Thread: Question: Retaining a licence with no firearms but without secure storage facilities

Interested to hear on any updates following on from this thread in 2022 please:

https://www.nzhuntingandshooting.co....nt-flat-87042/

I've been made aware of a forum member where the advice from the FSA is that his existing licence now needs to be surrendered, part–way through the licence period, because he is in a temporary flatting situation where it is impractical to install the security measures that he has in place at the family home and present when the licence was approved and issued. He has no firearms in his name or on-site, only using firearms when he returns home. Other family members are licenced and hold the firearms in their names securely at the home address.

I have confirmed with the FSA that this advice is based on the Arms Regulations 1992. Only the sections relevant to this forum member's situation are copied below:

Arms Regulations 1992, Clause 19: Conditions relating to security precautions

(1c) the holder must take reasonable steps to ensure that any firearm in their possession is secured against theft:

(2) The reasonable steps required by subclause (1)(c) are—
keeping on the holder’s premises—
(2)(a)i a lockable cabinet, container, or receptacle of stout construction in which firearms may be stored; or
(2)(a)iii a lockable display cabinet or rack in which firearms are immobilised so that none of them may be fired; and
(2)(b) securely fixing to the premises all locked cabinets, containers, racks, and receptacles in which firearms are stored; and

(3) The steps taken under subclause (2) must be approved by a member of the Police following an inspection carried out—
(3)(a) at the time the holder’s firearms licence is issued (or renewed); or
(3)(b) during an inspection under section 24B of the Act


Arms Regulations 1992, Clause 24B: General conditions of firearms licence

(1) Every firearms licence is subject to the conditions that the holder of a firearms licence must,—
(1)(c) permit a member of the Police to inspect the place or places where the firearms are or will be kept, and the place or places where the ammunition is or will be kept, and, for those purposes, to enter at all reasonable times upon the premises where that place or those places are situated.

Also
Arms Legislation Act 2022, Clause 55:
A holder of a firearms licence who changes their address must, within 30 days after doing so, give written notice of the change to a member of the Police.

From what I understand of the above, following receiving notification of a change of address, Police may choose to arrange an inspection of the security or they may not, but either way security that meet the above must be in place.
I'm interested in the padlocked chain placed around a secure fixture such as the hot water cylinder mentioned in the previous thread as being (perhaps not universally) accepted as sufficient security. Presumably this was accepted when there were no firearms currently at the place of residence, and that should any firearms be stored on-site in the future, they would have arrived in their own pelican case or similar that meets the secure container requirement of (2)(a)i above, and that by chaining such a container in place the requirements of (2)(b) are then also met.

Either way the opportunity to contribute to the re-write of the Arms Act is timely, and I'll put in a submission along the lines that this area could be tidied up. Cancelling and then reapplying for a licence in these circumstances seems a needless waste of resources.