Brief to the Standing Senate Committee on National Security, Defence and Veterans Affairs C-21 –

An Act to amend certain Acts and to make certain consequential amendments (firearms) Statement by Didier Deramond General Manager Association des directeurs de police du Québec November 20, 2023 2 Mr. Chair, Committee members, The Association des directeurs de police du Québec (ADPQ) thanks you for the opportunity to comment on Bill C- 21. First, let me remind you that our association, representing all Quebec police chiefs, would like to raise a few concerns about the new version of Bill C-21 in light of rising gun violence in Quebec and the history of firearms use in mass killings.

Before going any further, the ADPQ wants to make it clear that it supports the changes that were made to the bill. These include “ghost guns,” regulations to restrict high -capacity magazines and the creation of an expert advisory committee to independently study the classification of firearms currently on the Canadian market. That said, although many amendments have been made since we last appeared before your committee , the ADPQ believes that new provisions need to be included in the current bill to ensure that the new version of the law has the desired effect. Let me explain.

Currently, anyone with a Possession and Acquisition Licence (PAL) can buy not just the calibre of ammunition they want, but also any quantity of ammunition they want, even if it is concerning. In other words, an individual can buy ammunition for a calib re of a weapon they do not own and buy 200 if they so choose. In addition, simply possessing ammunition is not an offence. I am sure you will agree that this is a major problem given the growing number of illegal and 3D -printed firearms on our territory.

The ADPQ strongly believes that: o there must be a connection between an existing firearms licence and ammunition; and o an ammunition purchase register must be created. Likewise, given that firearm parts critical to making firearms operational have no serial number and that there is NO ban on owning them, anyone can store them. The ADPQ believes it is vital to ban owning firearms parts unless they have first been authorized by the Registrar.

This is why the ADPQ also believes the federal government should require manufacturers to issue a serial number on critical firearms parts, ensuring they can be traced. 3 Dear Committee members: If the current bill were amended with these four new provisions: o ensure there is a connection between an existing firearms licence and ammunition; o create an ammunition purchase register; o ban owning firearms parts without a licence; and o require firearms parts manufacturers to issue a serial number. Quebec’s police chiefs believe this bill is better suited to the current situation and would have a greater impact.

I would also like to share some of our other concerns with you. As our president told you when he last appeared, some provisions of the bill need to be aligned with Quebec legislation. In Quebec, we have the Act to protect persons with regard to activities involving firearms. This law, which requires certain timeframes for implementation, makes the 30-day deadline for revoking firearms under federal law nearly impossible. Some firearms remain in circulation simply because federal law does not square well with Quebec provincial law.

The ADPQ therefore recommends to committee members that the 30-day timeframe for revoking a firearm be increased to bring federal and provincial laws in line with each other. Finally, the ADPQ is deeply concerned about police officers’ knowledge of firearm laws. According to a survey by the Service du renseignement criminel du Québec (SRCQ): 65% of police officers say they have little knowledge of the Firearms Act. 85% of these same police officers feel they could be better trained on firearms. These percentages, which are admittedly extremely high, show that police training on firearm laws must be expanded.

That is why the ADPQ recommends special atten tion be paid to funding police training when laws are amended. The ability of law enforcement to enforce laws is too often overlooked. The ADPQ would like to reiterate the need for additional funding in some areas, such as mixed teams, firearms inspectors and laboratories, to name a few. In closing, while the ADPQ applauds this bill, it would like to point out that Bill C-5 was passed. It removes minimum penalties on certain firearms offences by increasing maximum penalties.

This seems somewhat at odds with the current bill. 4 Messaging must be consistent with the goal of making our communities safer. Unlike other countries, gun ownership must remain a privilege, not a right. Consistent messaging must also inevitably be directed at young people ( Youth Crim inal Justice Act ), especially when we know that it is young adults who all too often use and normalize firearms. Finally, ADPQ acknowledges the noble intention of the current bill and reiterates its support, albeit with a caveat.

We would like to reiterate that, to ensure safety, it is imperative for the federal government to make amendments to the current bill by including: o a connection between an existing firearms licence and ammunition; o an ammunition purchase register (even if it is quite difficult); o a ban on owning firearm parts without a licence; and o a requirement for firearms parts manufacturers to issue a serial number. Thank you. I am available to answer any questions you may have. Didier Deramond General Manager ADPQ