October 30, 2003
Mrs.
Sheila Fraser
Auditor
General of Canada
240
Sparks Street
Ottawa,
Ontario
K1A
0G6
Dear
Mrs. Fraser:
Subject:
GOVERNMENT
FAILS TO FOLLOW ITS OWN REGULATORY POLICY
Reference is being made to my previous letter
dated June 16, 2003. Please find
attached the government’s October 28th response to my Order Paper
Question Q-248 confirming once again that when it comes to implementing firearms
regulations, the government fails to follow its own Cabinet-approved Regulatory
Policy.
As anyone can plainly see from its response, once
again, the government has failed to provide information on its firearms program
to Parliament that would “ensure that use of the government’s regulatory
powers results in the greatest net benefit to society”. It failed “to weigh the benefits of alternatives to
regulation, and of alternative regulations, against their cost”, and
consequently, it also failed to “focus resources where they can do the most
good”.
The government’s feeble response to question
(a) confirms that it doesn’t even have a good understanding of the benefits of
firearms ownership. How can the
government possibly do a proper cost-benefit analysis of the firearms program if
it can’t even list the benefits of gun ownership in Canada? I have attached an interim list of the benefits of firearms
ownership that I have prepared with the help of academics, firearms experts and
responsible firearms owners.
The government’s response to question (b)
completely failed to identify any “indirect costs” of implementing
its firearms program such as the “major additional costs” of
enforcement and compliance as noted in paragraph 10.29 of your December 2002
report on the Costs of Implementing the Canadian Firearms Program. The three reports prepared by the Parliamentary Research
Branch clearly demonstrate that enforcement costs and compliance costs for the
firearms program will easily cost between $2 and $3 billion dollars – costs
that the Solicitor General refuses to report to Parliament.
I have enclosed copies of these three Library of Parliament reports.
…continued on Page 2
-2-
The government’s perverse response to part (c)
of my question demonstrates the government’s unwillingness to even acknowledge
the huge economic costs of the firearms program.
On August 16, 1999, the Department of Justice refused to provide me with
a copy of its entire 115-page report on the economic impact of the gun registry
by declaring it a “Cabinet confidence”.
I have attached a copy of my news release dated May 11, 2001, showing the
other government departments that should be interested in these economic impacts
that have also failed to address this costly question.
I only have two questions, how much longer is the
government going to keep Parliament in the dark about the true cost of the
firearms program? Would you
consider exposing this repeated failure of the government to follow their own
Regulatory Policy in your next Status Report to Parliament?
Sincerely,
Garry
Breitkreuz, MP
Yorkton-Melville
cc
Reg
Alcock,
Chair of the Standing Committee on Government Operations and Estimates
Sue Barnes, Chair of the Standing Committee on Finance
John
Williams, Chair of the Standing Committee on Public Accounts
Andy
Scott, Chair of the Standing Committee on Justice and Human Rights
Walt
Lastewka, Chair of the Standing Committee on Industry, Science and Technology
Paul
Steckle, Chair of the Standing Committee on Agriculture and Agri-Food
Bernard
Patry, Chair of the Standing Committee on Foreign Affairs and International
Trade
Raymond
Bonin, Chair of the Standing Committee on Aboriginal Affairs, Northern
Development and Natural Resources
Charles
L. Caccia, Chair of the Standing Committee on Environment and Sustainable
Development
Clifford
Lincoln, Chair of the Standing Committee on Canadian Heritage
Joint
Chairs Gurmant Grewal and Céline Hervieux-Payette of the Standing Joint
Committee for the Scrutiny of Regulations
ATTACHMENTS
AND ENCLOSURES
GOVERNMENT
RESPONSE TO ORDER PAPER QUESTION Q-248
http://www.cssa-cila.org/garryb/publications/Article193.htm
LIST OF THE BENEFITS OF FIREARMS OWNERSHIP
http://www.cssa-cila.org/garryb/publications/Article149.htm
LIBRARY
OF PARLIAMENT REPORT - COSTS OF ENFORCEMENT
http://www.cssa-cila.org/garryb/publications/march20,2003.doc
LIBRARY OF PARLIAMENT REPORT - COMPLIANCE COSTS - FIREARMS LICENSING
http://www.cssa-cila.org/garryb/publications/LofP-june16-2003.doc
LIBRARY
OF PARLIAMENT REPORT - COMPLIANCE COSTS - FIREARMS REGISTRATION
http://www.cssa-cila.org/garryb/publications/LibraryPaper-ComplianceCosts-Registration.doc
MARCH
11, 2001 NEWS RELEASE - ECONOMIC
COST OF THE GUN REGISTRY
http://www.cssa-cila.org/garryb/breitkreuzgpress/Guncontrol41.htm
RED-TAPE
AND TAXES DRIVING HUNTERS OUT OF THEIR SPORT COMES AT A HUGE COST
http://www.cssa-cila.org/garryb/publications/redtapetaxes.htm