OFAH letter to Minister Blair on PAL renewals
On July 21, 2020, the OFAH sent the following letter shown below to Minister of Public Safety and Emergency Preparedness, Bill Blair.
Dear Minister Blair:
OFAH members and the broader firearms community are becoming increasingly concerned with the backlog in Possession and Acquisition Licence (PAL) application and renewal processing. We have expressed these concerns in recent weeks, but are now formally asking the federal government to implement a temporary solution(s) that will allow firearms owners with licences that expired while services were interrupted (and likely immediately prior to that period) to continue to hold a valid licence until a time that the licence processing backlog can be resolved.
The OFAH acknowledges the impact COVID-19 has had on many services, and supports the need for the federal government to implement measures intended to protect public service employees. Therefore, our concerns are less focused on the licence processing delays themselves, and more on the implications it will have for the ability of responsible firearms owners to enjoy hunting, trapping, and sport shooting activities this year.
Currently, the Firearms Act has a six-month extension period upon licence expiry that allows owners to retain their firearms. This ensures that simple possession (even while properly stored) does not put responsible firearms owners in a non-compliance situation; however, it doesn’t allow them to buy, sell, transport, or use firearms during the extension period. This means that potentially thousands of licence holders won’t be able to hunt this fall, practice at the range, or carry a gun while engaged in regulated trapping activities.
Activities like hunting, trapping, and sport shooting are incredibly valuable for the social and mental well-being of millions of Canadians, and are more important now than ever as a break from the challenges we face individually and as a society during these difficult times. Canadians need hunting, trapping, and sport shooting right now.
Hunting, trapping, and sport shooting result in almost $9 billion in spending and contribute $6 billion to the GDP, while supporting 47,000 jobs and almost $3 billion in labour income. Canada needs the hunting, trapping and sport shooting industries to remain strong as we recover from the COVID-19 pandemic.
The government is better positioned to determine the exact legislative and/or administrative steps needed to alleviate this issue, so we won’t attempt to prescribe the best possible solution. We do, however, recommend that the government explore all possibilities, and we offer some approaches for consideration.
The introduction of Bill C-20 in Parliament yesterday, if passed, may present the simplest means to alleviate the issue with licence renewals. In particular, the Time Limits and Other Periods Act (COVID-19) included in the bill would enable you as minister to extend the period during which a licence is valid. We commend the government for proposing measures that will help keep Canadians from being penalized for things that are out of their control, and specifically for including the Firearms Act as legislation that these licence extensions can apply to.
The purposes of this legislation is to: 1) prevent any exceptional circumstances that may be produced by coronavirus disease 2019 (COVID-19) from making it difficult or impossible to meet those time limits; and 2) to temporarily authorize, in a flexible manner, the extension of other periods in order to prevent any unfair or undesirable effects that may result from the expiry of those periods due to those exceptional circumstances. These purposes directly fit the PAL processing backlog issue, and the ministerial order making powers proposed in the Time Limits and Other Periods Act (COVID-19) would go a long way to resolve the concerns we have. We strongly encourage you to exercise these powers as soon as possible upon Bill C-20 receiving Royal Assent.
If the proposed Time Limits and Other Periods Act (COVID-19) is not enacted or experiences any significant delay, then we encourage the government to explore all other possibilities, including an expansion of the parameters of the existing extension period to include use and acquisition.
Regardless of what solution is used, the government should also clarify what “proof” of a valid licence is required. This has been a significant source of confusion for firearms licence holders, particularly when significant backlogs occur. For example, if a “renewal” was interpreted to mean that a licence had been processed and is valid, even without being in receipt of the PAL card, then could an email confirmation be considered a temporary licence until a physical one is received in the mail?
Bill C-20 and other possible approaches described above will not mitigate the challenges experienced by new applicants, so we recommend the government explore all opportunities to facilitate Canadian Firearms Safety Courses within public health guidelines, and establish a plan to help new or aspiring firearms enthusiasts to get a licence as quickly as possible after submitting an application.
The OFAH strongly encourages the federal government to take quick action to resolve these issues, and we are willing to work with you to find solutions that will keep Canadians hunting, trapping and sport shooting.
Thank you in advance for your consideration.
Yours in Conservation,
Manager, Fish & Wildlife Services