Here is the letter I sent to the Globe and Mail in response to Rock's insulting letter of 14 June. Further details of the costing have already been submitted to Cdn-firearms Editor 16 June 1995 The Globe and Mail 444 Front Street West Toronto, Ont M5V 2S9 fax: 416-585-5085 Dear Editor: Re: Justice Minister Allan Rock's letter to the editor, The efficacy of gun registration [14 June] Mr. Rock writes to criticize Henry Hess's article the week earlier [Rock ignoring gun control figures, critics say [June 8]. According to Mr. Rock I belong to "the gun lobby" and can't be relied upon to "bring a touch of reality into an overwhelmingly emotional debate." I beg to disagree with this insulting depiction of myself. Unfortunately, Mr. Rock prefers to attack me personally rather than to defend his proposed legislation. The fact that I own firearms does not destroy my IQ; nor does firearms ownership have any logical relationship to one's position on bill C-68. A wide variety of people oppose bill C-68 -- including many who do not own firearms. For example, among the organization that do not support bill C-68 are: the Canadian Medical Association, the Canadian Civil Liberty Association, the Provinces of Alberta, Saskatchewan, Manitoba, New Brunswick, and Ontario, and both of the Territories. These groups are hardly part of the 'gun lobby.' Mr. Rock raised a number of points in his letter. I will try to reply to each one as briefly as I can. First, in his letter, Mr. Rock attempted to dispute my estimate that firearms registration [and the accompanying owner licencing] will cost Canadian taxpayers around $1 billion. Mr. Rock continues to mislead the Canadian public. His claim that universal firearms registration would cost $85 million is demonstrably false, and Mr. Rock knows it. When Quebec recently asked for $300 million for its share of the costs for registering firearms, Rock grudgingly admitted that $85 million only referred to the costs of setting up the central registry in Ottawa. The provinces would have to pay the lion's share of the costs: that of enforcing the law. Mr. Rock claims my estimate of the costs is flawed because it is based upon an outdated registration system. This is misleading. My estimate is based upon 4 independent methods, including the present handgun registration system. All 4 approaches yield approximately the same result: universal firearms registration will cost taxpayers between $750 million and $1.5 billion. The 4 methods that I use to estimate the cost of universal registration are: [1] requests for funding made by the provincial governments to cover their share of the costs of registration, [2] the costs incurred by the current method of registering handguns, [3] estimates made by knowledgeable experts inside the Justice Department or Provincial Attorneys General, and [4] a time-motion study of the procedures required to register firearms. [See the appendix to this letter for a more detail discussion of these estimation approaches.] Many Canadians oppose universal registration as it would be a costly failure. No Canadian will be safer if this bill becomes law. The high cost of firearm registration would just divert money from more important social services that really can save lives. Second, Mr. Rock did not attempt to defend the claim that universal registration would reduce violent crime; all he could do is to list the number of countries [and Australian states] that register firearms. He fails to mention that numerous police reports in Australia, New Zealand, and the United Kingdom that have recommended the abandonment of universal firearm registration as being expensive and not very useful. Mr. Rock can not easily dismiss the case of New Zealand. New Zealand abandoned firearms registration in 1983 because the police felt it wasn't useful. The problem in New Zealand wasn't a lack of computer networks, as Mr. Rock claims. Modern computers wouldn't have helped. The basic problem with registration concerns the high cost of entering accurate information. Solving that problem of accuracy means hiring people to check each and every firearm in order to verify the identification information and serial number. Many firearms have duplicate serial numbers or do not have a serial number. Remember: Garbage in, garbage out. Third, Mr. Rock claims that there is a correlation between between firearms availability and firearms deaths, and he cites a discredited Swiss law professor, Mr. Killias, as having 'demonstrated' this link. Unfortunately for Mr. Rock, Mr. Killias did no such thing. In a startlingly incompetent article, Mr. Killias claimed to have demonstrated such a link, but he did not manage to accomplish this. Mr. Killias carefully selected a few countries that could support his claim, and excluded those that did not. Not satisfied, he even split the United Kingdom, evidently because it supports his claim, into three separate regions, and then includes all three of these pieces in his 'international' study as well. Mr. Killias also violated basic statistical rules in his study in order to arrive at his conclusions. Curiously, this 'criminologist' prefers to publish in medical 'coffee table' magazines, rather than in reputable criminology journals. This is an expert? In conclusion, I agree with Mr. Rock on one thing, we need more 'reality' injected into the debate on gun control. Unfortunately, it will not come from him. If the motivation of gun owners can be questioned, then so can the motivation of the gun banners. Mr. Rock's letter is another example of how emotional this debate has become. Canadians must hope that the Senate, as the repository of 'sober second thought' will be able to introduce the 'reality' into this debate that is so sorely needed. Respectfully yours, Gary A. Mauser Professor Appendix The 4 methods that I use to estimate the cost of universal registration are: [1] requests for funding made by the provincial governments to cover their share of the costs of registration, [2] the costs incurred by the current method of registering handguns, [3] estimates made by knowledgeable experts inside the Justice Department or Provincial Attorneys General, and [4] a time-motion study of the procedures required to register firearms. [See the appendix to this letter for a more detail discussion of these estimation approaches.] First, provincial funding requests. Two funding requests by the provinces [Quebec and Alberta] have been made public. The province of Quebec has requested $300 million from the federal government to cover the costs this single province expects to incur in registering the firearms in that single province. Since Quebec has approximately, one-quarter of the Canadian firearm population, this yields an estimate of $1.2 billion for the total cost of registering all firearms in Canada. Alberta has asked for even more: $500 billion. Presumably, the Provincial Attorneys General anticipate additional problems in enforcing this extremely unpopular requirement. Other provinces, Ontario, New Brunswick, Saskatchewan, Newfoundland, Manitoba have expressed concerns about the high costs of firearms registration, but they have not made estimates public. Second, a report by Mr. Terry Wade in Mr. Rock's own Ministry found that it cost the government around $82 to register each handgun. Third, leaks from people inside the Justice Department and various provincial Attorney Generals' offices suggest that, under the firearms registration system proposed by Rock, they will not be able to register long guns any more cheaply than the current cost of registering handguns, $82 per firearm. Since there are between 5 and 25 million firearms remaining to be registered in Canada, this yields an estimate of registration at least $400 million. Fourth, time-motion studies. To register a firearm properly, the firearm must be physically inspected by a person who is knowledgeable about firearms . This means that practically speaking, owners must bring their firearms to the local police station to be inspected before being registered. Probably, this will be the local Firearms Registrar at the local Police Department or RCMP Detachment. Since not all local firearms registrars will be familiar with all possible firearms that they will be asked to inspect, Ottawa must double check each firearm to confirm the accuracy of the registration. If this is not done, the registry will contain so many errors as to render it useless to the police. If there are no problems, then this process will take about two hours per firearm. However, there will be problems. Approximately one-third of all firearms do not have serial numbers; these will have have serial numbers added. Many firearms have duplicate serial numbers. These will have to be identified and additional numbers or characters added in order to assign each firearm a unique serial number. Other firearms have unique serial numbers in languages other than English. How will serial numbers in Arabic or Cryllic or Chinese be dealt with? Therefore, when these problems are factored in, I estimate that it will average around 3 hours to register each firearm. If police clerks earn around $25 - $30 per hour [including benefits], then it will cost between $75 and $90 to register each firearm. This confirms the earlier cost estimates. All of these methods arrive at approximately the same amount. In addition to registering firearms, Bill C-68 proposes to licence each and every firearm owner. At the present, only 1 million firearms owners have a current FAC. There are at least 2 million firearms owners who will need to be investigated in order to be issued a new FPC. It will cost at least as much to issue an FPC as it does currently to issue an FAC. Estimates vary from $100 to $185 to issue a new FAC. This process involves a police check, interviewing the prospective firearm owner as well as both of his or her references. This means that it will cost between $200 million and $370 million to licence all firearms owners in Canada. For a still more complete discussion of the costs of bill C-68, please see my paper, "An Outline of a Cost/Benefit Analysis of the Proposed Firearms Owners Licence and Universal Firearms Registry" that I presented to the Standing Committee on Justice and Legal Affairs, House of Commons, May 15, 1995. Gun registration: The Home Shopping Network for burglars. Gary