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Telephone: (613) 941-5995 or 1-800-635-7943 Fax: (613) 954-5779 or 1-800-565-7757 [email protected]
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MAIL POSTE
Canada Post Corporation / Société canadienne des postes
Postage Paid Port payé
Letter mail Poste-lettre
1782711 Ottawa
If undelivered, return COVER ONLY to: Publishing and Depository Services
Public Works and Government Services Canada Ottawa, Ontario K1A 0S5
En cas de non-livraison,
retourner cette COUVERTURE SEULEMENT à : Les Éditions et Services de dépôt
Travaux publics et Services gouvernementaux Canada Ottawa (Ontario) K1A 0S5
Disponible auprès de :
Les Éditions et Services de dépôt
Travaux publics et Services gouvernementaux Canada Ottawa (Ontario) K1A 0S5
Téléphone : (613) 941-5995 ou 1-800-635-7943 Télécopieur : (613) 954-5779 ou 1-800-565-7757 [email protected]
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Mounted Police du Canada
Security Classification/Designation Classification/désignation sécuritaire
RCMP GRC 2823 (2002-11) WPT
TO/DEST: Superintendent Laurent Cyr Your File - Votre référence
Director of Operations
FROM/ORIG: Rob MacKinnon Our File - Notre référence
Manager, Business Support & Improvement
Date: November 13, 2008 Phone: (613) 843-5444
SUBJECT/OBJET: Impact of Bill C-24 on CAFC Operations
Introduction
The intent of this briefing note is to present a high level analysis of the impact of Bill C-24 on the resource requirements for the Canadian Firearms Program.
Background
On June 19, 2006 the government tabled Bill C-24, an Act to amend the Criminal Code and the Firearms Act (non-registration of firearms that are neither prohibited nor restricted). This Bill proposes to repeal the legislative responsibility to register non-restricted firearms and introduce the requirement for firearm retailers to record all sale transactions of these firearms. The Bill is still to be scheduled for a second reading and presented to committee.
A clause by clause analysis of Bill C-24 was performed (see Appendix B) which revealed that Bill C-24 will influence the registration, transfer and import/export functions of the Canadian Firearms Program. As a result, the operational areas impacted are the Canadian Firearms Registry (CFR), the Central Processing Site (CPS), the offices of the Chief Firearm Officer (CFO) and possibly the Canada Border Services Agency (CBSA) when all of the import/export provisions come into force.
In order to establish the impact on resources a model was constructed (see Appendix A) which estimates the number of resources in the current environment that support the registration and transfer functions. This model creates a bench mark that allows a comparison to be made if Program activity is altered as a result of Bill C-24 coming into force.
The Model
The model focuses on the registration and transfer processes and uses transaction volumes, estimated timings per transaction and working minutes per Full Time Equivalent (FTE).
Activity Source
Transaction Volumes Compiled from the CFIS database using the 2005 calendar year Timings per
transaction
Constructed in consultation with the CPS, the CFR and using the established timings within the Contribution Agreements with provincial Chief Firearms Offices.
Working Minutes Industry standard methodology of:
72,600 working minutes (1,210 working hours) per year per FTE
• Based on:
o 220 working days per year
o 330 working minutes (5.5 working hours) per day per FTE
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RCMP GRC 2823 (2002-11) WPT
Category Activity
Pre-Bill C-24 Reflects FTE requirements assuming:
• the processing of registrations & transfers includes restricted, prohibited and non-restricted firearms (current environment).
Post-Bill C-24 (Classification)
Reflects FTE requirements assuming:
• the processing of registrations & transfers for restricted and prohibited firearms will remain.
• the removal of registration for newly imported and newly manufactured non-restricted firearms for individuals and business, therefore the Program will not be made aware of these: and
• during a transfer of a non-restricted firearm:
o the validity of the transferee will be confirmed;
o the collection of firearm details will be required to ascertain the
“kind” (class) of firearm (applying section 27(a)(i)(ii)(iii) of Bill C-24); and
o a CPIC check will be performed on the firearm to determine if it has been reported as lost, missing or stolen (Policy decision since we are collecting the firearm details anyway)
Post-Bill C-24 (No Classification)
Reflects FTE requirements assuming:
• the processing of registrations & transfers for restricted and prohibited firearms will remain.
• the removal of registration for newly imported and newly manufactured non-restricted firearms for individuals and business, therefore the Program will not be made aware of these: and
• during a transfer of a non-restricted firearm:
o the validity of the transferee will be confirmed; and
o the collection of firearm details will not be required (applying section 27(a)(i)(ii) of Bill C-24)
Analysis
The model was constructed using actual annual volumes and timings per transaction derived through consultation. The FTE requirements that are provided for the current environment are based on a formula, which establishes productivity based on these volumes and timings. In order to ensure an accurate measurement, the same model was used to calculate FTEs for a post C-24 environment. Volumes were adjusted accordingly to reflect the removal of non-restricted firearms and timings were adjusted to reflect the alteration in process. Since the same formula was used to calculate FTE requirements for a C-24 model, it provides an equivalent means in which to compare against today’s requirements. For this reason, the amount of FTEs required, as well as the percentage increase or decrease, has been provided.
It should be noted that the model calculates FTE’s based on throughput and does not take into consideration CPS shift work, (which includes weekends and stat holidays), as well as maintaining bilingual service at all times during hours of operation. This therefore provides a statistic of CPS FTE’s, in a current environment (Pre-Bill C-24), that is actually lower than what exists. While this anomaly would affect the FTE counts, it would not affect the percentage increase or decrease in a post Bill C-24 environment. For this reason, it is more important to focus on the percentages rather than on the actually FTE results for CPS.
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RCMP GRC 2823 (2002-11) WPT
A summary of the analysis is presented in the below noted table.
Department Amount of Full Time Equivalent (FTE) required Pre-Bill C-24
(Current)
Post Bill C-24 (Classification)
Post Bill C-24 (No Classification)
CPS 24.53 38.55
(57.17% increase)
11.95 (51.29% decrease)
CFR 39.74 7.17
(81.95% decrease)
6.35 (84.03% decrease)
CFO 3.87 7.01
(81.26% increase)
7.01 (81.19% increase)
Total 68.14 52.73
(22.61% decrease)
25.31 (62.87% decrease) Full details of the analysis are included within the actual model (see Appendix A). A “Resource Summary” (page 9 of the model) also depicts the FTE financial impacts which are based on position classifications for each activity.
Conclusion
The implementation of Bill C-24 will ultimately decrease the overall required resources associated to the registration and transfer activities. If there is a requirement to establish the “kind” (or class) of firearm, prior to the firearm being transferred, (as outlined within the scenario titled “Post Bill C-24 (Classification)”, the percentage decrease would be significantly less than the alternative (as outlined within the scenario title “Post Bill C-24 (No Classification).
While the focus of this exercise was on determining the impacts on FTEs, in performing the analysis it was recognized that additional risks should be identified if C-24 were to come into force.
• The process will become extremely cumbersome for CPS, as well as the client under the
“Post Bill C-24 (Classification) option, if the Program is required to collect firearm details each time a firearm is transferred. It is also envisioned that this process would dramatically decrease the compliance rate if implemented.
• Since the firearm data will not be retained (in either transfer scenario), but purged once approval is granted, there will be no evidence that the CFO authorized the transfer based on the fact the firearm was in fact non-restricted.
• On the revocation of a licence the CFO or police will not be able to determine the total number of firearms owned by the individual or business.
• An inspector examining firearms of an individual will not be able to obtain a list of the total number of firearms located at any given address.
• A CFO will not be able to determine if an individual has been in continuous possession of a firearm since 1998 when processing an application for the renewal of a POL.
• As non-restricted firearms will no longer be recorded in the CFIS database there will be no ability to perform continuous eligibility on those firearms (CPIC firearm events).
• If a CFO refuses to authorize the transfer of a non-restricted firearm, there will be no record of the refusal in the CFIS that the CFO can rely upon should the client appeal the refusal since the firearm data will not be retained.
• Non-restricted firearm information will no longer be available to the police via the CFRO.