INTRODUCTION

CONCLUSION

DOCUMENTS ATTACHED (See note at the end of this paper)

1. Globe and Mail Article, "National gun registry to cost more than planned" – October 31, 1997
2. Edmonton Journal Article, "Gun registry would cost nearly $1B" – September 15, 1997
3. Edmonton Journal Editorial, "Gun registry cost is up" – November 3, 1997
4. Financial Framework (C-68) Department of Justice - April 24, 1995
5. Western Report Article, "Mr. Rock’s missing zero" – June 12, 1995
6. Commons Debates, Question No. 18, Mr. Garry Breitkreuz – February 13, 1998
7. 1997-98 Estimates, Part III, Department of Justice
8. 1998-99 Estimates, Part III, Department of Justice
9. Canadian Police Association Brief – November 27, 1997
10. Canada Gazette Index, Part I – Ottawa, Saturday, December 13, 1997
11. Canada Gazette Index, Part II – Ottawa, Wednesday, April 15, 1998
12. Peace and Security, Explanatory Notes, Gun Control, Department of Justice – May 1976
13. Gun Control is not Crime Control, by Professor Gary Mauser, Fraser Forum – 1995
14. Research on Firearms Registration by H. Taylor Buckner, Ph.D. – May 8, 1995
15. Presentation at Gun Control Debate by H. Taylor Buckner, Ph.D, Montreal – February 11, 1998
16. Letter from RCMP Commissioner J.P.R. Murray to Dept. of Justice – July 21, 1997
17. Twin Sault Ste Marie Trap Association Presentation by Donna Ferolie, President – February 17, 1998
18. Motion Picture Studio Production Technicians Letter – January 26, 1998
19. Speech by the Saskatchewan Justice Minister John Nilson – April 17, 1998
20. E-Mail Communications on Costs from Dave Tomlinson, President National Firearms Association
21. Letter from John R. Lott on his book, "More Guns, Less Crime" – April 15, 1998
22. Windsor Star Editorial, "Gun registry costly and ineffective" – August 22, 1997
23. Ottawa Citizen Editorial, "Repeal C-68" – April 26, 1997
24. Edmonton Journal column, "Gun registry: expensive numbers game" – September 14, 1997
25. Windsor Star Editorial "Gun registry costs" – October 7, 1997
26. Halifax Daily News article, "Ottawa funds gun registry, not provinces" – February 26, 1998
27. Vancouver Sun article, "Gun registry cost too high" – December 11, 1996
28. Ottawa Citizen article,"2000 bug forces federal freeze" March 19, 1998
29. Letter from Canadian Firearms Centre Re: Distribution Costs, March 2, 1998
30. Toronto Sun article, "Gun crimes dropping but cops worry" – March 8, 1998

On October 31, 1997 the Globe and Mail headline revealed, "National gun registry to cost more than planned" (see clipping - Attachment #1). This came as no surprise to the many of the expert witnesses who warned the House of Commons Standing Committee on Justice and the Senate Standing Committee on Legal Affairs of this eventuality during the 1995 review of Bill C-68, Firearms Act. The Firearms Act was proclaimed into law on December 5, 1995 and after three false starts is scheduled to come into force on October 1, 1998.

This is a preliminary assessment of what Bill C-68 could cost taxpayers and will serve as a background paper to an official request for a forensic audit by the Denis Desautels, Auditor General for Canada.

An article from the October 31, 1997 edition of the Globe and Mail (see Attachment #1) states, "Implementing a national gun registry will wind up costing more than the planned $85 million, Justice Department officials said yesterday. A new estimate will not be made public until February, but the total cost of the mandatory registry is expected to be significantly higher than predicted in 1995 by the justice minister at the time." (emphasis added)

The article went on to cite a number of reasons for the Justice Department error:

• a number of provinces will not administer the firearm registry
• the federal government will now have to manage the firearm registry in these provinces
• the costs of fighting a court challenge by six provincial and territorial governments
• $85 million estimate included only start-up costs for the program
• advertising expenses to promote the registry were not included in the estimates
• training for police and law-enforcement officers were not included in the estimates
• ongoing operating costs were not included in the estimates

In a September 15, 1997 column in the Edmonton Journal, "Gun registry would cost nearly $1B" (see Attachment #2) Lorne Gunter stated, "And what is it likely to cost Ottawa to acquire this data? Nearly $1 billion. Over the past year, Ottawa has spent $120 million setting up its registry including $30 million on a computer program which it may now have to scrap. And the government has yet to register its first gun. Since Ottawa expects it to take seven years and it’s only going to get more expensive once it has actual guns to register, $1 billion seems like a low-ball estimate."

An editorial on November 3, 1997 in the Edmonton Journal was titled, "Gun registry cost is up – Ottawa should give true estimate" (see Attachment #3). The editorial stated, "In the context of the current fiscal climate of massive reductions to government spending, the cost of any new program needs to be carefully scrutinized before being implemented and the estimates then shared with Canadian taxpayers." (emphasis added)

Questions & Comments: With implementation now scheduled for October 1, 1998, it is now imperative that this cost-benefit analysis be done immediately. And not by the Department of Justice who got it wrong in the first place but by an independent auditor. Parliament was clearly misled during the debate of Bill C-68 both about the true costs of the measures proposed, the effectiveness of the measures to reduce the criminal use of firearms and the impact these proposals will have on the Canadian jobs and the economy.

On April 24, 1995 the Department of Justice tabled a document with the House of Commons Standing Committee on Justice called, Financial Framework – Bill C-68: Added Costs – Over 5 years (1995/1996 – 1999-2000). (See Attachment #4)

Questions & Comments: If the Department of Justice couldn’t prepare an accurate cost estimate in 1995, why should Parliamentarians and the public believe any new estimates they present? Isn’t it time for someone independent and with the taxpayers’ and the public’s best interests at heart to prepare this cost estimate?

The June 12th, 1995 edition of Western Report magazine published an article titled, "Mr. Rock’s missing zero – His registry will cost 10 times his estimate, unless gun owners ignore the law" (See Attachment # 5). The article written by Peter Verburg states in part, "The assumptions underlying Mr. Rock’s estimate have been widely repudiated. According to his ‘Financial Framework’ for C-68, there are approximately seven million firearms, and three million owners in Canada, figures obtained from a 1991 Angus Reid poll. He expects $116.7 million to be raised over five years through fees ($17 per gun). He claims that will cover most of the full cost of the registration and related programs over the next five years. But the average cost of registering a handgun under Bill C-17, according to Justice Department figures, is $82, and the current cost to the government of issuing a licence is $125. After subtracting revenue from fees under the proposed system, calculates Gary Mauser, a business administration professor at Simon Fraser University, the net cost to the government would be about $78 per firearm. Therefore, to register seven million firearms would cost at least $546 million, concludes Professor Mauser. The cost of licencing three million owners is between $195 million and $345 million, producing a total cost to taxpayers of $741 million. But that is only the best case scenario. In 1976, when the Trudeau government was looking at registration, the justice minister at the time, Ron Basford, estimated in a report that there were ‘over 10 million [firearms] in 1974, with almost one-quarter million added to the stock each year.’ Two decades later, there should be over 15 million firearms in Canada. At $78 per gun, that bumps the cost of registration up to $1.17 billion. Worse, at the end of April Richard Bergman, deputy commissioner of the RCMP, to the Commons Justice Committee there could be up to 25 million firearms in the country, nearly one per capita, the same rate of gun ownership as in the U.S. Based on the current cost of registering handguns, the total costs would be a whopping $1.95 billion."

In June of 1997, a number of Firearms Safety Instructors were touring the Department of Justice’s Canadian Firearms Centre in Ottawa. A CFC official told the group that the centre had spent $146 million so far. Two days later at a Firearms Safety Instructors Conference, during a seminar on the new computerized registration system, the contractor’s representative said approximately $150 million had been spent to date.

On September 25, 1997, Garry Breitkreuz, MP (Yorkton-Melville) introduced a written question Q-18 on the Order Paper asking how much the government has spent implementing C-68. He also asked the government to provide an accounting of how this money has been spent, how many federal employees are working on the implementation and to provide a revised estimate of the total cost and number of employees to implement the provisions of the statute in each province and territory.

On February 13, 1998, the government responded to the question saying that the government had only expended $34.3 million on the implementation of the provisions of C-68 and that only 53 federal employees are working on the implementation of this statute at the Canadian Firearms Centre (see complete text of response in Attachment #6).

Questions & Comments: Why does the $34.3 million amount quoted by the Minister of Justice directly contradict the $146 million quoted by the CFC officials in their personal communication with firearms instructors in July of 1997? Why did the Minister of Justice tell the House of Commons that there were only 53 employees working in the Canadian Firearms Centre while the newly issued government telephone directory lists 126 employees working in the CFC?

The 1997-98 Estimates, Part III for the Department of Justice under the Law and Policy section, Key Initiatives, (b) Firearms Control Measures states: "In 1997-98, the Department will seek Preliminary Project and Funding Approval for this project. Over the period, 1997-98, the Firearms Centre will undertake the phased implementation of the licensing, authorizations and registration components of the Canadian Firearms Registration System, as well as the training of more than 50,000 police/enforcement officers, 3,000 customs officers and crown attorneys and the preparation of information packages for the judiciary." (see page 22 of Attachment #7)

Page 25 of the estimates document describes the "Performance Measures for the Law and Policy Business Line/Activity." Bullet number seven states, "Enhanced public safety and perception of safety and reduced incidence of violent crime involving firearms." The cost of these "firearms control measures" are lumped together with all other line items and therefore it is not clear how much these initiatives will cost taxpayers (see page 26 of Attachment #7).

Questions & Comments: The Department of Justice is being less than forthright with their cost estimates. How can taxpayers (or Parliament) determine if the cost of implementing universal gun registration is cost-effective if the government won’t tell them what the cost has been so far and will be in the future? How will taxpayers know if other measures for controlling crime wouldn’t produce better results than gun registration?

A researcher from the Library of Parliament talked to Gordon Perry of the Canadian Firearms Centre on March 13, 1998 requesting a copy of the "revised estimates" promised by the Justice Department in the Globe and Mail article (see Attachment #1). This senior Justice Department official said, "The ‘revised estimate’ referred to will appear in the 1998-99 Report on Plans and Priorities which has not yet been tabled in the House."

A copy of the 1998-99 Estimates, Part III for the Department of Justice under the Law and Policy section, Key Plans and Strategies, is attached (see Attachment #8). The "revised estimate" promised by the Canadian Firearms Centre officials is even more disappointing than the previous year’s effort. Page 21 under the sub-heading of "Firearms" states, "Effective implementation of the government’s firearm control system is among the Department’s highest priorities. The regulations required to implement the system are in place following the scrutiny of both Houses of Parliament as required in the statute. The new Licencing and registration systems will be ready June 1, 1998 for data input. The operational agreements with the provinces and federal partners that will be necessary to administer the initiative over the long term are under negotiation. The system will be fully operational by October 1, 1998." On page 27 under the heading "Expected Results" it states, "reduction of incidence of violent crime through the implementation of firearms control measures."

With the exception of the "Contributions to the provinces and territories for the Firearms Program" detailed in Table 5 on page 38, all other expenditures related to implementation of gun control measures are buried in other line items.

On April 15, 1998, the researcher in the Library of Parliament called Jean Valin, Public Affairs Director for the CFC and he was told that the above information is the only information available.

Questions & Comments: That’s it? This is the "revised estimate" we’ve all been waiting for? How can Parliament and the public make decisions about the cost-effectiveness of gun control measures if the Department of Justice hides the costs from them? At least four provinces have opted-out of the administration of the firearm registration system. What will the implementation costs be in those provinces compared with the costs of the "operational agreements" in the other participating provinces? Who is doing the "data input"? Who are the other "federal partners" involved and how much is their participation costing taxpayers?

On November 27, 1997, Neal Jessop, President of the Canadian Police Association presented a brief to the House of Commons Standing Committee on Justice with respect to the Proposed Regulations pursuant to the Firearms Act (see Attachment #9). Officer Jessop told the Committee, "Put bluntly, cops on the street provide greater public safety benefit than registration of firearms. The government has made progress in parole reform, high risk offenders and DNA search warrants although much more is required in these areas, all of which has been identified and all of which would be more cost effective than firearms registration insofar as public safety is concerned."

Questions & Comments: Doesn’t the government have a responsibility to spend tax dollars where they will produce the best results? When it comes to reducing violent crime, how does the effectiveness of registering guns compare to putting more police on the streets? Doesn’t the public at least deserve to be told what the most cost-effective crime fighting measures are? How else can voters and taxpayers make an intelligent choice about the alternatives available to the government and which ones to support?

On September 21, 1995, Ontario Solicitor General, Bob Runciman appeared before the Senate Standing Committee on Constitutional and Legal Affairs. He told the Senators, "Our position is that the sections of Bill C-68 that provide for compulsory registration of all firearms will divert police resources from more important tasks. Those sections will reduce the number of officers and amount of money available to deal with serious crime. They will make the real task of gun control more difficult and more dangerous for the police officers that undertake it. And those provisions will ultimately have no significant impact on violent crime or the use of firearms by violent criminals." Mr. Runciman also pointed to the failure of the handgun registration system as proof that registration "does little to limit the use of handguns by criminals."

The Ontario Solicitor General concluded, "In Ontario alone, just dealing with the paperwork generated by registration would take between 10 and 15 officers off the street and put them behind desks shuffling registration forms. That is the equivalent of about 30,000 hours of police time each year – just to deal with red tape. In national terms, 85 million dollars would put another 1,000 customs agents on the border; 500 million dollars would put 5,900 police extra officers on the street. The federal alternative is to use the money to register every shotgun and bolt-action .22 in Canada. No great brilliance is required to figure out which would have a greater impact on crime."

Questions & Comments: Here is one province’s assessment of how much it will cost to implement gun registration. As the Solicitor General for Ontario points out these police resources could be produce better results at reducing crime if they were spent in other crime-fighting initiatives. Officials at the Canadian Firearms Centre say the RCMP will enforce the gun registration scheme in those provinces that opt-out. Unfortunately, Mr. Runciman’s arguments to spend the money on police activities where they will do the most good apply just as much to the RCMP as they do to the Ontario Provincial Police.

The Canada Gazette, Part I, Ottawa, Saturday, December 13, 1997 (index attached Attachment #10) published the Proposed Regulations for the Firearms Act introduced by the Department of Justice, pages 3795 to 3849.

The Canada Gazette, Part II, Ottawa, Wednesday, April 15, 1998 (index attached Attachment # 11) published the Proposed Regulations for the Firearms Act introduced by the Department of Justice, pages 1184 to 1296.

Each set of proposed regulations includes a Regulatory Impact Analysis Statement but these impact statements are far from complete. For example, on page 1200 of the April 15^th Gazette under the heading "Anticipated Impacts" it states, "The precise number of affected individuals and business in unknown, but it is estimated to be several million individuals and several thousand business." On page 1201 under the heading "Small Business Impacts" it states, "In 1996 there were 6,271 firearm business permits issued under the existing Criminal Code provisions."

The Regulatory Impact Analysis Statements for the proposed Firearms Act regulations did not include: (a) estimates of the cost of implementation and estimates of ongoing operating costs for the federal, provincial and municipal governments, (b) an analysis of the cost-effectiveness of the regulations, and (c) an assessment of the impact these regulations will have on sectors of the economy for things like firearms sales, hunting, sports shooting, tourism, aboriginal guiding and outfitting, etc, and (d) an estimate of the number of business failures and number of jobs to be lost and the total dollar impact on the GDP.

Questions & Comments: How can Parliament and the public properly assess the "impact" of these firearms regulations if the Regulatory Impact Analysis statements do not include cost estimates and economic impact statements? Isn’t there some legal requirement that all the facts be presented in the Gazette so voters and taxpayers can make their own assessment? How can democracy work if vital information is being withheld from the public?

In March of 1991, the Department of Justice published a Technical Report (TR1991-8a) titled, "Firearm Ownership in Canada" by the Angus Reid Group, Inc. Page 1 of the report states, "A total of 10,103 households were contacted in this survey. In each household, an adult member was questioned on whether or not their household owns any type of firearm. If a firearm was owned by the respondent or any other member of the household, the Angus Reid Group interviewer then administered the remainder of the questionnaire."

Based on a single telephone interview, Angus Reid reported on page 3 of the report, "The prevalence of firearm ownership is estimated to be 23 percent of Canadian households." On page 4 of the report the pollster guesstimated, "The approximately 2.2 million households with a firearm own an estimated total of 5.9 million firearms."

On May 8, 1995, H. Taylor Buckner, Ph.D, Professor of Sociology, Concordia University, Montreal appeared before the House of Commons Standing Committee on Justice stated, "According to estimates I calculated from the 1995 Gun Control survey, organized by Professor Gary Mauser, with my assistance, the Reid study under-estimated the number of firearms in Canada by at least 24%. This is a result of women not reporting firearms ownership (which has been found in other surveys), and not taking into account those who refused to answer the question. There are also people who lie, which makes the total an unknown percentage higher. Similar problems have been reported in U.S. surveys (Erskine; Kennet; Kleck). This, the cost estimates for Bill C-68 based on the number of firearms to be registered are many, many millions too low."

Questions & Comments: It is truly surprising that so many respondents admitted to a stranger over the phone that they owned one or more firearms. The question is, how many didn’t admit to owning a firearm? Despite this serious flaw in the design of the poll, the Department of Justice has continued to delude themselves and mislead Parliament and the Canadian people by claiming that there are only 5.9 million firearms in Canada. Unbelievably, the government has not adjusted this number upward since 1991 despite knowing that there are hundreds of thousands of new firearms being brought into Canada every year.

A government report released in May of 1976 by the Department of Justice and the Department of the Solicitor General provides clear evidence that the government knows there are at least 15 million firearms in Canada. The report’s covering letter is signed by Minister Ron Basford. The report is called, "Peace and Security: Protection against violent crime – Explanatory Notes Gun Control" (see Attachment # 12). Page one of the report states, "At the same time, there has been a steady increase in the number of firearms in Canada. Estimates place the number at over ten million in 1974, with almost one-quarter million added to the stock each year." Likely because of a more realistic estimate of long guns in Canada the 1976 report concluded on page 4, "Finally, registration of each individual long gun was considered as well and it appeared to be impractical as well as unduly expensive."

Questions & Comments: Adding a quarter million new firearms a year to the existing stock of ten million firearms for the last 24 years means that at the end of the year 1998 there will be at least 16 million firearms in Canada. The Department of Justice can’t explain where the additional10 million firearms went between 1974 and 1998. Many critics suspect the government persists in using the lower number of 5.9 million firearms instead of the 16 million so that the participation or compliance rate for their registration scheme will appear higher than it really is. And, won’t registering 16 million firearms cost the taxpayers more than registering 6 million?

The Justice Department argues that cost of registering each long gun will be dramatically cheaper than the $82.69 it now costs the provinces and the RCMP to issue a registration for a restricted weapon such as handgun (see Department of Justice Technical Report (TR1994-9c) "Review of Firearms Registration" Page 27, Table-2 "National Cost Summary of Registration of Restricted Weapons"). The authors of this report also make important comments under sub-headings Financial Aspects (page 34) and Cost Recovery (page 36).

Questions & Comments: The fact is it will cost all levels of government to implement universal firearm registration system but the Department of Justice doesn’t know how much. Nor do they know how much the government will recover in licencing and registration fees from firearm owners. Finally, aren’t "cost-recovery" and "user-fees" just other names for taxes? Isn’t the government required to prove that a tax or user-fee will produce some tangible benefit to the users or society at large? What is this benefit and how will it be measured? Is it just that the government has the power, so gun owners are forced to pay? And how much will responsible firearm owners be forced to pay? And what will happen if there is excess revenue? Will it go to lower the cost of licencing and registration? Or will it go into general revenue? Responsible firearm owners would likely be more willing to pay higher taxes to put more police out on our streets and highways and in our communities, which can be proven to produce real improvements in controlling crime and improving public safety.

In March of 1991, the Department of Justice published a Technical Report (TR1991-8a) titled, "Firearm Ownership in Canada" by the Angus Reid Group, Inc. As explained above, this poorly designed poll resulted in an impossibly low estimate of the number of firearms in Canada. For the same reasons this poll also dramatically underestimated the number of firearm owners in Canada.

In 1995, The Fraser Institute published a Critical Issues Bulletin by Professor Gary Mauser of Simon Fraser University called, "Gun Control is not Crime Control." (see Attachment #13)

On page 8 Professor Mauser states, "According to survey estimates at least one household in four in Canada has firearms. A recent survey found that 23 percent of households had firearms in 1991. There are 10 million households in Canada, which means that 2.2 million households have firearms (see table 1). This may be a low estimate as another recent survey found 34 percent of households had firearms, which would mean 3.4 million households own firearms. Thus, there are between 2.2 million and 3.4 million Canadian households with firearms. Since there may be more than one firearms owner in a household, these are minimum estimates of the number of individual firearms owners in Canada. As well an unknown percentage of people have firearms but have not reported them to the interviewer. Consequently, the best estimate is that approximately one-third of Canadian households has one or more firearms. This means that, in 1993, there were between 3 million and 7 million individual firearm owners out of a total population of 29 million."

Questions & Comments: How much will it cost to issue possession and acquisition licences to up to 7 million firearm owners in Canada? How many will apply for the permits if as many as 30% of gun owners don’t intend on registering their firearms anyways? (See next page and Attachment #14) How much revenue will this bring the government initially and on renewals? How much will it cost the government to issue these permits?

Dr. H. Taylor Buckner, Adjunct Associate Professor of Sociology, Concordia University spoke in a debate at the School of Community and Public Affairs of Concordia University on February 11, 1998. (See Attachment #14) Dr. Buckner said, "The final reason registration will fail is because gun owners are being required to pay for it. So called ‘cost recovery’ was a necessary smoke screen to get the legislation passed – it hid the true, and staggering, cost of the operation from the public and the politicians. The deceptive, ‘only $10 dollars for the first 10 guns’ strategy, is part of the smoke screen. Those trying to sell the legislation do not mention the possession fee, the transfer fee, the fee for foreign hunters, and the fees for retailers, wholesalers, and gunsmiths. The current system of registering handguns has only survived because it was free for the gun owner. There are millions of guns in Canada that are worth less than the total of the fees necessary to keep, register and sell them. For the owners of these firearms the economically rational thing to do is to not register at all, hunt without buying a permit, and sell the guns to friends, neighbours and criminals. The risk of detection is low, and an unregistered gun will sell for more than a registered one."

Questions & Comments: How much revenue will the government collect in fees (taxes) from gun owners, gun clubs, gun dealers, gun smiths, gun manufacturers, outfitters, foreign hunters, etc? How much of these fees will be needed to administer the licencing and registration system?

Paying fees is probably the cheapest part of the licencing and registration process. The time it will take will cost gun owners, gun clubs, gun dealers, gunsmiths, gun manufacturers, outfitters and foreign hunters much more. Filling out a registration form is not a simple process especially when making a mistake could result in a criminal offence. Just ask owners of restricted firearms how much time they spend filling out registration forms, running back and forth to the permit office. Just ask restricted firearm owners how much time they have had to take off work to get firearms registered.

Questions & Comments: How much productive time will be lost by everyone who is required to fill out a licence application and or firearm registration form? How much time will be spent by responsible firearm owners to keep the information up-to-date? How many firearm registrations will require verification by phone and in person. How long will this verification process take and will gun owners have to take time off work to comply? How much will this loss of productive time cost workers, employers and the economy?

In 1995, The Fraser Institute published a Critical Issues Bulletin by Professor Gary Mauser of Simon Fraser University called, "Gun Control is not Crime Control." (see Attachment #13)

On page 26 Professor Mauser states, "Even if only 25 percent of gun owners failed to register their firearms, the effectiveness of registration would be severely hampered. Even after registration, the police would not be able to trust the registration records to indicate if a suspect had firearms, nor would the courts be able to know that prohibition orders were complete. The actual number of people who would refuse to register could be far higher than 25 percent"

On May 8, 1995, H. Taylor Buckner, Ph.D, Professor of Sociology, Concordia University, Montreal appeared before the House of Commons Standing Committee on Justice stated, "In the 1995 Gun Control survey, a national study carried out by Canadian Facts in which 1,505 Canadian adults were interviewed, we asked gun owners, ‘If the government’s proposal to register all firearms becomes law, do you plan on registering all, some, or none of your firearms?’ Overall, only 71.1% (+ 6%) of gun owners said they would register all their guns. In other words, roughly two million firearms belonging to over a quarter of firearm owners will remain unregistered. Of course, over time with great expenditure of funds and criminal prosecutions, more than 71.1% registration could probably be achieved." (see Attachment #14).

Dr. H. Taylor Buckner, also participated in a debate at the School of Community and Public Affairs of Concordia University on February 11, 1998 (See Attachment #15). Dr. Buckner said, "Bill C-68 is Canada’s third attempt to register all firearms. The first was passed on July 1^st, 1920, and repealed on June 4^th, 1921. The second was passed on August 15^th, 1940. After complaints from the RCMP about the work involved it was repealed on February 20^th, 1945. For universal firearm registration to provide any benefits there must be a high level of compliance. If there is not, the police will not be able to use the data with any certainty. They will not be able to inspect gun owners to see if their firearms are safely stored, and obviously, they will not be notified of the theft of unregistered firearms. They will not be sure when they enter a domestic conflict that there are no firearms present, or be able to confiscate guns under a prohibition order. No one has been foolish enough to claim that criminals will register, so long-gun registration will turn out to be as ineffective a crime fighting tool as handgun registration has been. The registered owner risks being charged for unsafe storage if his guns are stolen, risks being charged if he did not notice and report the theft. Being asked to pay to get your name on a list, so you can be inspected and charged with various criminal offenses, is a bizzare concept, on that will guarantee failure of the system. Ask any economist."

Questions & Comments: What was the compliance rate for the previous two long gun registration schemes implemented in Canada? Would these compliance rates produce the improvements in public safety claimed by the government and their supporters? Will the design of the current system improve compliance rates over the previous attempts at universal registration of firearms? What compliance rate is enough to reduce the criminal use of firearms? How many tax dollars should the government be prepared to spend to achieve this compliance rate?

In November of 1997, hearings to review firearm regulations were held by the House of Commons Standing Committee on Justice. During the hearings RCMP officials stated, "The potential for errors on applications from members of the public who may not be well versed in firearms classification is extremely high. If the police services of this country cannot count on the veracity of the information entered into the Canadian Firearm Registration System, they may not use it to its full potential."

During these same hearings, Assistant Deputy Minister Richard Mosley claimed that if the serial number of a firearm is incorrectly recorded on a mail-in application, and subsequently placed on a registration certificate, it would still be a valid certificate. According to the Justice Department, the only time the information on a registration certificate will be verified to determine its accuracy is when the firearm is sold or transferred. Reform Justice Critic, Jack Ramsay, MP for Crowfoot (Alberta) commented, "This is unbelievable. The fact is that we’re going to have thousands and thousands of bogus registration certificates and unreliable information contained within the registration system."

Eric Goodwin, Chief Firearms Officer for P.E.I. also warned the Justice Committee, "The information contained in the registry on restricted and prohibited firearms will be unverified and hence unreliable. This will impact on police safety, public safety and enforcement."

Dr. H. Taylor Buckner, Adjunct Associate Professor of Sociology, Concordia University spoke in a debate at the School of Community and Public Affairs of Concordia University on February 11, 1998. (See Attachment #15) Dr. Buckner said, "We are told that computers will solve the problem, but they will not. The record keeping problem is not in the manipulation of the data, but in getting the correct data into the system and keeping it current, which depends on people."

Questions & Comments: If police stop a licenced gun owner with a properly registered firearm in their car and they run a check on CPIC and the gun shows up as unregistered because of inaccurate information supplied by the gun owner on his/her application or because of inaccurate data-entry, what will the police do? Seize the gun and arrest the gun owner? What evidence will they produce in court? How will the gun owner defend himself if he didn’t keep copies of all the documents filed? How much will this misdirected use of police resources cost taxpayers? How many real criminal acts will be committed while police are wasting their time harassing law-abiding, responsible firearm owners who will never be a threat to anyone’s safety?

So far the debate on costs has only focused on the hundreds of million it will cost to licence between 3 and 7 million law-abiding gun owners and register between 6 and 25 million firearms. But what about the cost of enforcing 137 pages of provisions of the Firearms Act and the 140 pages of regulations? No one has even suggested how many police or inspectors will be deployed, what methods they will use to enforce the new laws and how much this enforcement activity will cost. Surveys show as many as 30% of all firearm owners are planning not to register their firearms. Are the police going to "inspect" (raid) millions of households to find the firearms owned by these "made-in-Ottawa" criminals who are no threat to public safety whatsoever? How will this activity stop the real criminals?

Nor has the Department of Justice estimated how many charges are likely to be laid, how many will be contested in court, how many cases will be won or lost, how many will be appealed to higher courts, how much the court costs and lawyers will cost taxpayers, and who will pay the court costs and legal costs, the federal government or the provincial governments? How many more constitutional and charter challenges will there be with respect the highly controversial provisions of C-68?

The Department of Justice has also failed to estimate how many gun owners who are convicted will end up going to jail, what the incarceration costs will be and how much of these costs will be paid for by the federal government and how much by the provincial governments.

Questions & Comments: How much has it cost to enforce the previous gun control laws? How many charges have been laid, how many have been contested in court and how much has it cost taxpayers? Further, what is the government’s track record? Charges for improper storage of firearms are almost always won if contested in court because of poor wording of the legislation and regulations. Is the same thing likely to happen with C-68?

The Firearms Act bans hundreds of thousands of firearms. So far the government has refused to pay compensation for the loss in value experienced by the owners of these banned firearms. Once firearm owners prove in court that they still have property rights, the government will be on the hook for hundreds of millions in compensation. The governments of Britain and Australia have paid compensation to gun owners for firearms they have banned, it’s only a matter of time before Canada will have to do the same?

Questions & Comments: How many firearms have been banned by the government? What was the value of these firearms before they were banned? What is the value of these firearms now? How big a liability is this for Canadian taxpayers? When will the compensation have to be paid?

Here are some excerpts from a letter dated July 21, 1997 sent by RCMP Commissioner J.P.R. Murray’s to the Deputy Minister of the Department of Justice (See Attachment #16).

These false or misleading statistics were introduced six times in affidavits by the federal government and their supporters during a court challenge of Bill C-68 in the Alberta Court of Appeal. The challenge was launched by the Government of Alberta and supported by the governments of Saskatchewan, Manitoba, Ontario, Yukon and the N.W.T. The RCMP still refuse to swear an affidavit in court attesting to the accuracy of the Justice Department’s manipulation of RCMP firearms crime statistics.

Questions & Comments: How can the government estimates claim that implementation of the provisions of C-68 will "reduce the incidence of violent crime involving firearms" when the RCMP and the Department of Justice can’t even agree on when a firearm is "involved" in a crime?

In order for the criminal justice system to work, the people have to believe that the laws passed by Parliament are fair and just, will improve public safety and will be an effective use of taxpayers’ dollars. Between 3 and 7 million responsible firearm owners and millions more of their friends and families know that Bill C-68 is neither fair nor just. They know that it will not improve public safety and that there are far more cost-effective ways for the government to reduce violent crime and save lives.

Many millions of Canadians know that Bill C-68 is a bad law. As many as 2 million have told pollsters that they intend to defy the law and not register their firearms. When this happens they also start to question the appropriateness of other criminal laws and statutes passed by Parliament. This may lead citizens to consider ignoring other criminal laws because they have reason to believe that the government and police already consider them criminals under Bill C-68. Already, we are receiving anecdotal evidence that firearm owners are buying and selling firearms ignoring FAC rules that they previously respected.

If several million gun owners now become possible criminal suspects simply because they own firearms, they will undoubtedly become less cooperative with the police. These millions of Canadians will be very suspicious of letting police on their property and in their homes when police are investigating real crimes and chasing down real criminals.

Many millions of Canadians know that the Commissioners of the RCMP and Chiefs of Police support Bill C-68. They also know the vast majority of serving RCMP officers and police on the street don’t support Bill C-68. Citizens have every right to question the independence of the police force and believe that the RCMP brass and Chiefs of Police have become political pawns.

Police forces grow and Chiefs get promoted or get raises on the basis of crime statistics. It will be far easier for police to get a "criminal" conviction under complex gun laws than by investigating real crime. Some police officers may start to take the easy way up the ladder by using the provisions of C-68 to increase their crime statistics and clearance rates. When this happens, and it will, people will protest against all police and the police will become the enemy not the public’s protector.

Polls clearly indicate that the vast majority of police on the street oppose Bill C-68 and gun registration in particular. When these common sense police officers are told by their superiors to support and enforce the law against their better judgment, they lose respect for their superiors and lose respect for the other laws in the Criminal Code and the lawmakers in Parliament. When the vast majority of police on the street know that Bill C-68 is a bad law, many police officers may begin to decide for themselves which criminal laws make sense, which ones don’t and which laws to enforce and when to look the other way.

Questions & Comments: This is not a healthy situation for relations between the police and the law-abiding public whom they depend on for help to keep the peace. If this trust between the police and the law-abiding citizenry breaks down then the entire criminal justice system is in jeopardy. This is not a healthy situation between the police and their superiors. This is not a healthy situation for relations between majority of police who oppose gun registration and the few who will enforce it. On all three fronts, the work of police officers is going to be more difficult. The question is how much will these cost taxpayers? How many fewer real crimes will be solved because citizens are less cooperative with police than they were before?

The Department of Justice claims that gun control provisions past, present and future save lives but cannot produce a shred of evidence to prove their case. On the other hand there is conclusive evidence that firearm ownership saves thousands of lives.

In 1995, The Fraser Institute published a Critical Issues Bulletin by Professor Gary Mauser of Simon Fraser University called, "Gun Control is not Crime Control." (see Attachment #13)

On page 22 Professor Mauser states, "Instead of saving lives, strict firearm legislation may actually have the perverse effect of costing lives. This might happen if legislation denies firearms to people who need them for self-defence. Firearms are used to save human lives as well as to take them. As surprising as it may be, based upon representative surveys the author estimates that Canadians use firearms to defend themselves about 32,000 times annually and against animal threats about 36,000 times annually. If firearms actually saves human lives in only 5 percent of these situations, then the use of firearms in self-defence would save more lives each year than are lost through firearms misuse in Canada."

Questions & Comments: Will the provisions of C-68 decrease the number of firearms available for self-defence? Will the provisions of C-68 impede the access and availability of firearms to their owners for defensive purposes? Will home break-ins and home invasions increase because real criminals know that home owners are likely to be unarmed and/or their firearms are likely to be locked up so as to present little or no threat to their criminal activity? Why are burglaries of occupied homes so low in the United States, higher in Canada and higher still in Britain?

Dr. H. Taylor Buckner, Adjunct Associate Professor of Sociology, Concordia University spoke in a debate at the School of Community and Public Affairs of Concordia University on February 11, 1998. (See Attachment #14) Dr. Buckner said, "Without nearly absolute compliance, millions of guns can and will be sold on the gray (not registered, for non-criminal use) or black (not registered, for criminal use) markets. These sales are already beginning to increase."

Questions & Comments: The firearm registration system will obviously drive guns into both the gray and black markets. The question is how many will be sold in these markets? How much revenue will the government lose as a result?

In February of 1998, Donna Ferolie, President of the Twin Sault Trap Association came to Ottawa to inform the Northern Ontario Liberal Caucus of how much Bill C-68 is going to cost her community.

Ferolie’s 10 page presentation (see Attachment #17) is loaded with facts about how just two provisions in Bill C-68 will devastate border towns and northern businesses and communities and do nothing to improve public safety. She looked at the proposed fees to be levied on non-residents entering Canada with firearms, and the overly complicated procedures proposed for residents and non-residents crossing the Canada-US border with legally-owned firearms to be used for hunting and sporting purposes. Her report details the impact that these two provisions will have on Canadian residents, American citizens, on Canada Customs operations and the economic and cultural impacts.

Ferolie’s analysis shows more common sense than anything government has yet produced on the economic impact of their flawed legislation. Here are some of the things she found out:

1. Customs officials estimate that it will take at least 30 minutes per firearm each way to do all the checking and recording demanded by the regulations.
2. The new Customs regime will be no more effective and far more costly than the current Y38 card system.
3. Hundreds of thousands of border crossings will be stalled inconveniencing all travelers to and from the States.
4. The half-hour hassle at the border and the $50 a year fee for U.S. sport shooters and hunters will dramatically reduce the number of American tourists.
5. Boycotts by American sport shooters are being actively promoted in the U.S.A.
6. Tens of millions will be lost to the northern Ontario economy, businesses will go bankrupt and fifty-year-old shooting clubs will die.

On January 26, 1998, the House of Commons Standing Committee on Justice received a letter from the Motion Picture Studio Production Technicians (see Attachment #18). The letter stated in part, "Is the disruption of over 2 billion dollars worth of economic activity in the Theatrical, Film and Television industry in Canada the desire of our country? Is the loss of tens of thousands of jobs the acceptable price of these firearms regulations? We are expanding and creating jobs while safely using ‘firearms’ in 75% of this growing industry. The vast majority of these ‘firearms’ are replicas or altered to fire blanks. These regulations jeopardize a growing, successful industry and loss of employment to ten of thousands of Motion Picture and Television employees, producers and service providers."

Questions & Comments: Doesn’t the government have an obligation to tell taxpayers how many jobs are going to be lost as a result of the provisions of Bill C-68? Will crime increase in affected communities because of the rise in unemployment? How many fewer hunting licences are being sold as a consequence of gun control laws? How will fewer hunters affect wildlife populations and how much will this cost governments? Once the tourists stop coming, the businesses fail and the employees are on unemployment insurance or welfare is no time to start considering the economic impact of this legislation. The time is now!

The November 15, 1997 edition of the Montreal Gazette reported the following quote from the Deputy Prime Minister: "This could be the start of a global movement that would spur the development of an instrument to ban firearms worldwide that would be similar to our land-mines initiative." Herb Gray was commenting on an agreement he signed on behalf of the government of Canada with the Organization of American States.

The government of Canada has assumed a leadership role in the United Nations efforts to initiate global gun control. The Canadian Firearms Centre has at least three staff working in a unit called "International Issues." Canadians regularly attend international gun control meetings.

Questions & Comments: How many Canadian bureaucrats are attending how many international gun control meetings? Why are they going to these meetings, what good will come of it for Canada, and how much does this activity cost taxpayers? The Minister of Foreign Affairs has refused permission for Dr. Jim Pankiw, MP for Saskatoon-Humboldt to attend these international meetings as an observer. Why? What have they to hide from Parliamentarians?

As anyone can see from the previous seventeen pages, the provisions of Bill C-68 are going to cost Canadian taxpayers plenty. The scary thing is the government has no idea how much it will cost nor has it assessed what impact the bill will have on our justice system or our economy. Obviously, the government should not proceed with implementation of the provisions of the Firearms Act until all these costs are well researched and made known to the public. The government has refused to provide these facts to taxpayers. The Auditor General for Canada is our last hope that justice will be done before this colossal mistake is perpetrated on the Canadian people.

It has been impossible to reference and comment on all the documentation that is available regarding how much C-68 will cost taxpayers. All internal references to attachments plus the following additional documents can be obtained by contacting the office of Garry Breitkreuz, M.P..

1. Speech by the Saskatchewan Justice Minister John Nilson – April 17, 1998 (Attachment #19)
2. E-Mail Communications on Costs from Dave Tomlinson, President NFA (Attachment #20)
3. Letter from John R. Lott on his book, "More Guns, Less Crime" (Attachment #21)
4. Windsor Star Editorial, "Gun registry costly and ineffective" – August 22, 1997 (Attachment #22)
5. Ottawa Citizen Editorial, "Repeal C-68" – April 26, 1997 – Attachment #23)
6. Edmonton Journal, "Gun registry: expensive numbers game" – September 14, 1997 (Attachment #24)
7. Windsor Star Editorial "Gun registry costs" – October 7, 1997 (Attachment #25)
8. Halifax Daily News, "Ottawa funds gun registry, not provinces" – February 26, 1998 (Attachment #26)
9. Vancouver Sun, "Gun registry cost too high" – December 11, 1996 (Attachment #27)
10. Ottawa Citizen article,"2000 bug forces federal freeze" March 19, 1998 (Attachment #28)
11. Letter from Canadian Firearms Centre Re: Distribution Costs, March 2, 1998 (Attachment #29)
12. Toronto Sun article, "Gun crimes dropping but cops worry" – March 8, 1998 (Attachment #30)