Submission on the. Submission

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on the Page: Two We support the 'Intent' of this bill as it addresses the importation of 'Airsoft' guns in a practical and workable way. As an organisation we utilise 'Airsoft' guns in our business at various levels, and an efficient importation process is important to our ability to function. As a business we operate primarily in the tourist and adventure recreation sectors. As you are aware prior the Christchurch earthquakes tourism contributed $2.3 billion to the annual Canterbury economy with an average per person daily spend of around $200. We have already been responsible for hosting groups from overseas as we offer something very unique. Along side 'Airsoft' gaming we also provide guns, equipment, special effects, training, and technical advice for film and media projects, events, and public displays. For our business to continue to grow and expand we need access to 'Airsoft' guns. It is our aim to help to convince overseas visitors to come back to Christchurch and to continue to promote our home city. As an organisation we also help promote and develop the sport within New Zealand. Growing annually 'Airsoft' is becoming a more recognised sport represented by anational Body and with in excess of 25 clubs nation wide. In formulating this submission we have consulted not only with ASNZ (the National Body) but with our suppliers, overseas clients, our local fire arms licensing officer, and 'airsoft' players in New Zealand. Unlike other gun related activities 'Airsoft' can boast a 100% non fatality, non serious injury record and is a safe and very sensible way of being able to promote and install safer gun handling and use practices. We would like to put forward for your consideration a few suggestions that we feel could make the bill work a little better. In all matters our suggestions are intended to support the bill and its passing into law.

on the Page: Three Special Reasons to Import: We support the general 'Intent' of these but we would like to see the following added so that there is no grey area for us as abusiness when applying for apermit Permit to import 'Restricted Airgun' Permit to import 'Restricted Airgun Parts' special reasons, document clearly by adding the following so as to give just cause to obtain a permit to import 'Airguns' that the bill has arbitrarily re classified as being 'Restricted Airguns' for 'Restricted Airguns', if the importer is a registered fire arms dealer, or the operator of a business that utilises 'Restricted Airguns' for the sole purpose of conducting business and who holds a 'Dealers License'. special reasons, document clearly by adding the following so as to give just cause to obtain a permit to import 'Airgun Parts' that the bill has arbitrarily re classified as being 'Restricted Airgun Parts' for 'Restricted Airguns', if the importer is a registered fire arms dealer, or the operator of a business that utilises 'Restricted Airguns' for the sole purpose of conducting business and who holds a 'Dealers License', or an approved 'Gun Smith'. Create two new clauses: We would support the 'Intent' of two new clauses aimed at restricting the ammunition that could be legally used in Airguns' one creates an 'offence' increasing Police powers of control whilst the other creates a limiting restriction Non approved ammunition (Airgun) The Offence: new offence, document clearly by adding the following so as to make it an 'offence' to use any ammunition in a 'Restricted Airgun' designed for the sport of 'Airsoft' that is not approved. every person commits an offence and is liable on summary conviction to a fine not exceeding or seizure of their 'Restricted Airguns' ~ or both who uses non approved ammunition.

on the Page: Four Create two new clauses (continued): We would support the 'Intent' of two new clauses aimed at restricting the ammunition that could be legally used in 'Airguns' one creates an 'offence' increasing Police powers of control whilst the other creates a limiting restriction Approved ammunition (Airgun) Definition: the definition, document clearly by adding the following so as to set a safe fps limit that will help protect the public, law enforcement officers, and end users. approved ammunition, only spherical plastic or bio degradable ammunition of the required calibre may be utilised in 'Restricted Airguns' designed for the purpose of 'Airsoft'. Qualifying to import: We feel that current workload of inspections currently faced by NZ Customs would simply transfer itself into a large volume of 'Permit' applications to be processed by the NZ Police. We would like to offer as an alternative the reduction in eligibility to obtain a permit. Club members importing a 'Restricted Airgun' airsoft club member, being a member of an airsoft club should not be sufficient reason to import a 'Restricted Airgun'. this is to both reduce the number of possible permit applications and ensure that both the requirements and intent of the act are complied with. Club members importing 'Restricted Airgun Parts' airsoft club member, being a member of an airsoft club should not be sufficient reason to import 'Restricted Airgun Parts'. this is to both reduce the number of possible permit applications and ensure that both the requirements and intent of the act are complied with. It is also intended to prevent the illegal upgrade of a 'Restricted Airgun'.

on the Page: Five Remove 'Restricted Airguns' from the 'Restricted Weapons' list: So as to reduce any continued possible burden to NZ Customs that may occur from having to ensure that any 'Restricted Aīrgun' does not fail into another category requiring boarder control 'Aiguns' regardless of action or cycle, i.e fully automatic firing, should no longer be included in the 'Restricted Weapons' list. Restricted Weapons list Permitting Restriction Restricted airguns that are capable of fully automatic function be de classified as a 'Restricted Weapon'. Reduction in 'Boarder Control' commitments by NZ Customs. That the permitting process require the applicant to provide just and reasonable cause to import a 'Restricted Airgun' that is capable of 'Fully Automatic' function at the time of importation. To allow the NZ Police to prevent persons without just and reasonable cause to import a 'Restricted Airgun' of this type. This would include irresponsible, reckless, or illegal use. Recommendations: Given the enclosed submissions that we have made we would like to make the following recommendations 1) 2) 3) 4) The reasons for importation of a 'Restricted Airgun' be documented to include dealers. That ammunition be regulated to protect the police, public, and end users. That importation be restricted to licensed dealers and ASNZ approved armourers. That permitting be a part of the importation process. Additionally to these recommendations we would like to add the following, it is these recommendations that we would especially like to speak on 1) 2) 3) 4) That 'Internet' trading of 'Restricted Airguns' be banned. That ASNZ (Airsoft Sport New Zealand) be recognised as the consultative body for 'Airguns'. That ASNZ be required to establish a regional Armourers' system to facilitate and maintain the legal importation of 'Restricted Airguns'. That a 'National' interpretation of the amendment and its application be made available to ASNZ and all stake holders. In conclusion we would once again like to record our support for the bill that you are considering.

& on the Page: Six Special Considerations: Annually NZ Customs face processing numerous small consignments from many individuals within New Zealand, This not only places a huge work load on them but often most of these consignments are put together to remain under the GST threshold for importation. Not only are there guns but also gun parts and accessones. Many consignments are from people who do not play 'Airsoft' as a sport but who want to own a gun for various reasons, or are from people who intend to conduct illegal internet trading. We would like to suggest that by restricting the ability to qualify to import 'Restricted Airguns' the following benefits could be reasonable expected. 1) Larger consignments by dealers and armourers that will breach the GST threshold thus generating a GST revenue for Government. 2) A lower amount of permit applications for NZ Police to process. 3) A better control of end use and ability to acquire as persons loose their ability to import. abusing the legal requirements would quickly 4) The likelihood of use by persons not having just cause would be diminished as the only place they could obtain Restricted Airguns' would be outside of a ASNZ club from a Licensed Fire Arms Dealer. 5) A reduction in illegal internet trading. Persons with a history of these actions would not be able to import. 6) A legitimate and open promotion of the sport that would openly include NZ Police, NZ Customs, and Government participation could be begun. This would in turn help ASNZ to establish a set of National Standards. 7) A better ability to prevent or restrict illegal modification as parts also are controlled. We would fully support any recommendation to re define the interpretation of 'Supply' in the Arms Act to include 'For Use' This would require any persons providing a 'Restricted Airgun, Paint Ball Gun, etc' for use to apply for and obtain a Fire Arms Dealers License. We believe that this can only help to promote better and safer commercial operations (such as ours) and help set a set of national standards. Greater safety and compliance for all.