European Commission
Attn: Commissioner
Mrs. Elżbieta Bieńkowska
Brussels, Belgium
Peter Ziemann
Kapellenstr. 64c
65193 Wiesbaden, Germany
EMail: [email protected]
Fon: +49 611 9518051
Wiesbaden, 22. Nov. 15
Feedback to COM(2015)750/F1
Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Council Directive 91/477/EEC on control of the acquisition and possession of
weapons
Dear Commisioner,
I am giving you feedback regarding COM(2015)750/F1 as an individual citizen. I am also
a legal weapon owner within the scope of Council Directive 91/477/EEC and the
German legal framework on the acquisition and possession of weapons
(„Waffengesetz“).
I will be likely affected by the new ruling that the Commission is trying to impose with
this Directive.
I appreciate the effort of the Commission in light of the recent attacks to review the
usage of firearms by serious and organised crime and terrorist organisations.
However as far as I am aware all those types of attacks have been carried out by either
fully automatic weapons – so called Category A weapons (Annex I to Directive
91/477/EC part II) - or other type of illegal acquired weapons/explosives.
I am not aware that any of the attacks that have been carried out by legally owned
weapons (within the scope of Council Directive 91/477/EEC). Therefore I appreciate if
the Commission reconsiders their decision based on facts where legally possessed
weapons had been used in fraudulent usage of firearms.
You state: „... Semi-automatic weapons represent a high share of today’s hunting and
sport-shooting weapons. However, the evaluation study concludes that some semiautomatic arms can be easily converted to automatic arms, and the existing Directive does
not provide any technical criteria to prevent such conversion. However, even in the absence
of conversion to category 'A', certain semi-automatic firearms can be very dangerous when
their capacity regarding the number of rounds is high. The proposal bans the semi-automatic
weapons which are included in the current category 'B7'. ...“
While I agree that semi-automatic weapons represent a high-share of today’s sport-shooting
weapons, I do not agree with that statement with regard to hunting. Contrary to hunting
sport-shooting requires weapons being universal to be used in different competitions. Since
semi-automatic rifles typically provide a universal platform to mount different type of
equipment used for the different competitions (e.g. optical scope, reddot scope, handgrip,
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bipod) they will be often chosen by sport-shooters as a “weapon platform” (Picatinny Rail,
MIL-STD-1913).
In my case I just own one (semi-automatic) rifle, which I use for different short-distance
(50m / 100m) and medium distance (300m) competitions. I will swap accessories as
required (e.g. from optical scope to iron sight; from bipod to handgrip).
Thus reclassifying those weapons into Category A, i.e. making them illegal for possession by
citizens, will likely inflate the overall number of weapons. Since for each competition a
different weapon needs to be chosen.
An addition I do not agree with you assessment that semi-automatic firearms can be
dangerous because of the capacity of the magazine. For example magazine capacity is
regulated to 10 rounds in Germany for sporting purposes and 2 rounds for hunting. If the
Commissions believes that high-capacity magazines represents the major threat of semiautomatic rifles the Commission shall regulate the magazine capacity instead of banning the
legal use of semi-automatic rifles.
You state:
(9) Some semi-automatic firearms can be easily converted to automatic firearms, thus posing a
threat to security. Even in the absence of conversion to category 'A', certain semi-automatic
firearms may be very dangerous when their capacity regarding the number of rounds is high.
Such semi-automatic weapons should therefore be banned for civilian use.
However this statement does not justify the reclassification of Category B, point 7 firearms
as Category A point 8 firearms.
As you correctly stated Category A weapons present a thread to public safety. And weapons
legally owned within Category A could be used to arm terrorists or other criminals.
Since terrorists typically target a group of citizens to be killed in a short time period, semiautomatic weapons are not their preferred platform. Their goal is not precise aiming (and
shooting) but generating most harm by bullet spreading. This threat does not exist for semiautomatic rifles.
In my view even the (magazine) capacity of semi-automatic rifles will not impose a higher
threat to public safety. In additional even rifles with bold action (Category C) can be
equipped with high capacity magazine. A trained shooter with a bold action rifle can cause
similar harm like a shooter using a semi-automatic rifle.
In summary:
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The Commission need to reconsider their goal to further restrict the possession of
firearms by citizens in light of the recent terrorist attacks; since automatic weapons
are used by terrorist instead of “legal weapons”
If magazine capacity is a major concern by the Commission, the magazine capacity
shall be regulated instead
Semi-automatic weapons are used by sport-shooters as a weapon platform. Instead
of having to own many firearms for different competitions the sport-shooter can
rely on one weapon system.
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Semi-automatic weapons do not impose a terrorist threat to public safety like
automatic weapons
Please consider my comments for further revision of the Directive.
If you have any questions please feel free to contact me – preferably using my Email address.
Kind Regards,
Peter Ziemann
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