PR and local public perception

[hitchphil]

the guidance also says -

Miniature rifle ranges and shooting galleries

A person operating a miniature rifle range or shooting gallery at which either miniature rifles not exceeding 5.84mm (.23") calibre or air weapons are used may possess, purchase or acquire such miniature rifles and their ammunition without holding a firearm certificate. Anyone may use these rifles and ammunition at a range or gallery of this type without a firearm certificate. No club approval is necessary.

This I believe allows air rifle only (& 0.22 but in practice they comply with HO requirements) clubs to operate a payg shooting gallery because they don't need HO approval thus don't need to comply with the HR guidance for clubs & only need to get guests to sign a form or register with a S21 statement. Not sure how their insurance works?

Fairground showman is also exempt from S21 & any member of the public, convictions or not can pay & shoot a showman's air rifle (aka bent bit of junk).

[Racalman]

Nope, .22rf can be used at a miniature rifle range. Here is an example of one club that makes good use of this exemption:

http://www.marlowrifle.com/publicopendays.htm

You don't need an FAC to buy the rifles or ammunition either, but quite how it works in practice I'm not sure.