Tag Archives: impact assessment

European Commission: Banning bullets – do it for the Birds!

Trying to ban guns was not successful – next: Ban on bullets!

EU Commission has asked ECHA (European Chemical Agency) to conduct study and consultation to ban lead bullets. [1] To avoid mistakes done with misguided firearms directive, like missing impact assessment, they have started a public consultation for restrictions of Lead in shot in wetlands AND ”Any other uses of lead ammunition (than lead in shot in wetlands), including hunting in other terrains than wetlands and target shooting. Lead weights for fishing.”

According to their statement ”Modern lead-free ’gunshot cartriges, such as steel cartridges, are suitable for all types of hunting in wetlands and are widely available.”

In other words, EU is currently asking for public feedback on commission plan to ban lead (and copper) on ammunition – using the environment as an excuse.

The attempt to ban concerns [2] ammunition which contains lead in concentrations greater than 1% by weight, for shooting with a shot gun within a wetland or where spent gunshot would land within a wetland, including shooting ranges or shooting grounds in wetlands. And in addition there is another parallel study on restriction on ”other ammunition” meaning lead-based rifle and pistol ammunition. In other words – pretty much all ammunition.

Problem 1:
The definition used for defining the wetland is the following [1]
“areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres”.

The Ramsar definition of wetlands is a comprehensive and internationally recognised definition but it means that lead bullets will be banned up to 24,3% of surface area in for example Sweden.

Problem 2:
All current rifles would not be usable anymore. This includes pistols as well. Long range shooting would become impossible for civilians. This is because for any kind of accuracy bullet stability is essential. The issue comes from barrel twist, which is usually calculated with Millers formula which is slightly improved version of classical Greenhill formula, which indicates that bullet material density matters – when for example calculating values for .308, for which barrel twist is usually 12 inches with traditional lead ammunition, corresponding rifle twist for example copper bullets would be about 9,5 inches. This means that your expensive rifle just became unsuitable for ammunition currently available.

Problem 3:
In addition to this – its not only hunters who are going to be royally shafted with this restriction:
It pretty much makes sportshooting impossible by banning .22 ammunition, which we all know is mostly lead.

Problem 4:
Steel, which is considered to be suitable ”cheap” enough alternative wears out barrels like there is no tomorrow.

Problem 5:
It is also classified in many countries as armor piercing round material, which means steel bullets are banned.

Problem 6:
Not all shotguns are rated for steel shots. The hunters would have to in some cases buy new shotguns.

According to commission, all of this is ok, because it provides ”Increased (long-term) opportunitiesfor birdwatching.” [2]

Solution:

The public consultation on this proposed restriction will start on 21 June 2017 and end on 21 December 2017, which means that YOU should provide feedback as soon as possible to by reading and providing information according to document [2] .

It is of utmost importance to get involved in this, both on as individuals, and as hunting and sport-shooting organizations because, ECHA considers only the environmental perspective – which according to past does not pain a pretty picture.

For example banning of copper shots has been already proposed. The biggest problem, according to our sources is that at the moment is that for example Danmarks Jaegerforbund lobbies hard for banning lead ammunition by sending out strong signal that lead can be replaced easily in all ammunition, including .22. In addition to this, they claimed that NORMA is already researching steel ammunition for other calibers for civilian market. According to ECHA, there should be zero-tolerance for lead, which means most likely long term campaign

What can I do:

– Spread information. Get your own hunting and sport shooting association to participate and provide their statement for the public consultation! Provide statement as an individual. Clock is ticking!

Would you like to know more?
Check our partner Gunsweek’s article about this particular topic:

https://www.gunsweek.com/en/current/news/lead-ammo-ban-eu-it-again

References:

[1] https://echa.europa.eu/fi/addressing-chemicals-of-concern/restriction/echas-activities-on-restrictions/current-activites-on-restrictions

[2] Public Consultation:
https://echa.europa.eu/documents/10162/d7fb96cf-7956-7406-3568-399ca20151e0

[3] https://www.gunsweek.com/en/current/news/lead-ammo-ban-eu-it-again

Picture: Courtesy of Gunsweek

Our Impact Assessment

The European Commission has so far failed to support the EU Gun Ban plans with an impact assessment – most likely because carrying on an impact assessment would cripple the gun ban plans, as its outcomes would seriously contradict the anti-gun agenda. Two members of the first panel brought on their own evaluation, with facts and figures, that were the true centerpieces of the event.

Katja Triebel, head of research for the Firearms United network, introduced her own impact assessment – a document drafted closely following the EU impact assessment guidelines, largely based on many of the documents that the European Commission is trying to use to justify its ban plans, and impressive both in terms of detail and sheer workload that was necessary to generate it.

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Every proposal must be based on an impact assessment study and a debate

FIREARMS UNITED Conference – Dita CHARANZOVÁ MEP – ALDE

I am in the EU business for more than 12 years.

I was hoping that the Commission under the president, Mr. Juncker, will follow the Smart regulation principle. Unfortunately this piece of legislation is not, what I consider of smart regulation.

Every proposal for legislation must be based on a impact assessment study and broad public debate. This was not the case.

I am happy that the European Parliament took on board many concerns – all what you (guest) mentioned. And we are ready to continue to work with you. Because at the end – what I want to achieve – is to have something which makes sense, which is implementable and which can also be enforced in the Member States.

It is very unfortunate that we recieved the data from the Member States and the Commission only recently. And they clearly shows that the concerns that you (guests) raised are fact based.

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FIREARMS UNITED’s Answer to the European Commission

FIREARMS UNITED commented and critized the 3 studies and arguments of the European Commission

  • cropped-001_LOGO_FU_WCGO.jpgMissing Impact Assessement
  • 10.000 homicides
  • Risk of legal ownership
  • 500 000 “stolen” firearms
  • Deactivated firearms
  • Conversions of semi-automatic firearms

Read our facts for above “arguments”:  Continue reading