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Comments and Suggested Inputs to the PNP Draft Implementing Rules and Regulations for RA 10591

Hereunder are our comments and suggested inputs for the Draft PNP Implementing Rules and Regulations for RA 10591. These comments and suggestions were arrived at a joint effort by PROGUN, Pinoyguns, Lock n Load, and allied organizations and supporters, after several months of discussion and consultation. Please note the following:

1. In spite of our request, we are not members of the technical working group of the PNP (TWG-PNP) for the drafting of the IRR, which we understand is being done under a closed-door policy. We disclaim that we have any direct participation in this process of discussing and drafting the IRR apart from these comments and our attendance at the PNP Open Forum at Camp Crame.

2. Nevertheless, we understand that TWG-PNP is accepting comments and suggestions from civilian stakeholders and organizations. It is in this light that we are submitting these comments and suggested inputs.

3. We have no assurance, and neither are we making any assurance, that our comments and suggestions will be considered or included in the final draft of the IRR. 

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Suggested inputs and comments to the PNP Draft Implementing Rules and Regulations of RA 10591

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. 

An Open Letter to President Aquino: PNP rubber Stamp for Implementing Rules and Regulations for RA 10591?

Dear President Aquino,

News has just come out today that the Philippine National Police (PNP) is holding a "public hearing" on Thursday 15 August 2013 at 9am-5pm at Camp Crame for "public consultations" on their draft of the Implementing Rules and regulations (IRR), which had already been made and prepared, for the new Philippine Firearms Law Republic Act No. 10591. This apparently is a clear violation of what is provided in sec.44 of the law which states that the IRR shall be formulated AFTER public hearings and consultations with concerned sectors of society, viz:

Airguns and Airsoft guns now excluded from definition of "Firearms" Under New Law RA 10591

The definition of "Firearm" under the new law RA 10591 is expressly defined in Art. 3 (L) which states: (l) Firearm refers to any handheld or portable weapon, whether a small arm or light weapon, that expels or is designed to expel a bullet, shot, slug, missile or any projectile, which is discharged by means of expansive force of gases from burning gunpowder or other form of combustion or any similar instrument or implement.

The Problem with Changing of the Guard

The perennial problem with dealing with government agencies is that every time there i a change of administration, or a revamp or a reshuffle, the policies also change, oftentimes drastically. This latest problem of refusal of the PNP FED to issue permits to carry outside of reisdence or permits to transport which are only for a few days or event specific, highlights this recurring issue. A statement from the "desk of the president" of the PPSA blog was picked up which stated that as per their meetng with Chief PNP and other officials, no more PTTs were going to be issued for 3 months, as previously was the case. Instead, they would only be for a few days to a week at most. Likewise, there is talk that PTTs would now be 'merged" with the PTCFORs, if at all they would be allowed to be issued.

PROGUN Crime Statistics Project to continue till end of 2013

By popular request and as per agreement between the PROGUN board, we will continue our crime statistics project till the end of the year 2013. There is another upcoming Comelec Gun Ban which will take effect in October to coincide with the Barangay elections. The purpose of our crime statistics project is to chart the trend of crimes during the gun ban period and in between.

COMELEC GUN BAN 2013: What we have learned

As of 13 June 2013, the COMELEC gun ban was lifted. It was in force since 13 January 2013 within which period all licensed and legitimate gun owners were not allowed to carry their firearms outside of their residences, due to the election period. Both the COMELEC and the Philippine National Police have hailed this gun ban as having been "effective" and that crime rates and election violence went substantially down during the period. The PNP has even issued a statement, albeit falsely, that there were only 58 election related violence incidents during this gun ban period. We refuted these figures as being false and/or innacurate, insamuch as we had listed the correct figures of violent crime incidents during the gun ban period as being recorded as 2324 violent crime incidents in which there were 1189 injuries and 1862 fatalities during the gun ban period.

Nevertheless there are a number of trends and lessons that can be inferred from our criime statistics project for this comelec gun ban of 2013 which are:

1. The COMELEC gun ban is INEFFECTIVE in preventing or detering violent crimes and election related violence. During this period, election related and other violent crimes, continued unabated and the perpetrators were neither detered nor apprehended from committing these crimes. We have not heard also of anyone having been prosecuted and convicted of these crimes committed.

Aquino signs comprehensive gun control law

MANILA – President Benigno Aquino III has signed a new gun control law.

It provides stricter guidelines on securing a gun license and sets limits to the number of firearms a person may own.

Under Republic Act 10591, one must be a Filipino citizen, at least 21 years old and should be employed, and has no criminal record to own a gun.

One should also indicate in writing why he or she needs a firearm and should pass a gun safety seminar.

The new law also raises the penalty for illegal possession of firearms from four to six years in prison. -- ANC

May 2013: Thus far the bloodiest month of the year.

As widely anticipated, the month of May 2013 turned out to be the bloodiest thus far of this year. Expectedly, the 13 May elections and the period early in the month immediately leading up to the event, raised the bar for violence as never before in Philippine election history: Incidents: 491, Injuries: 333, Killed: 405. Sadly, these figures were missed by the mainstream media and were picked up only by the smaller news agencies.

In stark contrast, war torn Iraq listed the following deaths for March 2013: 33 deaths, and for February 2013: 22 deaths. Source: http://www.iraqbodycount.org/database/. Of course, Iraq is a failed state where violence, crime, and terrorism is rampant, whereas the Philippines claims to be a democratic country ruled by a constitutional government and the rule of law. Considering the foregoing comparison, it makes one wonder which is a better and safer place to live?

The Woolwich attack: The Effect of a Gunless society

On 23 May 2013, a man named Michael Adelbolajo, a British citizen of African and islamic origin, along with his companion, ran over a British solder in South London, got down from the car, and hacked and decapitated the soldier to death. The incident was caught by a bystander on video, where the attackers, with bloody hands and meat cleaver and knives, are seen as speaking to the camera justifying their attack. All the while 50 bystanders stood by watching doing nothing. In spite of the efforts of one brave woman who tried to pacify and disarm the attackers, the attackers held reign and refused to desist for minutes after. London police were likewise present and did nothing except to call for armed back up since apparently these first responders had no guns. In short, the people present at the scene were helpless and terrified in the face of two knife wielding terrorists.

The UK frequently touts itself proudly as a gun free society. Since the enforced national gun ban in 1997 in the wake of the Dunblane shooting, British citizens have by and large been disarmed by their leftist government, save for a few hunting shotguns which must legally be kept locked up and unloaded. Now a gun free zone, London strictly prohibits the carrying of any type of gun by civilians - even some of its own police. As we can see, this misled policy has led to disastrous, if not interesting, results: 50 bystanders including police, could not do anything to stop the two attackers who were armed with bladed weapons. 

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