The inefficiency of the system is not reflective of the efficiency of your officers. And that's my final word. Morris, can I just add, you talk about cost, but you're also adding into that seizures, appeals prep, and Article 13s, which is changing the goalposts in many ways, is it not?"

"So, I think one of the things that we've undertaken around the consultation is to listen to what people have to say, to be absolutely clear on what is and isn't being included. But the figures that we have arrived at, or the figures that we think reflect what a cost-neutral firearms licensing process would be, is primarily around the cost-neutral firearms licensing process. But we talked earlier of £24 for a license in England and Wales. We have no figure in our mind of what we would like that price to be. It needs to be cost-neutral. But if you have £24 and then you pay for your medical certificate on it, you're not that far off £240. Whereas in Northern Ireland, we continue to pay for the medical certificates as part of the process. So, the consultation was for a reason. We are happy to work with yourselves, the Department of Justice, and our partners who are both here and watching online."

"To..."

"Pat, you indicated you want to come in for a quick one. I just have one more question. What do you do now with those responses that you've had? Where do they go?"

"Yeah. Um, sure. Uh, I think with regards to responses, as I previously said, we have received, I think, close to around a thousand responses. And again, I want to place on record my thanks to those people that have taken time to respond. And I understand that it's frustrating that this decision has been taken. Um, we will use those responses again to listen to the concerns, to analyze those for themes that have been raised, and use those again as we move forward with that engagement to understand what we could do differently. And finally, I hope and encourage those individuals and organizations to respond to a future consultation, whilst acknowledging that this is an idea."

"Okay. Paty, you want to come in for a quick..."

"Very quickly. Um, I've seen the pre-populated system and how it works for dealers, and they showed me that, and it seems to look well. But someone mentioned to me, I don't know whether it's anecdotal or whether at the other end, do you have, do you still utilize paper-based stuff at the other end? In other words, I'm looking at a pre-populated system that looked great, but is the same pre-populated system used at the other end to process the firearm certificate?"

"We see the, we see the same. And one of the benefits, as I said earlier, of that system is that when we're doing variations and things, it fills in all the personal details and everything else for somebody there. Whereas there is, as I said, for example, there is an issue and we need to move to a complex case, then we start to fill in forms. Some of them are done manually, some of them are done online, depends on the nature of the form. But the overall, the overwhelming amount of work is done on an electronic system. So, it's not like we print something and then start filling it in again."

"All right. Okay. Now, just..."

"Someone had mentioned that to me, but..."

"Thanks very much. And just to make the point, the £204 is for the initial grant. That's someone starting new."

"That's..."

"It's £135 for renewal."

"Renewal."

"That's a big difference from what's been suggested here."

"I, I was looking at the fees earlier. There's a bewildering variety of different fees for different. I mean, that is completely structured differently."

"£200 for a shotgun, for example."

"Yes. And the regrant..."

"Lesser. But thank you for your time. Thank you."

"Okay, folks. Thanks very much for your attendance here today. That's everyone. I wanted to ask the question that's been asked. Thank you very much for your answers. And I wish you every success in the way forward with regards to your next steps and with the consultation with the community out there and indeed the firearms fraternity and indeed this Justice Committee. So, thank you very much."

"Thank you. Thank you very much."

"Okay, members, moving on to agenda item number five, firearms licensing fees, consultation, proposed amendments to firearms licensing fees and abandoned assisting the British Association for Shooting and Conservation oral evidence. Can I refer members to pages 122 to 129 of the meeting pack for the relevant papers? Therefore, members of the committee will now hear from BASC on the department's consultation. The witnesses providing evidence today are Tommy Mann, director of BASC Northern Ireland, Dr. Alex Murray, head of law at BASC, and then Gavin Walsh, former Northern Ireland Public Services Alliance NIPSA representative. You're very welcome to the meeting. Thank you very much for your attendance. I'll give you that bit moment to get settled."

"Very warm."

"It's very warm. It is. Gets very heated in this room for all sorts of reasons."

"Uh, well, Tommy, I suspect you have an opening statement that you want to present to us."

"Um..."

[snorts] "I could just take a minute or two just to um sort my paperwork out, please."

"Yep. Good afternoon, Chair and committee members. Um, my name is Tommy Mann. I am the director of the British Association for Shooting and Conservation, otherwise known as BASC. My colleagues today, as the Chair said, are Dr. Alec Murray to my left, head of law at BASC, and Gavin Walsh, former NIPSA representative for PSNI. Just for the benefit of those watching online or listening online, um, we've already provided a detailed written brief to the committee. Um, and now we're here to give the oral brief. BASC is the largest shooting organization in the UK, and we firmly believe that any changes to legislation or policy should be evidence-based. We are delighted to be here. Um, thank you for the opportunity to present to the committee on department proposals to increase firearms licensing fees and amend a banded system. It is important for us to state from the outset that we are very keen to work with the department, the PSNI, and the Justice Committee to find a solution that, as far as possible, works for everyone. We are um, we were pleased to see that the department's consultation focused solely on fees and the banded system, both of which can be amended by order, obviously, without the need for primary legislative change. Uh, and when the consultation is brought forward, the new consultation, we think it would be beneficial if it was again focused on those two areas. I think otherwise, we risk getting into a protracted period of engagement, as some of the committee members will know from the last consultation around 2012. Um, it's fair to say the situation has changed somewhat since 5:00 yesterday, when the minister withdrew the consultation. That is a welcome move. Uh, and in light of that last-minute development, we have tailored our presentation accordingly. So, we have a lot left to say. You'll be glad to hear at this point in time. Um, I think what we need initially is a little bit of clarity, perhaps. And, um, I didn't, I certainly didn't think we got it from the department in relation to the Q in response to the questions that were being asked in your committee packs. The briefing packs, we gave you a letter that I had signed off, was dated the 20th of April, to the department, and it really set out our concerns in pretty soft terms about specific, specific elements of the consultation that we felt could potentially be unlawful. And it really asked the department to rectify those areas and do it quickly, if possible, and get the consultation back out. We were happy to engage and contribute to the process along with our partner organizations. Um, that was on the 20th of April. We didn't get a response, despite several reminders, three or four. And we didn't get a response. And then on Tuesday of this week, Tuesday morning, we issued a pre-action protocol letter to start the legal process. And then, as you know, the consultation was withdrawn yesterday. I'm not sure if you're aware of that, but if you're not, you are now. And that's where we are with it. Um, in terms of our concerns in respect of the consultation, I will get into that in a second or two, but I'd just like to get back on to my brief. Um, we're talking now about our concerns and the POP letter, and the department's failure to respond to us, but it throws our brief out of sync, so to speak, because that wasn't forthcoming from the department. In terms of the economic benefit of shooting, there are 54,000 certificate holders here, roughly. Um, and the 2024 value of shooting report highlights a positive role that shooting plays in the management of around 1 million hectares. Some £10 million is spent by people that shoot on habitat improvement and wildlife management here each year. The voluntary conservation work carried out here requires the equivalent of 500 full-time jobs to replace those efforts. Wider afield, recreational shooting is worth around £60 million per annum to our economy, and the sector sustains roughly 1,200 full-time jobs. I'll just take a minute and set a little bit of context before we go back to our concerns around the consultation. Um, I would like to mention the Northern Ireland Firearms Representative Group, which was formed back in 2021 in response to deep-rooted concerns around PSNI firearms licensing. It was really on the back of the firearms magazine debacle. The NFRG, as it's called, consists of nine organizations, including all the main shooting and countryside organizations: BASC, Country Sports Ireland, the Scottish Association for Country Sports, the Ulster Rifle Association, the Ulster Clay Pigeon Shooting Association, the Northern Ireland Small Bore Shooting Association, the Northern Ireland Practical Shooting Confederation, the Northern Ireland Firearms Dealers Association, and the Northern Ireland branch of the British Deer Society. The group is currently chaired by BASC, with the secretariat provided by Country Sports Ireland. The NFRG have a previously agreed position on fees increase, which is: we are strongly opposed to any increase in fees without a full, independent, transparent review of the necessary processes within firearms licensing. The review should involve the firearms group, and our participation in that regard has previously been agreed by PSNI, and that is a matter of record. I understand, Chair, as well, that you may have a letter from the Ulster Farmers Union saying they support our position as well. Is that correct?"

"Yeah. Yeah."

"Thank you. So, if I might just backtrack to get on to our concerns around the consultation itself. Um, so we had concerns around a predetermined outcome. There were four options, but there was not a lot of detail, if any, very little provided on option one, two, and three. The department were firmly fixed. We, as far as we're concerned, our view was that they were firmly fixed on option four, excuse me, and to our mind, that was a predetermined outcome. Everything hinged on the policy objective of full cost recovery in line with option four. There's been a lot of talk about the £2 million shortfall. Um, in broad terms, the system brings in £1.3, it costs £3.3, and that means there's a £2 million shortfall. There's no detail on that. Nothing. Um, the consultation referred to a data collection exercise that was carried out by PSNI in June last year, 2025. Uh, but yet, while the PSNI had done that, and my understanding that was passed to the DOJ, there was no detail of the data collection exercise in the consultation. That was another concern. Uh, another one we picked up was enforcement costs. Uh, Chair, you referred earlier on, while the DOJ were giving their presentation, you referred quite rightly to seizures, firearm seizures, preparation of appeals to the DOJ, and Article 13s, where a firearm certificate holder, excuse me, does not apply on time and their firearms are seized. That's what we call enforcement cost. It happens after the firearm certificate has been issued. You will obviously be aware that the department uses two documents, Managing Public Money and the Audit Office Report, as its main drivers for full cost recovery. If the department was across its brief on Managing Public Money, it would know that Managing Public Money does not allow you to charge for enforcement costs. So, to be clear, the fees are set out in Schedule Six, and that's what we pay for the application process. So, let's say it's between myself and Alex. Alex pays me as the branch for that application."

[laughter] "process. Anything that's carried out at the back of that application process after the certificate has been issued is enforcement cost. Uh, and it was very clear from the consultation that they had included enforcement costs, which then raises the question: Is have enforcement costs been included in the £2 million? Which then raises a question around the Audit Office Report and the £300,000 shortfall. Was enforcement costs included in the £300 shortfall in 2018? Um, there were two other issues, concerns we had in relation to the consultation, and one of those was in relation to the way the questions were asked. Keep me right on. I think it was question seven."

"Question seven. Yeah."

"Um, do you agree with the department's proposal to move to full cost recovery? Yes. Uh, move on. No. Please elaborate. Um, when really, those two response answers should have been the same, if you get what I'm saying."

"Mhm."

"Um, and the final one, as Kira had rightly pointed out, there was the identifiers required. No name required. No email address wasn't mandatory. So, somebody could go and print off one or 2,000 consultation responses, tick all the relevant boxes depending on their agenda, and get them to the department. And we felt that was very much open to exploitation. So, they were the concerns that we raised, both internally through Alex as our legal advisor, and then externally with Darren Mackin and Phoenix Law. Hence..."

[snorts] "the POP letter then on Tuesday, and that brought us to this point. Chair, Alex, do you want to comment any further on that?"

"Um, what, just about the POP letter?"

"Yeah, sure, just generally."

"Yeah. So, um, obviously, the issuing a POP letter is not something that we really wanted to do. It was sort of a last response, really. Um, but we did, as Tommy said, we sent the letter on April the 20th, and that went unanswered. And we really had no choice but to go down the legal route. Um, and that was one of the reasons, presumably, why the consultation has been paused or withdrawn. Um, and perhaps not just in relation to the consultation responses that the department was receiving and reading, as they said they were doing when Mr. George was giving evidence."

"Thanks. Um, for clarity today, we talked about BASC and chairing the Northern Ireland Firearms Representative Group. For clarity today, I think it's important to clarify. I'm here today representing BASC. As BASC alone has paid for the legal work, we've done the groundwork here. And as the committee members will know, I've been working my way around the committee over the past eight months. So, I think I've met the vast majority, if not all of you. So, thank you for your engagement in that regard. Um, on firearms licensing fees, we, as per your written brief, we do not support the department's proposal to move to full cost recovery. Um, the DOJ consultation consisted of seven documents, roughly 100 pages, and between 35 and 40,000 words. But yet, having been through all of that, I still couldn't tell the committee how much it actually costs to process an application for a firearm certificate, or any indeed, any of the other transactions listed in Schedule Six of the Firearms Order, what we call a fees schedule. So, without clarity on the work carried out by FEB staff, it's impossible for us to accurately determine the true cost of the various transactions set out in Schedule Six. By contrast, the last fees review carried out by BCS, Business Consultancy Services, back in 2010, totaled 47 pages of data on the fees aspect alone. 47 pages of data. We are disappointed that the department has cherry-picked the full cost recovery aspect from Managing Public Money, yet has chosen to ignore all of the other aspects of the same document, including, most importantly, the standards that public services must meet, must deliver, which are set out in Box 1.1 of Managing Public Money. Those standards include honesty, impartiality, openness, accountability, accuracy, fairness, integrity, transparency, objectivity, and reliability, carried out in the spirit of, as well as to the letter of the law, in the public interest and to high ethical standards, and achieving value for money. We feel strongly that full cost recovery is not appropriate for a service that does not meet the standards set out in Managing Public Money. Many of you will know that we have concerns, your constituents also have concerns, around the lack of accountability of PSNI Firearms and Explosives Branch, and this has been the case for many, many years. Um, by way of solution, and as a first step in achieving greater accountability, we think the implementation of a service charter, which is permitted under Managing Public Money, would be a step in the right direction. Additionally, we feel strongly that there should be an independent mechanism for holding FEB to account, including, for example, when they fail to meet the agreed processing timescales as set out in the charter. In the wider context of holding FEB to account, the Police Ombudsman for Northern Ireland has no remit to investigate complaints against police staff. Similarly, the Northern Ireland Public Services Ombudsman has no remit to investigate complaints against police staff, despite the fact that that is a requirement of Managing Public Money. Just to be clear on that, so anybody can go to a public body, public service, and complain, and if they're not happy with the way their complaint has been dealt with, they can go to the Northern Ireland Public Services Ombudsman. With FEB, you can't, because he doesn't have a remit. So, they're actually accountable to nobody. FEB, under pressure back in January '22, they did, as a result of pressure from the firearms group, introduce their own internal complaints procedure. This is a public body in 2022 introducing its own complaints procedure, and hasn't had one before that. Really, we don't have any faith in that complaints procedure. It's PSNI marking our own homework. It has no credibility. It has no integrity. But we pushed for it for a reason, because it was the first step, a small first step in achieving greater accountability. In the context of accountability, there's also an issue in relation to how key staff are deployed. So, for example, senior firearms licensing managers, how they are deployed is a very important aspect of FEB's job, day-to-day job. We call them SFLM, Senior Firearms Licensing Manager. They are key decision-makers, and as such, they play a critical role in the day-to-day operation of firearms licensing. Yet, on occasion, they can be redeployed on the whim of the head of branch, can and have been. And when that happens, the backlog starts to grow. At one point in 2022, when asked how many SFLMs they had in the department, the response was nine. And then the obvious follow-up question is, well, how many of those nine are working on files? And the response was two. When asked what the other seven were doing, they were redeployed at the direction of the head of branch doing projects, but we didn't get any detail on that. And my members, BASC members, and the wider shooting community, and the members of our partner organizations are paying for that. Just to have that on record."

"I'll speed you up, Tommy. Can I?"

"Yeah, sure. Sure. Sure. Given the vital role that FEB plays in helping to ensure public safety, we feel strongly that any income derived from firearms licensing fees should, in its entirety, be ring-fenced for the branch. Additionally, we feel that the Chief Constable should ensure that FEB should be staffed to full capacity. The implementation of both measures should hopefully help ensure that FEB performs to the standards set out in Managing Public Money. Box 4.9.1 of Managing Public Money states, 'Each public sector organization should have sufficient staff with the skills and expertise to manage its business efficiently and effectively.' And I would add that this aspect of Managing Public Money also applies to the Department of Justice in the context of administering the appeals process. Just onto the banded system. Our submission in 2020 contained a very limited number of calibers, and that was done intentionally just to make it more palatable and acceptable to PSNI and DOJ. When we brought the banded system forward back in 2012, 2013, both PSNI and DOJ were very much against it, as they didn't see the benefits, but I think that has changed significantly to see the benefits of it now. Adding more calibers to the bands would, if done correctly, significantly reduce the administrative burden on FEB, as it negates the need for an FAC holder to submit an online application via PSNI, which could take many months, and sometimes longer, to process. As things stand currently, banded system transactions cost £15, which is half the price of a variation by PSNI. Adding more calibers to the bands will give FAC holders greater choice and flexibility when it comes to acquiring a new rifle directly from a firearms dealer, and a same-day over-the-counter transaction. In short, it's a win for the certificate holder, it's a win for the firearms dealer, and also a win for PSNI, given the reduced workload. I would add that similar transactions in GB, although they don't have a banded system, but similar transactions in GB and in the South are free of charge. So, I think we absolutely need to revisit the cost of that transaction specifically. Um, we also feel that the banded system should be reviewed and updated every five years, at least every five years. We, in terms of the way forward in the banded system, have drafted a more comprehensive version of the proposal contained in the consultation. We're happy to share that with PSNI and the DOJ and bring it back to the committee if the committee thought that was appropriate. We note from the DOJ paperwork that it was shared, that was shared with the committee, that PSNI have some public safety concerns around the banded system. That wasn't put in the public domain. And that may well be the case. However, if that is the case, then we would appreciate the opportunity for the PSNI to share those concerns and discuss those concerns in order to find a way forward. I'll close on the ministerial directive that Paty referred to earlier on. So, we have firearms dealer trade members, and many of them are having difficulties with the cap on their holdings, and they're restricted by the ministerial directive. It's not a legislative issue. It is, as the name suggests, it's a ministerial restriction, and the holdings for dealers need to be increased. That's our firm line on it. We feel that such a move is long overdue. BASC's position on this is that the cap should be removed completely, and the dealers should be permitted to hold what their individual premises can store securely, bearing in mind that they are regularly inspected by PSNI FEB inspectorate. That position would be in line with the principles of better regulation, which requires departments to operate good enforcement practices and proportionality, to have proportionality and regard for economic growth, which are two of the eight principles of better regulation. That brings us to the end of our presentation. Chair, we are happy to answer any questions that you may have. Uh, thank you for listening. We are also happy to report back to the committee at some point in the future if the committee thinks that's appropriate for us to do so."

"Okay. Thank you very much, Tommy. That was a very thorough presentation there. So, thank you, Tommy."

"Yeah. Um, thank you for coming in today. It's really appreciated. And I think it is welcome and the right move that the consultation was withdrawn. But the main concern I heard from our contributions earlier and presenters earlier was just the point that we're at with relationships between stakeholders such as yourselves and the department and FEB. And kind of the first question I really wanted to ask you is, what did you make of what you heard in the earlier presentations?"

"Well, we heard earlier on."

"Yeah."

"From the department and the police."

"Yeah."

"Uh, the police, not so bad. I felt there was a very distinct lack of openness and transparency from the department. Uh, that said, we initiated, we initiated a legal process on Tuesday. So, I'm sure they're quite sensitive about how they respond to questions here in front of the committee, bearing in mind we're sitting in a public gallery. So, their response, or their performance in front of the committee, comes as no surprise."

"To be honest, it's what we expected, totally."

"Okay. Any specifics you want to draw out?"

"Um, I would say I'll answer it in a slightly different question, if I may. We are a professional organization. We are very much here to work with the police, to work with the Department of Justice, the minister, and to work with this committee to find a way forward for everybody as best we can. I said that at the start of this presentation, and I'll say it again, that is very much the case. We're not here to frustrate anything. But I think we need to be clear when we have genuine concerns in relation to the lawfulness of a consultation, and where we raise those concerns diplomatically and respectfully in a soft letter to the department, and the department fails to respond despite several reminders, then BASC is left with no choice but to act robustly and decisively and in the best interest of its members."

"Yeah. No, no, I understand that. And it is disappointing that it got to that stage. Um, I'm really hopeful that from now on, we can sort of see a reset and we can see engagement, because it does sound like you're keen to engage and to find workable solutions. And I think that's something that's really positive. And I think I said earlier, and I know we met before, that I don't think anybody who pays for a service expects it never to increase ever. But you and your members would be keen to gauge on that and want to see the evidence base for fees increases as well."

"Yeah, absolutely. The evidence base is an important thing for us. That's across all departments in government. Um, we're very firmly of the view that if there's an intent here to change policy or legislation, it should be based on sound evidence. That's sound evidence that would withstand robust scrutiny."

"Um, and clearly, the department's consultation didn't. Um, I would just like to comment in terms of robust scrutiny. Um, we, thank you to Paty McLo. We were heavily engaged in the Northern Ireland Audit Office report back in 2018. We gave a very significant amount of evidence to the Audit Office, and a lot of that, it was BASC and others, and a lot of that evidence that was given to the Audit Office didn't make the final version of the report, which was very disappointing to say the least. I raised some of those issues with Karen Donnelly, who was the auditor controller at that point in time, and we had a lengthy engagement process, but I never really got any satisfactory answers. I think to sum it all up, it was we raised those issues with a deputy chief constable at the time, but there were certainly issues that were in the public interest. So, for example, the purchase of laptops by PSNI back then, where they purchased laptops, gave them out to firearms dealers, gave them out to clubs to help with the implementation of the online system. We don't know who paid for that or where the laptops went to. Um, firearms inquiry officers were issued with electronic tablets that were pretty much useless. Didn't connect to PSNI systems, didn't connect to the internet. And the inquiry officers gave off about it at the time, and they were told, 'Just hang on to them, turn them on occasionally to just show some usage.' Um, another one with the Audit Office was that FEB staff were told, instructed not to talk to auditors during the review. That's just the tip of the iceberg. The examples of things that were given to the Audit Office that didn't make the report, but yet the department hanged their hat on the Audit Office report and a recommendation to move to a full cost recovery over the long term. Um, it, the department also missed what you picked up on, Chair, the 56 days. Just to go into that in a little bit more detail. The department said 56 days, but historic data shows that they can do it much, much quicker. So, 56 days isn't really a push for them."

"How much quicker could they do it?"

"It didn't, it didn't give a timeline. It just said it could be done much quicker. Historic data said it could be done much quicker."

"That's the quote in the..."

"Thereabouts. I'm not looking at it, but that's just off the top of my head."

"Connie, is that..."

"Yeah, no, that's very comprehensive, and I appreciate your engagement with the committee on this. So, thank you."

"Thank you. Can I ask you, we've already touched on this. I touched it in my questioning to the department, and then you've raised it also in your presentation with regards to enforcement costs being added, or we think being added to the, well, first very much so in the consultation, but then into the full cost recovery issue. The minister last week, I think in Question Time, raised the issue about charging for..."

"Appeals."

"Yes."

"Which would be another layer again then on to enforcement."

"Uh..."

"Was this during Question Time?"

"I think it was through, or it was either through Question Time or a statement, but I think it was Question Time."

"I knew you..."

"Was it you, maybe you'd asked it, or one of your members?"

"Your colleague Keith. Keith was Keith Buchanan on appeals, the protracted delays respective appeals."

"What's your view on actually then adding the cost of appeal into the full cost recovery model, along with all of the other issues that, you know, arise with regards to seizures, with regards to police work preparation, with regards to Article 13s? We're adding another layer on here, which is increasing the cost recovery. Then surely..."

"Our view on this is very simple. When you look at Managing Public Money, it's very clear in that you cannot charge for enforcement activities, and enforcement activities occur after the certificate has been issued. And I think that's a fundamental flaw in the consultation because if they're saying we're going for option four, which is 153% of an increase, it's going to be £250. But as soon as there's a little issue there in their figures, then it's like a house of cards, and it all comes tumbling down. And when we point out, well, actually, you've charged, you've included enforcement costs here, but Managing Public Money, the very document that you're using as a driver for full cost recovery, says that you cannot charge for enforcement costs, then I think that's been a major issue for them. But just to answer your specific question in relation to appeals, to my mind, and Alex being legally qualified to answer this and having looked at what went in our pre-action protocol letter to the department, clearly the view of our solicitor, and Alex can correct me if I'm wrong here, was that the appeals process was an adjudicative function that's carried out by the department, and as such, it's an enforcement function."

"And it cannot be charged for."

"Yeah."

"Would you agree?"

"Yes, definitely."

"Okay. You talked about the consultation not, Kira touched this in her questioning around names and addresses and identification on the applications. Now, you are a pretty slick operation, BASC. You have a lot of members who are motivated to respond to this consultation. The truth could be that you could have actually manipulated that safeguard or that loophole in the consultation, and you could have motivated your members to actually flood the consultation."

"Yeah. Absolutely."

"But yet, you've raised it as an issue that you see and a weakness and a flaw with the consultation."

"Yeah. Yeah. 100%. Um, anybody who looks at our Facebook page will have seen that we have been out with paper response questionnaires. We've been out going around firearms dealers and encouraging members to respond. Uh, the response we've got has been phenomenal. Uh, I have not met one person who is keen on full cost recovery. Everybody's against it. Nobody wants to see any increase in fees. You might get the odd person who says, 'Well, I wouldn't mind paying a bit more, but there's no guarantee that things are going to change.' So, well, say no, I don't want to pay anymore because there's no guarantees. Uh, and during those sessions within a firearms dealer's premises, we come across people who maybe say, 'Yeah, I've done it, but I'll do it again.' And my response would be, 'But what have you done?' Because there's been an e-lobby running, for example, and people were confused as to, well, was that e-lobby a response to the consultation or was it something else altogether because it was a different name? Where if it had been called an electronic response to the consultation, then people would have been a bit more clued in. So, I think that has muddied the waters a bit. Um, but in that regard, where people have said, 'I've done it,' and we've questioned them, and it's very clear that they've done already done a response, we've been very clear, 'No, you can't do it. We have to be whiter than white, beyond reproach. You can't do it. You've done it, and that's it.'"

"Okay. Uh, Paty, you're..."

"Thanks very much, Chair, and thank you, Tommy, and everyone for presenting. Apologies, I had to step out for the start of your presentation, but that was, as they say on the TV, due to circumstances beyond my control. But thank you for that. Um, if you recall, the last time that we were here going through all this, it was the banded system was introduced, and it was more, under duress, that the department introduced it through their own basic medicine. Um, and they had to introduce it, but the outcome to that was that it was good for, we'll call it, firearms certificate owners, and good for business. That was the outcome to it. And just listening to earlier there about the ministerial directive. Uh, I'm very interested to pick up your point there where it's not the RFD's fault that the system isn't working right. And I don't accept, as we clarified there, that not every firearm that's sitting on the shelf in the RFD is one where the person who has applied for it is a complex case. I just don't accept that."

"Yeah, I would agree."

"And it can't be the case. It just simply can't be the case. So, to your mind, on your basis of what you have witnessed, what you see, and the number of cases that come your direction, the department itself and FEB, how do they make themselves more efficient?"

"Uh, good question. Um, I can tell you what hasn't improved efficiency, to start with."

"Okay."

"Um, we've introduced two electronic systems over the years. Um, we removed paper back in 2017, 2018, and we went to an online only system, which was sold on the basis that it was going to capture the right information first time, every time. Um, it hasn't, it hasn't done that. It hasn't improved things. To use the terminology that does around in our sector, all it has done is just removed postmen, but it hasn't really created any efficiency. Then we had the, and Gavin would be more familiar with us and more across it, the implementation of the firearms licensing management system."

Um, [clears throat] that was, that was more recent. That was a few years ago. Uh, and again, we're still not seeing any improvements. Now, certainly the number of complaints from our members has gone down, but to me, that, that's not saying that the service levels have improved. That's saying that members have just become accustomed to, uh, a service that's, that's poor. That's the bottom line.

Yes. And they implement, they implemented, uh, a policy whereby if your application wasn't in, uh, just thinking, if your pol, if your application wasn't in six months, let's say,

um, or was, yeah, if your, if your application wasn't in for at least six months, then you weren't entitled to, to ring up and query where it was. So it was only after the six-month duration you were accepted in terms of phoning in to query where it was. But trying to get anybody on a phone, uh, that just doesn't happen now. There's no telephone contact. Everything, everything is done by, by email.

Um, how do they make it more efficient? I think, um, a couple of things. Ring fencing the staff because, uh, my understanding of a big part of the problem has been a lack of resources, staff. And I think if you were to ring fence the staff and lock the numbers down, you know, there would be, there would be people who will retire. Gavin might want to jump in here and comment on it, but there would be people who retire or go out under a voluntary exit scheme or want to move to another post or they get promoted. Uh, and I think those, they have difficulty filling those posts.

And I think if you had the, the staff numbers locked, where somebody leaves and that post isn't left vacant and it's, it's filled. Um, you think back to what we said about managing public money and the requirement for bodies, public bodies to ensure that their departments are operating efficiently and effectively and that to have appropriate staff numbers, that would certainly be one way where the staff numbers are kept, uh, at a, at a certain level.

Do you, chair, if I could have some slight leeway on this matter as well with an issue Mr. Loan raised, and I'll come to that, but to, to my thoughts and process within PSNI, normally it is 70 to 80% of the costs are staff related. So that'd be the big cost burden. Um, given that the difference in 2 million from 2016 to 2026, the addition of 30 AO2 grade firearms officers is sub 1 million pound bill. So still to be a considerable black hole, uh, in relation to the inflationary matter that's been mentioned in the papers and at the table here earlier. Those staff would love to have seen an inflation rate increase in their pay over the number of years that I was with them, but never got it. So I think to simply say an inflationary increase in licensing fees, it won't help to, it's, it's more than the costs were on the staff side. And Tommy's right here on some of the issues about, I mean, there, there's a matter of issues within the staff, um, their workload, staff pressures that they are, uh, also abstraction from other things, which puts more pressure on staff that are there, going to overtime. The sort of one thing I think was chief, chief superintendent mentioned it there, was the full cost recovery here would seek to get the numbers of staff employed that would then help a branch me ring fencing. You know, have they actually applied for these people? Have they applied to fill the vacancies? Would they then ring fence those staff as they get trained up and are what, six months, I think we said about an SFLM? Would they then ring ring fence those people because they have the experience and the knowledge to do that role? As a former union rep, I would say no, because that's then stopping them from maybe taking a promotion, taking a move closer to home. So there's all those sort of inefficiencies in there. But I think firstly, if there's vacancies, are you expecting the license holder to pay for those whilst they're vacant, as would seem to be the case? I hope that all makes sense now. But I think, you know, there's a number of things are abstractions. People not trained properly. Uh, so many things that lead to inefficiencies. In my time, there was certainly staff and management breakdowns, which was, it took up a considerable amount of my time and was not good for the service that the license holders then got. Hope that covers the point.

Um, I'd just like to elaborate on that. I, I know exactly where Gavin's coming from.

Staff management breakdown. That was around the same time as we went to the audit office. That was a serious breakdown in relationships between senior staff, senior management, and, uh, and staff within the branch. To the point where the department became pretty much dysfunctional. It was a toxic working environment. Uh, and I think we let a go at that, let's say, in the interest of building on relationships and where we are present and trying to move forward collaboratively.

Um, what I would say, just in terms of, uh, PY's question there about, um, uh, efficiencies, a service level agreement, that was a point Kira picked up on about agencies, partner agencies, and, and timelines for response from partner agencies. Managing public money allows for what you call service level agreements between government bodies. It's not just about a service charter for, for the, you know, members of the public, but it also goes backwards as well between government departments. So a service level agree, a agreement could be implemented between, uh, the police and the health service, for example.

Okay. Just one other question, please, chair. And that's back to, um, um, I'm glad to hear you mentioning the bandit system being reviewed every five years. But the bit I don't understand is the public safety concerns. You're not introduced a bandit system where a FICO bar is being put in the bandit system. And, um, from your point of view, you know, you're the experts in this. You're talking about a, [clears throat] firearm that can be shot safely in responsible hands. That's essentially what it is. And many of the calibers that are already on there would be at least of equal power to anything new that would be introduced. So that bit I don't get. And we heard this argument before the last time.

Yeah.

And it, it just, it, to my mind, it doesn't stack up unless somebody's idiotically introducing a bar 50 to, to the, to the bandit system, which not going to happen. But could, [clears throat] it just bring us back to your motivation in this? And like, I know from working with yourselves that you're, you're a professional organization, but the, and this is key for us, that your intention isn't to, it's certainly to challenge them, but to challenge them professionally.

But your, your intention is to have a smooth, good outcome for everybody.

Absolutely 100%. Um, yeah, as I said earlier on, we're, we're here to work with the department, here to work with PSNI and this committee and the minister, um, to try and achieve an outcome that is suitable for everyone involved. It'd be difficult to do, but, but that's our aspiration.

Um, just come back to your question again there about efficiencies. Uh, Gavin touched on staffing levels and, and locking in, ring fencing staff, ring fencing money for the branch. So any income derived from any fee, whatever that fee may be, whether it's increased or not, we're very strongly of the the view that it should be ring fenced for the branch. We want this fixed permanently. We don't want to be coming here to you as elected representatives, and we don't want our members going to you as your constituents complaining about FEB. We want a long-term permanent fix, not a stick and plaster. And the, just in terms of efficiency, to go back to your question, service levels, staffing levels, money, ring fence, all that sort of stuff, the bandit system will, without doubt, as I've already said, bring efficiencies.

Um,

but again, we don't actually know, um, what that exchange looks like in within the department, within the branch. Um, having worked it out and talked through it, talked through it with firearms dealers, we think it probably takes about 10, maybe 15 minutes to change one firearm for another, uh, and update the systems. And, and we're paying, as I say, 1515 for it. And I think that that fee specifically needs to be.

Told me it'd be helpful, maybe for other members, that if you could expand a bit on the introduction of new calibers to the bandit system where you go in and the dealer does literally all the work on that, and the current system whereby if that caliber isn't on the banded system, it has to then go for variation and get back to increasing the workload at FEB.

Yeah, good point. Thank you. So there's four bands. Uh, it's like four types of car, if you want to call it that. Um, four different bands. Uh, four different lanes. Uh, firstly, we have urggon, you have rim fires, that's small caliber rim fires. Uh, then you have the fox calibers, what we call 22 center fires. And then we have what we call the deer calibers. Now, off the top of my head, without looking at the banded system that's set in law currently, there's probably a total of maybe 20 calibers there, thereabouts, spread throughout those four bands. And our, uh, uh, proposal to the Justice Committee back in 2020, as I said earlier, was just, uh, to insert a small number of additional calibers in there. But that was really just to get conversation dialogue going, as I said earlier, to make it more palatable, acceptable to PS and I. But certainly in terms of efficiency, the more calibers that we can put in there across those four bands, the more that will increase the efficiency, uh, for FEB, reduce, certainly will reduce their administrative burden. Um, it makes it more flexible, uh, for certificate holders going into a firearms dealer. And the thing about that is, the dealers are getting the money there in the end. You walk in with one gun, you hand it over, and you, you walk out with your new gun, you pay your money, job done, and the firearms dealer updates FEB within 72 hours and they update their systems. Now, if you were to, as Paty asked me to do it, um, to explain, if, if you have, let's say, a 243 rifle that's in the deer caliber band, and you wanted a 6.5, the 6.5 Creedmoor isn't in the band. It's in the proposal now to go in because it's such a popular caliber.

But, but it's not in law at the minute. So, as things stand at the minute, you would have to apply using the online system and go through FEB to get that on your license. And that could be, how long is a piece of string.

In,

the meantime, that rifle will be sitting on the shelf,

on a firearms dealer's premises.

The firearms deal.

You know, I, I did listen to the chief superintendent earlier on. Uh, I, I don't agree with quite a few of his, his comments, and I'm just going to flick through my paperwork here to see what notes I've taken. But on, on the ministerial directive, um, Paty [snorts] asked about, uh, the, the opportunity for removing it or, or, or increasing holdings under the ministerial directive. This was looked at previously, as the department said, back in 2022, I think it was. And I'm 90, I don't have the paperwork here because I didn't expect to be here, but I think back then Sam Donaldson was a chief superintendent, Jonathan Hart was a head of branch, and I'm 99.9% sure that they said they had no issue with it. It was a DOJ issue, and they had no concerns as long as the firearms were stored safely. And here we have now a scenario where the chief superintendent is saying we have public safety concerns. But he did admit that those firearms are being stored in a strong room in a firearms dealer's premises, which are monitored, which have monitored [clears throat] alarm systems, uh, which have cameras, which have buzzers on the doors to let people in and out, and those premises are regularly inspected. So I don't see what the problem is.

Was it not so much, was it not more that they were out in the community, so in a household, as opposed [clears throat] to the firearms dealer, and he had concerns there? Now, I don't necessarily agree with him in that regard, because as Paty said, at the time of that question, those people have firearms licenses. They are, they are fit to hold licenses.

Yeah. We're talking with, with respect to, we're talking about two different things. We're talking about ministerial directive and firearms dealers' holdings.

And we deviated to, uh, collectors.

Yeah.

Not directed at you, but direct police. We need to stay on track. We're talking about the ministerial directive. It's in bad need of review. Uh, that's our view on it. And as I say, there's issues there under better regulation strategy in terms of proportionality and the, um, economic growth principles, two principles of better regulation.

Okay. Morris, thanks, chair. Thanks for your presentation. Uh, what, what I would like to take out of what the chief console said there was, he said he had a compliment, full compliment of 67, but he didn't tell us how many of those, that compliment is actually working on firearms, or have they been, um, taken out of the service to go and do another job within the PSN? So he didn't say that there. Also, the cost of the backlog has been factored into the, the, the recovery cost and the overtime that he is spending on his staff. So there's, there's a lot of conflated figures and [clears throat] and the overall assumption, and that that causes me concern because I don't think it's a proper figure that they, they produced for the full recovery.

I, I would absolutely agree with that. And I go back to what my comment earlier on about the business consultancy services review, uh, back in 2010, 47 pages of data on the fees alone.

Can I just comment on that one, sir? Uh, I think what he said was, to maintain current practices, he would need 63 staff.

Mhm.

And my inclination, I think that's what I heard earlier, was that they didn't actually have that, but they were seeking full cost recovery in order to have that amount of staff.

That was my pick up.

You made it clear they have 63 current additional staff.

That's what he needed to maintain the current practices. My, my apologies. The other point, chair, through you, is the, the centralization of the whole system, uh, in your local Bobby, and that knows the local community,

and can verify whether somebody's a capable person of holding a firearm quicker than somebody that's working in Belfast looking through papers and having to do all the manual checks on that particular body, uh, before he can issue a firearm certificate, whereas we've done locally, uh, it can be issued or refused pretty quickly.

Yeah, sure.

So, if I could just say, and maybe chief didn't make it clear, but those 30 FOs are out in the districts.

So they would be the go-to person for the individuals and theory should know.

But part of the issue is the turnover of staff. So we're getting new people. Uh, they might, they don't necessarily know the area. So it will take them time to get used to that, to get to know who the people are. Uh, sometimes it's promotion into that role. So they're hitting a promotion. Now, they don't necessarily deal with staffing issues, but they do have to deal with individuals, public, respond back to firearms centrally, who then do a lot of the decision-m. But from what I know, the FO does have quite a bit of sway on what happens out, out in the districts.

I would absolutely agree with that.

Thank you, chair. He didn't make that clear. No, he didn't. Now, unfortunately, but I may be coming from the wrong side of this time, but,

and I just think the system itself is inefficient. And I'm not casting any persons in the officers, but the system itself, to me, doesn't work.

Well, I think one, one point I pick up on that from is, but, and I did attend the audit office at the time they were doing the report, and it did promise about efficiencies. Uh, if you look at the papers, there are the income generation was 1.3 million at that time. The income generation in 2026 is still 1.3 million, but it's costing a lot more. So there isn't, there wouldn't appear to be efficiencies in the system.

Me.

Okay. Brian.

Thank you very much. Thanks for your presentation. To us, in terms of the consequences of delays, what happens if a license expires and someone's obviously still owns the gun and has it at home?

This was something, uh, that was raised with the audit office. So if my license expires today.

You're waiting for them to process it. You know, that's what I mean. You put in the renewal.

Well, if my, we'll deal with an expired license first, and then I'll get to your question. Thanks. Um, so if my license expired today, that's it. It's expired. It's gone. And, uh, I should have put my application in preferably eight weeks in advance. And, uh, I would get a phone call to say they're coming out and they're going to lift my guns because my certificate is no longer valid.

Um, however, if I was to apply, uh, two days ago,

right,

I put my application in two days ago and my certificate expires now, then they deem that to be a valid application. It's in the system, and the, the chief constable then exercises his discretion,

right,

not to come out and seize your firearms because you have an application in the system.

Okay. Well, okay. Well, that's good to hear. So they won't come out and say it just because of their delays in processing applications?

Or,

no. Um, the problems that a delay would cause, for example, where you don't have a valid certificate, then technically you can't go out and purchase ammunition. They have issued advice previously, some time ago, where they say you take your certificate that has expired and you ask your firearm dealer to, uh, put the ammunition on an expired certificate. There are other problems that causes, uh, the expired certificate causes. So, for example, if I wanted to go to Scotland, uh, on a deer stalking trip, I couldn't go. I couldn't travel on a ferry because I don't have a valid certificate.

Mhm.

And in general terms, have you any sense of what percentage or what number of applications get turned down? Or,

I would wouldn't.

You don't, you don't get a question for the police directly.

Yeah. Yeah. Okay. And, and, and what, given that the fees haven't gone up for 10 years, and all what they're saying about compared to fees in England, what is your view on any increase in fees, or how, how would you like it? How would you prefer that it happened, if at all?

That's a very good question. Um, obviously, as a professional organization, we're up for discussion with any department within government. Um, we appreciate that they haven't gone up in 10 years. We were very much central to the, the discussions, uh, prior to the last increase. Um, we're happy to have those discussions and sit around the table and be involved and to lead, uh, and contribute professionally. Um, but I think, as I said at the start of this presentation, changes to policy, changes to legislation should be evidence-based, and, and I stick by that. So we would need to see the evidence to show, you know, how much it costs to process an application for a firearm certificate. We are obliged to pay what is set out in schedule six of the fee schedule, which I provided a copy, uh, in your, in your, uh, packs. Um, that's what we're obliged to pay for. And, you know, if they done their data collection exercise, and it works out that it costs, um, 120 quid, and we dig into those figures and it turn out to be accurate, well then that's what it cost to process a firearm certificate. But I would add, in the BCS review back in 2010, they went in three times and, and went in and, you know, done their, their data collection exercise and produced that 47-page report. But on three occasions, the figures were proven to be incorrect. So that's the sort of level of detail that we would want.

If it was justified.

Yes. Yes. That's the level of detail that we would want, and we would go through that, uh, with a fine tooth comb, obviously.

Mhm. Okay. Thank you.

Okay. Brian, thank you very much. No other member has notified to speak or ask questions. So Tommy, Gavin, and Dr. Murray, thank you very much for your time here today. Uh, and your presence has been very, very informative. Thank you.

Thank you, chair. Thank you very much. Um, chair, could I say one thing, uh, before we go? Thank you very much again for the opportunity to present to the committee. We will engage with the department, uh, the police, um, to the best of our ability, and we would really welcome the opportunity to come back and report to this committee on any progress made, if the committee thought that was appropriate.

Okay. You, thank you for your presentation. I'm sure there'll be a, [clears throat] lot of your members there are very grateful for the work that you've done, particularly around the pre-action protocol, and that may have been some part stimulus for the decision, uh, to withdraw the, uh, the, the consultation document, the post-consultation document.

Thank you.

Okay. Thank you very much for your time.

Thank you very much. Thank you.

Okay. Members, we are going to push on because we are struggling for time here. So agenda item number six, criminal justice sentencing etc. Bill. Written papers. Cling for members that the committee's call for evidence in the criminal justice sentencing bill closed on Friday, 22nd of May. The committee has received a large number of responses, as you can see from your pack, uh, from both stakeholders and individuals. And those received before the meeting pack was issued on Friday are items 6.1 to 6.43, which begin at page 132 of the meeting pack. Some additional responses have also been received since the pack was issued, and these will be provided to members in next week's pack. So can I remind members that the committee is already scheduled to hear from a number of stakeholders on the bill in the coming weeks. As the call for evidence is now closed, the committee will need to determine what other evidence sessions might be required to assist with scrutiny of the bill. It would be helpful if members could give some thought as to who they wish to hear from, and the committee can discuss this further in next week's meeting. If members are agreed with that.

Yeah.

So can I ask members then if they're content to note the, uh, items 6.1 to 6.43, uh, at this point? Okay.

Uh, K, you want to come in? No.

Agenda item number seven is the justice bill, then written papers, 7.1 ministerial amendments. Can I refer members to page 471 to 494 of the meeting pack? Can I advise members that the ministerial amendments to part one of the justice bill relates to biometrics were tabled on the 19th of May. The tabled amendments contain a number of changes that were not in the text of the draft amendments that were provided to the committee, and the committee was not advised of any changes to the amendments. The changes are highlighted in bold in p in paper 7.2, beginning at pages 474 of the meeting pack. Now, that's a very interesting thing. I don't think I've ever come across that. Can I advise members that the committee team has also identified a small number of changes in the other amendments tabled by the minister from the versions previously provided to this committee? These are detailed at pages 472 and 473 of the meeting pack and relate to the rehabilitation of offenders and matters to be included in the criminal record certificates amendments. So can I advise members that the committee has not had an opportunity to consider those changes to the ministerial amendments or take a position on them, and that this will be reflected in my speech on behalf of the committee during the relevant debate, and I am flagging this up, members, so that you can get an eye for yourself with regards to the debate, uh, which starts next week, and it's going to be over a period of days. So just so you're aware, there have been changes that we have not yet seen, which we have not even been able to scrutinize, even though the department was good enough to send us the amendments early on. They have been changed in many bits. So just so you know, 7.3, then is non-filterable list committee. Uh, members remind members that during the evidence session on the access NI filtering scheme, members requested a copy of the terms of reference for the new non-filtering list committee. The department has now provided terms of reference in draft form, and these begin at pages 488 of the meeting pack. So can I ask members if they're content to note the draft terms of reference, or is there any further information required at this stage? Okay, content.

7.4, the bar list and advisory, uh, lists, uh, the departmental response. Can I refer members to page 11 and 29, 229 of the table pack for the correspondence from the department providing a copy of the ministerial amendments to create a police barred and advisory list for Northern Ireland? Members will recall that the committee had asked that if the minister would consider bringing such an amendment after it became clear that the provision would not be made via a legislative consent motion in the Westminster crime and policing bill. So while appreciating the minister's agreement to take this important matter forward, the committee did not have sight of the text amendment before the end of the committee stage, and therefore was unable to scrutinize it in detail. So can I advise members that the me, minister's amendments also make provision that will enable officers to retire or resign while the subject of an allegation and who have been added to the advisory list to be brought back for misconduct proceedings, may also, which may also be concluded in their absence. The committee was advised of this proposed amendment in the department's response to a table of evidence received on the bill, but did not receive any further information and did not take a position on this matter. The correspondence provides information on a targeted consultation undertaken on the proposed amendments. The department states that there was unanimous support for those who responded for the disciplinary proceedings for former officers. With regards to the bar and advisory list, the police federation raised concerns about the disclosure of officers' names. The department has advised that there is no intention to make the list publicly available, and they will only be available to draw to, to available to UK law enforcement bodies. So can I ask members then if they're content to note the correspondence and the amendments? Agreed.

7.5, clause 27A, the taxation reform piece, the departmental correspondence. Can I refer members to correspondence, department page 30 to 37 of the table pack? Can I advise members that the department has written to address some of the points raised during the recent evidence session, as you recall from the bar and the law society on clause 27? Uh, the department states that the new clause is not a legislative blank check, but will simply clarify that fees and rates set out in secondary legislation can apply to anyone assessing costs to be paid out of the legal aid fund, including the taxi master. The department states that the motivation for reform is to increase the accountability, transparency, and budgetary control of public money, and has commented on brief fees and the concerns about a two-tier system. The department intends to make the necessary remuneration orders by end of this mandate. That's if 27A is passed, and advises that it will continue to engage with the bar and the law society to develop proposals for the consultation. Can I remind members that as the text of clause 27A was only received towards the end of the committee stage, the committee did not have the opportunity to consider in detail or reach a position on it? Uh, we only took that evidence, uh, to inform the members. So I can I ask members then if they're content to note the update from the department, or if any further information is requested? Okay. Content.

J, before that correspondence onto the, the bar and the law.

Yeah, I'm sure there's no, no issue there.

It came directly from what they'd said to us.

Yep. Okay. Very good. Brian, agenda item number eight is SL1, Special Educational Needs and Disability Tribunal Amendment Regulations Northern Ireland. Have you got additional?

We do. Sure. Um, sorry, just to make members aware that, um, the committee, uh, obviously had written to the Committee for Education and the Department of Education. The Department of Education's responses in, um, we did get something from the Committee, um, for Education during this meeting, which actually says they haven't reached their position on their regulations, and as a consequence on the department's reg [clears throat] our department's regulations.

Okay. Should it, should it be that we park this then to next week then?

Is that okay? A member's content then to get a fresh look at that and for go this week? Yeah.

Okay.

Yeah. Moving on then. Agenda number nine is police officer misconduct and vetting procedures intention to consult, department of justice written paper. Can I remind members that at the meeting on the 7th of May, the committee considered a paper from the Department of Justice providing an update on progress to introduce legislative amendments in relation to the police officer misconduct and vetting procedures? Members agreed at that time to request an oral briefing on the legislative amendment update, as well as response to some broader issues relating to police vetting and misconduct procedures. The department has advised that response to the those matters will be issued in due course. In the meantime, the department has written to the committee to commence a targeted consultation on a draft statutory rule to introduce amendments to the police conduct regulations Northern Ireland 2016. The rule will create 12 provisions, which are listed at page 528 of the meeting pack. The draft SR also includes provision to incorporate the revised code of ethics, which will place the schedule to the police conduct regulations Northern Ireland 2016. So can I ask members if they're content to note the paper and consider further during the ev evidence session, uh, with officials, or once the outcome of the consultation is available? Agreed.

J, number 10 is the legal aid remuneration consultation and maintaining an update up to date table of offenses and classifications of criminal cases. This is a written paper. Uh, can I refer members to page 549 to 553 of the meeting pack? Can I inform members that the committee has received a paper from the department giving notice of its intention to conduct a targeted consultation on proposals on how the legal services agency classify criminal cases not already classified in the legal aid legislation? Schedule three of the legal aid for crown court proceedings cost rules Northern Ireland 2005, as amended, sets out a table of offenses with nine classes of offenses. However, the schedule is a static and incomplete list, and as new offenses are created in statute, any offense not referred to in the statute table is classified as class H, attracting the lowest rate of remuneration and is frequently inappropriate for those cases. Practitioners then face a cumbersome process of seeking reclassification for such cases, which can then often result in delays. Can I inform members that the justice minister intends to consult on a direction to the LSA, the legal services agency, which will require and maintain an up-to-date table of offenses? It's a bit like the bandit system. The direction is technical in character and is aimed at simplifying administrative processing. This approach should ensure that practitioners are not faced with delay when seeking to submit their bail pending and reclassification process. It is intended. It is intended that the updated table of offenses to be maintained under the direction will be in due course be used for a future update of schedule three in the 2005 rules. It is proposed the short targeted consultation will run from, run from June the 1st to the 26th of June this year. Can I ask members of their content to note the paper and consider further once the outcome of the consultation is available? Okay.

Gen, number 11 is compensation award for miscarriages of justice, consultation on proposals to amend the statutory maximum compensation awards. It's a written paper from the department, and it's a page 555 of the meeting pack. Can I inform members that the department has advised that its intention to conduct a public consultation on the statutory maximum amounts of compensation payable for miscarriages of justice under section 133 of the criminal justice act 1988, as it applies to those cases in Northern Ireland which falls to department of justice? The department is seeking views on whether the existing statutory maximum awards in Northern Ireland remain appropriate, whether Northern Ireland should align with England Wales, where the statutory maxims are higher, and whether in principle there is justification to consider more substantive changes in the future, such as the introduction of a separate cap maximum for exceptionally long periods spent on custody or the removal of statute caps. Can I advise members, subject to any comments the committee may wish to offer? At this stage, the department plans to launch the consultation for an 8-week period. So can I ask members if they're content to note the paper and consider further once the outcome of the consultation is available? Okay.

Agenda number 12 is correspondence. Can I refer members to correspondence, me, six items of correspondence at page one, 572 to 5 to 8, 56 [clears throat] sorry. Uh, can I advise members that I will draw their attention to two of the items, and then members can have the opportunity to raise any. Can I remind members at the meeting of the 23rd of April, the committee considered response from the Department of Justice regarding the extern prisoner support project and the funding beyond March 2026? Members agreed to ask the department for further information on the work and outcomes of the project to date, and what impact assessment the department has conducted in relation to the services that may be lost if the project closes due to the lack of funding. Can I inform members that the department has now provided the response? Uh, can I remind members that the committee considered correspondence from extern at last week's meeting, which advised of an upcoming event to present the findings of research undertaken by Queens University Belfast on the impact of the project? So extern advised that an invitation will be extended to committee members in due course. So can I ask members if they're content to forward the response to extern for their information at this stage?

Uh, 12.6, then, uh, can I remind members at the meeting on the 14th of May, the committee considered response from the Department of Justice to the member, to a number of questions raised with the committee on an individual in relation to support for litigants in person, including support for self-litigants with disabilities, and separate correspondence from the individual to provide oral evidence to the committee? The committee forwarded department's response to the individual for information. Can I inform members that the committee has now received further correspondence from the individual in response to the department's asserting that the response does not answer the central issue raised in their correspondence, namely, what mechanism presently exists within civil adjudicative proceedings to secure, monitor evidence, and review effective participation for disabled litigants in person? The response also raises a number of further specific questions at page 659 to 660 of the meeting pack, and includes a copy of the dissertation that the individual has recently written and submitted for examination. So can I seek members' views on forwarding the paper beginning at pages 646 to the department for them to comment further on the issues raised and to respond to specific questions? Members agreed. Can I ask members if they're content with the other items of correspondence, or if they wish to raise anything at this stage? No. Okay.

Agenda item number 13 is forward work program. Can I inform members that the latest draft of the work for committee's forward work program can be found on pages 858 to 864 of the meeting pack? Can I ask members if they're content to note the forward work program, subject to any changes made in today's meeting? Agreed.

Agenda item number 14 is chairperson's business, or which I have none. Uh, and agenda item number 15. Any other business? Any other member wish to raise anything at this stage? No. Okay.

Agenda item number 16, date, time, and place of next meeting, which will take place on Thursday, the 4th of June, 2026, at 2 p.m. in room 30, Parliament buildings. I adjourn the meeting.

Committee room 30, sign.