UPDATE: On the IRR of RA 10591
Just as an update today we participated in the Public Consultation Hearing for the PNP Draft of the Implementing Rules and Regulations. Notably, a number of people who showed up complained that they were neither invited to participate nor informed. Nevertheless, in the limite time of less than two hours that was allotted to the open forum, a number of stakeholders inckluding PROGUN were able to give their brief suggestions, albeit incomplete, orally, while reserving our right to submit a written position paper or draft suggestions to the IRR Secretariat. According to the PNP, all drafts and suggestions "will be considered and noted", but not necessarily approved to be included. Additional public consultations will be held for regional stakeholders and concerns.
PROGUN will be submitting its position paper in conjunction with allied organizations such as Pinoyguns and Lock n Load.
In sum, we noted the following:
We scored a number of victories in this IRR. But some negative points have remained:
1. Gen. Gil Meneses stated that the SAME FEES that are being charged now, will continue to be charged under the new law. So, since the draft IRR of the PNP states that the fee for ALL TYPES of licenses shall be THE SAME, then it will definitely be cheaper for us who own several guns.
2. The 50 rounds limit exempts "licensed sport shooters". The problem is that the draft PNP IRR states that a separate license fee shall be charged for licensed sport shooters. My suggestion was that an exemption be made also for GUN CLUB members. So effectively the term "licensed sport shooters" be expanded to include gun club members, which I believe is the real intention of the law. The wording was just flawed.
3. The definition of "imminent threat" is vague and has to be re-worded. Not clear and too complicated.
4. Due to lack of time, we weren't able to tackle the issue of PTCFOR and PTT. But from the wording of the draft IRR, PTT is still available; it is just not clear if it is going to be for one event only or for 3 months or more. PTCFOR also has to be clarified whether one PTCFOR can be used for several guns or for one gun only.
5. The list of those professionals who are exempt from the Imminent threat requirement, was expanded to include "Other profession or occupation that the PNP may consider to be in imminent danger.", which is favorable to licensed gun owners.
6. The PNP confirmed that current unexpired licenses shall BE RESPECTED, until a five year transition period, after which everyone shall already be issued their new licenses under the new law.
7. Amnesty for loose and expired gun licenses shall be within 6 months after the IRR is passed. So if your licenses are expired, just wait and renew them during the amnesty period, it will be cheaper for you.