Author Archives: MarkAvery

  1. Wild Justice supports ‘End Wildlife Crime’ campaign by Wildlife & Countryside LINK

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    As a member of the coalition Wildlife & Countryside LINK (58 organisations working together to campaign for improved environmental policy), Wild Justice is pleased to be supporting a new initiative to ‘End Wildlife Crime’.

    LINK’s Wildlife Crime Working Group (of which Wild Justice is an active member) has today written to all Police and Crime Commissioners (PCC) candidates, ahead of the elections on 6th May 2021, to ask them to commit to end wildlife crime.

    Police wildlife teams are working hard to combat the tide of wildlife crimes but officers need more support. Constrained resources, limited training opportunities and missing data all hold back the successful capture and prosecution of wildlife criminals. Despite hundreds of offences being committed each month, just 10 people were convicted of wildlife crimes in 2019.

    Police and Crime Commissioners have a crucial role to play. PCCs can hep turn the tide on wildlife crime by increasing support for wildlife crime policing within the police plans and budgets they control, giving their officers increased access to wildlife crime training and by adding their influential voices to calls to national policing action.

    LINK has asked all PCC candidates to commit to the following:

    If elected as Police and Crime Commissioner, I commit to:

    • Make tackling wildlife crime a key priority within my first police and crime plan, and to
    make budget provision to support this prioritisation.• Increase wildlife crime training opportunities for officers in my force and liaise with the
    National Wildlife Crime Unit on best wildlife policing practice.
    • Encourage the Home Secretary to make wildlife crimes notifiable, so that data on these
    crimes can be collected and used to inform policing.

    Prior to the elections on 6th May and to help voters decide who to support, LINK will be reporting on which PCC candidates have made the commitment to end wildlife crime.

  2. NRW misses the point – or seeks to avoid it

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    We wrote to NRW’s Chair some time ago and did not receive an acknowledgement (although they say that one was sent). We have now received a response from Sir David Henshaw and another from a person called Customer Hub – as we expect that some of you will have done too. The response is copied below, in red.

    NRW is foolishly or deliberately and foolishly missing the point of our enquiry. We are not asking them to change their general licence GL004 – we quite like it (as we have said before, many times). But the conditions that apply to the licence are not clear and the licence exists now, yesterday, today and tomorrow, and that is why we wrote to the general enquiries function at NRW asking some specific questions, such as:

    • in which of the remaining months of 2021 is it lawful to kill Magpie, Jay, Carrion Crow and Jackdaw under GL004 in Wales?
    • what non-lethal steps must be taken before lethal control is lawful?
    • what information would NRW like to receive of breaches of the licence conditions and how should these be reported?

    These questions are not answered in what NRW have sent us, and so we will be going back to them to ask for answers to these questions about their current licences which allow killing of birds in Wales. If NRW cannot answer specific questions from the public on the conditions of their current general licences then they are not, in our view, properly fulfilling their duties as a regulator. If a member of the public asks specificially about the conditions of a current licence then NRW should be able to answer those questions. It would, of course, be a lot easier to put that clarification on the NRW website , but NRW has chosen not to do that.

    NRW’s response in red and our thoughts on it in black:

    Enquiry about NRW’s General Licences

    Thank you for contacting NRW about our General Licences. 
    No problem.
    Our General Licences clearly set out the purpose and circumstances in which they may be relied upon. This was one of the grounds of challenge in a recent unsuccessful legal case. The judgement is clear the current general licences are not unlawful and there is no legal requirement for them to specify, any further than they already do, the circumstances in which they may lawfully be relied upon.  There may be no legal requirement but as a regulator you should be able to answer sensible questions about the conditions of the licence when asked by the public – you haven’t done that. You are maintaining a fog of confusion about when it is legal to kill birds under GL004 for the rest of 2021. Your general licences permit what would otherwise be a criminal offence and so their boundaries are important and it is perfectly reasonable for the public to ask for clarification.
    We are currently undertaking a detailed and comprehensive review of our approach to all the permissions we give for shooting and trapping wild birds in Wales, this includes General Licences. We have committed that, as our licences are lawful and the review is underway, we will not be making any changes to our General Licences at this time. We haven’t asked for any changes – we have asked as a general enquiry, becauise the information is not ion your website, under what conditions we and others can go out and kill, say, Carrion Crows in Wales for the rest of 2021. This is a current issue, not a future issue.
    The current General Licences are valid from 1 January 2021 until 31 December 2021.
    Yes, we know that. But when is it lawful to kill Magpies, Carrion Cows, Jackdaws and Jays in Wales during this period – it’s a simple question and one which was covered in court. You miust be able to answer it. What’s the answer please? You have made no attempt to answer our questions about the non-lethal alternatives that must be tried before killing can lawfully be undertaken or about how we should report any apparent unlawful incidents.
    The review will include a consultation later in the year, and we would encourage you to take part as it will shape our future approach to all the permissions we give for shooting and trapping wild birds in Wales. Further details about the consultation will be made available on our website and on our social media channels once available.
    We’ll be happy to do that, thanks.

    We are aware of the Newsletter from Wild Justice that suggested you contact us about our General Licences. We hope that our response provides you with additional clarity about our General Licences and the context of our ongoing review. We also wish to advise that we did acknowledge receipt of the original correspondence from Wild Justice and have responded to their letter to us in full.
    You must be joking! You have avoided providing any clarity at all to direct and simple questions.

    Customer Hub

  3. Survey responses (5)

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    Over the Easter period we’ve post five short summaries of the responses – just for interest really.

    This is the fifth instalment.

    We asked you:

    Our newsletter subscribers are a very active group – and that doesn’t surprise us at all, and explains why you respond so quickly to requests for help. Thank you.

    In the free text ‘answers’, some of you asked some questions. Here are some examples with answers:

    • Q1: why aren’t you a charity? A: We might be in time, but we’re still thinking about it. The advantages are all financial – Gift Aid, no Corporation Tax anda few other things. The disadvantages are all to do with how it would eat up our time, create more work every year and possibly restrict how outspoken we could be about ‘political’ issues. At the moment we’d rather spend our time, energy and money campaigning and taking legal cases. But we have this nagging feeling it would be the right thing to do eventually.
    • Q2: why don’t you sell merchandise to make more money? A: We have discussed this a few times and we can’t agree! Would the revenue repay the time? Do we want to be selling more ‘stuff’ in a world full of ‘stuff’. This issue is parked for a while because we are too busy with other things.
    • Q3: will you help me….? A: We read every email that comes to us and we have given small amounts of help in the form of advice, information and introductions to worthy causes, but we can’t tackle anything other than a small number of issues at once – we’re a small organisation with no permanent staff. Our experience is that when we get into an issue we stick with it for a long time eg general licences. It’s important that we don’t start more projects or campaigns than we can finish.
    • Q4: why can’t I make regular monthly donations to Wild Justice? A: you can, and quite a lot of people do – thank you! But you have to set these up with your bank, we don’t do Direct Debits (they are too complicated for us to deal with at the moment).
    • Q5: why don’t you have a membership fee like most other conservation organisations? A: we aren’t like most other conservation organisations! Our newsletter is free – anyone can subscribe. If you like what we do then we think you’ll support us financially and we’d rather leave the amount entirely up to you. If you think we’re doing good work then please support us, but if you don’t, keep an eye on us and we might well amaze you in the future and then you can give us money if you feel that way. We could wind up Wild Justice very quickly if the money stopped coming in for our work, and if you don’t like what we do then that’s what we would have to do. We don’t have land, offices, permanent staff, salaries, pensions, stock or any of those things that we need to fund. We pay our bills on time – usually on the day they are rpesented to us and we don’t have any debts. At the moment, thousands and thousands of people like what we are doing and want to support us – we’ll trust that as our financial model for at least a while.
  4. Survey responses (4)

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    Over the Easter period we’ll post five short summaries of the responses – just for interest really.

    This is the fourth instalment.

    We asked you:

    These are difficult figures to compare with UK averages but it is fairly clear that Wild Justice newsletter subscribers are likely to eat less meat than the national average.

    When asked whether wildlife, the environment or animal welfare was their main concern (a difficult choice) our newsletter subscribers narrowly opted for wildlife conservation.

    How does Wild Justice make you feel (just 10 comments to illustrate the range)?:

    1. I was really pleased when I heard of the formation of Wild Justice. I have in the past been on many demos/marches./protests in respect of how animals are treated. Wild Justice is using a different approach and one which I believe is making a difference. When so much is weighted against kindness and compassion for animals ie loss of habitat due to intensive development type housing , factory farming, destruction of our wildlife such as badgers, Wildlife Justice gives me hope.
    2. Excellent that you can challenge through the legal system where other charitable organisation cannot or will not. It’s interesting to read the views of the likes of Countryside Alliance who tie themselves in knots trying to ridicule what you say.
    3. Please keep up the good work! Yoiu are taking action where it is needed.
    4. I had to put I live outside the UK. I live in the Isle of Man which is the British Isles. Home to a thriving population of hen harriers whose young migrate from the island and tend to get shot/poisoned or trapped in Scotland and the Lake district. I support wild justice because it is logical in its approach, open minded and inclusive in ways the organisations I did not tick in question 5 are not.
    5. Thanks for all you are doing – you fit a campaign niche that is vital to our future countryside.
    6. Your straightforward attitude is proving to be very effective as evidenced by the significant influence your interventions and challenges are already having on government and organisations. You can be proud of your successes which are sure to increase with time. I am proud to have the opportunity to be a small part of you.
    7. So happy you exist; I’m 83, not very active now and very deaf, but Nature + same on TV and my garden gives me all I need to make me happy, though I could do without the many parakeets (which I CAN hear) and feral pigeons which consume most of the food I put out. Any advice there gratefully accepted!! Good luck and keep on the good work.
    8. So proud that you stand up for the wildlife that have no voice!
    9. I think what you are doing is amazing- it is so interesting to realise that using legal challenges is making more difference (I think) to protection of wildlife than decades of conservation attempts. I think the RSPB are genuine, and it is excellent that many species are more numerous due to their work, and big projects like rat-removal on Tristan de Cuna are surely important – but at the same time where I live in Edinburgh/Lothians, whenever there is a new house development e.g. near Roslin, huge hedges still get torn out regardless of protests, and in hills south of Edinburgh there is still hardly any wildlife..and when I read the wording of the challenges or judge’s response to the gamebird/ shooting licenses I was amazed at the gaps and vague sections. I feel sure it is the same situation as women’s rights and the law – yes there was much progress and sea changes in attitudes from 1900-the 1970s- but in 1970 my friends mum still couldn’t get a mortgage on her own – it had to be in her husband’s name. That only actually changed after it became illegal to discriminate in that way. I spent my youth hating passing building sites, because of the ubiquitous unpleasant calls from male builders – it didn’t matter if you answered or ignored – nothing made a difference – we were just expected to “put up with it”. But suddenly when there are legal frameworks that define “considerate constructors” – impacting contracts – they don’t do it(because they are not allowed to)! I know a person may not change inside, but it’s been jolly nice for me… So that’s what effect I think you are having, in a way. I don’t know if it’s a coincidence, but I am following the Scottish Creel fishermen’s legal challenge against the Scottish Government not properly considering application for 3-mile limit on dredging. I also saw news of a coastal group in Sussex getting a dredging ban in an area (not sure of all details ) by citing a bye-law (I think)- where decades of scientific reports have failed. I wonder if your work inspires those groups? My problem at the moment is I literally have almost no money – I am studying, having given up my job to return to university – so I’m not a very useful supporter at the moment where finance is concerned. But I do fill out some of the surveys/ consultation responses you suggest. I am not on twitter so can’t comment. But I can tell you I like your writing style, often I look forward to getting your newsletters because the sarky comments on misinformation etc make me laugh!
    10. Well done to a dedicated team willing to fight to protect wildlife and the environment.

  5. Survey responses (3)

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    We sent out a survey in our newletter #57 and 8640 of you responded – which is amazing! Thank you.

    Over the Easter period we’ll post five short summaries of the responses – this is the third.

    We asked you:

    Wild Justice newsletter subscribers generally support a range of other organisations

    The UK was split very close to 50:50 on Brexit – Wild Justice newsletter subscribers who voted and disclosed how they voted were almost 75:25 Remain.

    Your free text responses indicated a high degree of understanding and support for the way that Wild Justice mixes legal challenges and campaigning approaches:

    1. I donate to over 20 organisations each year, but donations to Wild Justice is the ONLY organisation that I feel does not waste my money on ridiculous executive salaries. I believe you are all there not just for your own self satisfaction but that you really care deeply in what you are trying to achieve – so THANKYOU. I support you 100% in trying to tighten and change the present laws regarding our wildlife.
    2. I like your logical, committed approach using logical arguments rather than more extreme action. Although I do believe that reasonable , normally quiet people like me will respond and take action if something is inherently unfair.
    3. I am very supportive of Wild Justice’s work to “encourage” the statutory authorities to implement existing legislation to protect wildlife, and to work to improve the legislation where needed. Also support and welcome work to combat raptor persecution.
    4. Keep up the good work :). Your legal challenges are getting results.
    5. I’m really grateful to you all for the work that you are doing. I’m not so clear on my thinking, understanding and knowledge in this area even though I’ve been connecting and supporting campaigns since a teenager; but it feels that Wild Justice shows a really effective and necessary new way to keep a vigilant eye on actions that are harming our wildlife and our natural world, and to take strong action to counteract this. Thank you all once again.
    6. We owe you all at Wild Justice a big thank you for all your time and expertise fighting for the protection of our diminishing wildlife. For quite some time now you have been the only ones campaigning with any teeth. A couple of the NGOs in Q5 need to wake up. Thanks again and we will continue to support you.
    7. Clear objectives are set with evidence provided and the means to a solution provided. Very proactive organisation.
    8. I believe working through legal channels is a sensible and realistic way to try and ‘change the system’, although I also support those who use other methods, eg, Greenpeace and, to some extent, Extinction Rebellion. I am very thankful that Wild Justice is doing what it can to change legislation to protect wild animals and the environment – keep up the good work!
    9. Great goals. It’s really heartening to see a group like this prepared to take on the government over its appalling environmental (and related) policies etc.
    10. I think the work that you do is admirable; I really like how you use the law to make people and organisations accountable.
    11. I like how WJ use the law to determine and clarify processes and actions organisations should take and in that way hold them to account
    12. I think yours is a unique and necessary approach to takling the harm being done to wildlife and the environment by those who normally hide behind often outdated and unfit for purpose legislation.
    13. I strongly support the efforts by Wild Justice to ensure existing animal welfare laws are stringently applied and the efforts to introduce new laws to stop animal suffering.
    14. Think you’re doing a great job in a very difficult area. The law relating to the protection of wildlife and environment is often weak, poorly enforced and sadly exploited. An organisation such as yours is really needed. Well done for all your efforts
    15. I am very glad Wild Justice has come into being and has such a strong focus and direction. I wish you great success. We need a voice to open the eyes of those who are blind to or ignore the dangers that our world faces and someone to act impartially and decisively on behalf our wildlife. More power to your elbow!
    16. To me Wild Justice feels like a fresh, strong, professional, effective organisation which highlights, supported by facts, the wildlife persecution and damage to natural habitats that is happening today and fights effectively in getting present laws changed to better protect wildlife and natural habitats. The barbaric cruelty to wildlife haunts me and that it is allowed to go on despite evidence of lawbreaking because of loopholes in the law and associations with the perpetrators sickens me. I do appreciate the guidance you give through your unassuming newsletters when asking supporters to write to mp’s etc. it is good to have facts to hand. THANK YOU for all you are doing and please keep going. K
    17. The reason we support WJ is because our country needs a body to stand up for wildlife; EU laws have still not yet been made law here (as far as I am aware), wildlife crime is a huge problem, from hare coursing to raptor killing , and even though there is often evidence there are very few prosecutions and they are not enough of a deterrent to change some peoples behaviour. Landowners should be brought to task and not allowed to simply sack the employee who was carrying out their instruction. Unfortunately in this country wildlife comes second to money and its very sad. DEFRA and Natural England do not appear to be playing the role that many of us think they should be, sanctioning culls of wild birds for instance and giving out licences to kill – its disgusting. We also find it very sad that we can go for a 10 mile walk in the countryside and see very little wildlife, in fact there is more in our garden nature reserve when we get home! This needs to change. We both think your cause is incredibly important and wholly necessary. Well done WJ!
    18. I think you’re doing a great job in lobbying and campaigning successfully for changes in the law that make a difference to wildlife and the environment.
    19. I think you are doing an important job. There is little point campaigning to change the law if laws are not enforced. I should try harder to be a more active supporter!
    20. Very impressed by what you have achieved so far and your approach to challenging the state organisations supposedly protecting the wider public’s interests
    21. I think this is an excellent organisation. It is very important that where legislation exists to protect wildlife – that it is adhered to, and just as importantly – properly enforced.
    22. I support the way that you’re tackling issues that other wildlife organisations seem less able/willing to take direct action on.
    23. It’s great that someone is making a stand the way Wild Justice is. Thank you
    24. Wild Justice, along with a few other organisations and initiatives recently, has provided renewed hope that things can and will change for the better. As someone who has worked in conservation for 20+ years in the charity and public sector I was becoming very jaded and quite despondent in the face of witnessing continuing damage to our natural heritage from things such as DGS and improper use of General Licensing, especially since moving north for work. The existence of WJ has injected a much needed burst of positivity into the conservation debate and I expect I’m not the only person it has given a bit more momentum to.
    25. Keep up the great work, I like the fact that you are prepared to take on Defra and the Government to insist on positive change for wildlife.
    26. There is a real need for Wild Justice – to bring issues such as you are doing into the courts – to be decided by laws – so government has to abide by it’s own rules as it expects from Joe public to do.
    27. I admire your strategy of ‘playing them at their own games’. I despair at the way the legal profession in general has developed into a highly expensive ‘game of words’, but realise that it has to be used as one of the approaches to save our planet.
    28. I feel wild justice is a new and vital way of holding the government to account. Taking legal action, in my opinion, is the best way to improve the laws and ensure organisations are adhering to current laws. I would like to see improvements to laws concerning pollution of the environment, especially our water ways and better protection for habits – we can’t just keep building as a way to improve the economy. I do believe in what you’re doing and embedding it in law is the best way to do it!
    29. Power concedes nothing without demands. Keep making DEMANDS.
    30. I just think you are bringing to every ones attention the questions that no one else has the balls to ask, and I think that’s vital.
    31. Think you are doing a good job. It really should be done by Natural England but they have been so curtailed by Defra who appear to be in the shooting /and purely farming interests.
    32. I think you’re doing an excellent and much-needed job. It’s a shame that some of the other, long-established, wildlife conservation bodies – notably RSPB and the Wildlife Trusts, but also WWT, Butterfly Conservation, Plantlife, etc, etc – haven’t come together to develop a stronger and higher profile sector-wide approach to the issues you’re now addressing; and I also think that you need to hold their feet to the fire so they don’t feel able to continue to ignore the more difficult issues just because you’re now addressing them. It’s important to show decision makers and the wider public that Wild Justice is representative of the sector as a whole, rather than risking being portrayed as a radical or fringe group.
    33. I think you’re doing an invaluable job in conserving wildlife and confronting this corrupt government and their rich cronies who frequently talk about being conscientious ecologists and yet in their actions do just the opposite. Thanks for doing the job so well and being such a strong public / media presence.
    34. I greatly admire what you are doing to tackle the injustice to wildlife. You appear to have made strides where others have failed by being prepared to go to court and challenge policy. I think the action on general licences was a good one.
    35. I am genuinely impressed by what a small group of people, with a clear agenda and none of the “baggage” of the large NGOs, can achieve. Thank you for taking these fights to the courts and holding those in power to account in a way the large NGOs (RSPB and wildlife trusts) repeatedly fail to do. I see my contributions to wild justice as some of the most worthwhile charitable contributions I can make.
    36. I like your assertive legally competent approach to tackling environmental issues. I am impressed by your collective expertise.
    37. Finally an organisation prepared to stand up for wildlife through the courts. Protesting is all well and good but this is the only way to effect real change. Well done.
    38. What you are doing is incredibly important. Government and those who think themselves entitled to treat environmental concerns with contempt must be held to account and since brexit has removed the ECJ level of censure it only leaves organisations like you to take action.
    39. The UK has many laws that are important for wildlife and the environment that are not enforced, and there are many that we need but don’t have. Wild Justice seems to be attempting to correct the situation.
    40. Wild Justice has tackled important issues head on and not been afraid to go to the heart of power. Your vast experience and great credentials are well respected by all who are passionate about wildlife and sustaining this beautiful planet we live on – great job guys
    41. I support and admire Wild Justice for its uncompromising and outspoken campaigning. For too long landowners and the wealthy have behaved as if they have the right to destroy and ill-treat wildlife and the countryside.
    42. I’ve been impressed with your actions against the General Licences. These and also the questions concerning uncontrolled release of game birds into the environment are certainly good examples of causes I am willing to give strong support to.
    43. I support Wild Justice because it takes an activist position on issues concerning bird and animal conservation and protection, I have a deep concern about a society that allows people to slaughter wildlife for fun or to protect their prey, it is time landowners and mangers are made personally responsible for the actions of their gamekeepers. I have been keen on birdlife for all of my life but withdrew my support for RSPB for whom I volunteered, when they became a glossy talking shop and now focus on Wild Justice and BTO.
    44. Wild Justice appears to me to be a welcome, and complementary, addition to other conservation organizations. I like the way it comes across as active, professional and focussed. I like that Wild Justice progresses with challenging existing law to improve it and make it more precisely correct. Having Chris Packham as one of the ‘leaders’ is a strong positive for me as I respect and like him, purely through his television and radio presentations and persona.
    45. At last! An organisation which does not fear losing members because they rattle a few cages. It is what real conservationists have been missing – a body which fights back, with teeth bared. Keep it up.
    46. I support as many organisations as i can who try to look after our natural world. Yours appears to be one which tackles issues by trying to change laws. This is the way forward rather than just mud slinging as it that method goes nowhere. Keep up the good work. Brains over threats will prevail .
    47. I think you are doing a great job and that legal challenges are the way forward to protect and restore wildlife. I’d like to support you as much as I can.
    48. You are doing valuable, specific, constructive work that recognises and uses the power of legislation as well as fighting for hearts and minds. I should get more involved – so many calls on my time, so hard to know where to focus my energy – thankyou for doing it for me!
    49. What I like about Wild Justice is that there’s no spin or hyperbole. The Directors are clearly passionate about the things they take on and they do so logically and legally backed up by fact and reason. How can you argue with that? I am equally passionate about the other organisations I support but there is something different about Wild Justice and how it speaks to me personally. I like that.
    50. Love the way you are taking on the Establishment & its purpose to protect land owners, farmers, the gun lobby, hunting lobby etc and their rights at the legal level. Making it much harder (and making their actions transparent) for them to continue damaging the environment for the profit motive that drives them. Enforcement is everything in the end, but great to see you putting them on the spot, even if they drag their heels, don’t follow legal judgments or deliberately ignore the law. They’ve had it easy and their way for far too long!
    51. I think that what you are doing is brilliant and the reason why I say this is because you are using the law to achieve your and my aims and objectives. Your objective and factual approach to issues based on science and the law does not leave a lot of room for people and organisations who break the law to manoeuvre. The more that you use the law against these people the better off our wildlife will be. Wild Justice has done more in the past couple of years than I ever thought possible and what you are doing clearly works (well, most of the time). I am sorry that you as individuals have come under some very nasty treatment from certain people and organisations and that it cannot be easy for you at times, so thank you for all that you have done and will continue to do. Thanks also to your legal teams. One thing that concerns me is how difficult it is for surveillance evidence to be accepted and used in Court for criminal proceedings and I wondered if there was anything that WJ can do to help bring about changes in the law to resolve this issue. The Guardia Civil in Spain seem to have some good outcomes from using sniffer dogs and powers that allow them to go on any land at any time. Can we not petition for these types of resources and powers? Keep using the law to fight for wildlife, it’s the only way forward.

    It’s free and easy to subscribe to our newsletter – just click here if you are interested

  6. Survey responses (2)

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    We sent out a survey in our newletter #57 and 8640 of you responded – which is amazing! Thank you.

    Over the Easter period we’ll post five short summaries of the responses – this is the second.

    We asked you:

    • Just over 1% of newsletter subscribers live outside the UK.
    • Wild Justice’s newsletter subscribers are slightly under-represented in Northern Ireland and slightly over-represented in Scotland (but not by much)
    • Wild Justice newsletter subscribers are mostly middle-aged and older (a bit like the three of us)
    • 53% of Wild Justice newsletter subscribers are female.

    And here are some more of your comments:

    Newsletter and communications:

    1. Love the news letters and congratulations on achieving so much for wildlife
    2. I mostly follow your actions via the email newsletter which is helpful to keep abreast of your activities.
    3. Not actually got to look at website but enjoy the newsletter which keeps my levels of concern about wildlife/environmental issues at the forefront.
    4. Always enjoy receiving and take time to digest your updates.
    5. I also enjoy the tone of the newsletters – even if Chris Packham doesn’t write them I can see him talking in his no nonsense way. I’ve shared the newsletters with a number of people, some who have also become involved.
    6. I also like the way that you keep your supporters informed and up to date with the work you are undertaking and your progress.
    7. I read your newsletters. I don’t use Twitter or engage with social media really, but I forward your emails and spread the message that way….
    8. I have found your emails very informative and interesting. You are doing vital work raising awareness of wildlife and conservation issues.
    9. Great organisation with good communication and raising and supporting incredibly important issues
    10. I think you’re doing a great job, especially like the personable, relatable tone of your communications!
    11. Your newsletters give me hope that there are positive changes happening in this world.
    12. I skim read the emails -they are a but long for me. I don’t look at any other wild justice Comms.
    13. I follow you mainly through Twitter.
    14. You guys are very well informed on the issues you campaign on. It would be great if you could share more of this through links to research/ publications in your newsletter and website. You already do this, thanks, I’m just asking for more. Maybe a “resources” page on your website.
    15. Very interested in keeping up to date with Wild Justice and look forward to receiving the newsletters.
    16. I love receiving the newsletter and reading about all the great important work you do!
    17. I get so many communications on line that i am not encouraging you to send me a lot more but the amount that you send me at the moment is about right and i am keen to keep abreast of the issues that you raise
    18. I really enjoy your weekly newsletter and your Twitter account content and wondered if you could also launch an Instagram account?
    19. I enjoy reading the newsletter as it is informative and gives me an opportunity to help when I can
    20. I enjoy your newsletters and I usually sign petitions.
    21. I get so many e mails from groups I support I like brief clear updates with links to longer articles etc if wanted.
    22. I love the Newsletter content but sometimes it is a little long, maybe more frequent “bitesize” comms?
    23. Thank you for your information. It’s always in easy to understand format. I feel I am learning lots.
    24. I’ll read all information from your Newsletter
    25. Respected & informative in the undertaking of being a voice in conservation.

    It’s free and easy to subscribe to our newsletter – just click here if you are interested

  7. Survey responses (1)

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    We sent out a survey in our newletter #57 and 8640 of you responded – which is amazing! Thank you.

    Over the Easter period we’ll post five short summaries of the responses – just for interest really.

    This is the fourth instalment.

    You’ll see that our newsletter subscribers are primarily, but not exclusively, UK based and from right across the UK. Very few of our subscribers could be described as youngsters and more are female than male. Our subscribers support a range of other wildlife and environmental NGOs. More details on all that to follow over the next few days.

    We also invited free text comments on anything and received 4610 of those – we have read every one. We’ll summarise those comments in what follows too. Overwhelmingly, the comments were favourable and many made excellent suggestions.

    Let’s just get the less than polite comments out of the way first (then we can ignore them in future blog posts). It was very obvious, scrolling through the comments, that abusive and rude comments came from the shooting community. Because BASC (British Association for Shooting and Conservation) was one of the organisations we listed, it is possible to see how many of the rude comments come from people who self-identify as BASC supporters: all of them do (yes, every single one). This is not to say that all BASC supporters are rude and abusive, but it is true to say that all rude and abusive comments we received were from people who said they were BASC supporters. We had some nice comments from BASC supporters too.

    Here are some examples (of complete unedited comments) just to illustrate the range of comments (the rudest comments are colour-coded in red so that you can avoid them or seek them out as you see fit):

    • What you’re doing is fantastic because there’s so much which needs doing. And thank you for giving your time. I don’t know how you keep going what with the apathy of people and the ‘politicians’!!!!! But we all must keep going. I would love to help you further if I can. Good luck and stay safe.
    • I thank you all for the good work you’re doing. The campaign is so well organized and targeted. A voice of reason & hope in troubled times.
    • As someone with a lifelong involvement with a wide range of countryside activities (not all shooting related!), I’m genuinely interested in some of you’re aims, eradicating raptor persecution and mass gamebird release especially. I would however like to see at least some acknowledgement that human management of the UK countryside is a requirement and includes the wildlife that resides within it. I think even yourselves accept deer have to be managed – many other species similarly love the environment we have created but have no natural predators – badger & fox included – and can wreak havoc on species we need to conserve. Just one more & I’ll climb off my soap box. I personally am not a grouse shooting fanatic but surely the way forward is getting large landowners on board with conservation practices – moors are a managed environment like it or not and if grouse are not there (and they won’t be if left to their own devices) then Harriers and most other ground nesting birds won’t be either. PS I don’t work for BASC!
    • I have in the past participated in game shooting including grouse but I am now not doing so . I see the sport as out of control and often damaging so I support some controls
    • I agree with many of your proposals e.g. with regard to lead shot, game bird releases, but feel that sometimes you just come across as anti field sports and this then becomes personal. I shoot for pest control and for the pot. I love watching raptors and am disgusted if any are harmed, including Eagle Owls. The best day’s shooting for me is a Rabbit for the pot, calling back to a Buzzard and seeing the flash of a Kingfisher. You could have shooters on your side in many issues.
    • Wj is a Marxist cell intendng to destroying the British countryside and its traditions by repeatedly lying to ignorant townies about the true state of our wildlife and how important fieldsports are in preserving it. By destroying things like grouse shooting numbers of birds that currently thrive thereon will decrease whereby wj and others will go begging for ever more money to spend upon their next attack on our wildlife.
    • My opinion is that you haven’t a clue how the countryside operates and l am happy to give my support to land managers and gamekeepers. Packham is a liar and a fraud. Avery and Tingay need a lesson in reality. Your organisation will ultimately fail but not nefore you have fleeced a gullible public.
    • I maybe a member of BASC but I’m not their biggest fan, just like to keep up with what’s going on in the Shooting community and to hear their views on recent challenges to their sport, which I find quite amusing at times. I think your doing a cracking job with the general license reforms, but there’s still more can be done. My tip would be.. don’t take too many battles on at once. Keep up the good work.
    • Stay out of business that dosnt concern you. Shower of shite.
    • Have always been interested in wild life and also the environment plastic waste etc I am also an Airrifle shooter, I shoot mainly for food and also for the conservation of other wildlife, l don’t shoot for no reason, and I practice to keep up my skills for clean kills. I’m also not a fan of .22 target shooting clubs who have no respect for the land that they shoot over, I have complained many times about a local club that I used to belong too, and their dumping of lead residue onto the ground instead of disposing of it in the right way, I complained to the chair/secretary of the club, the clubs governing body, and also the land owner (Thames Water) but all to no avail, TW quite surprised me, as they profess to be guardians of the environment.
    • I appears WJ want to change the traditional way of the countryside, and not for the better. Their actions don’t support their words, for instance, the suspension of the general licence. It caused a lot of damage at nesting time through lack of pest control. Quite the opposite to what you claim to want to achieve. We now have a religion, and our traditional ways and strongly held deep beliefs will in future be protected as is any other religion. The next time anyone says anything derogatory about us , it will be reported as a religious hate crime.
    • terrible organisation with no understanding for the countryside
    • They have got no idea on animal conservation issues ..
    • I belong to The Free Church Of Country Sports and I find Wild Justice is really damaging towards my religion , I almost feel persecuted.
    • You are destroying this country’s hunting heritage with your ill-informed, biased and illogical rhetoric. Your representatives are low-intelligence, their ASD prevents them from spreading the truth, you lie and you deceive the public. You are reprehensible oafs with a vegan agenda and yet you offer no practical and effective solutions to pest control, conservation and protection of rare species. You should be ashamed of yourselves.
    • You do not understand how the natural world works predators have to be controlled or predated species suffer. The country side has been managed successfully by countrymen for generations.
    • You spout a load of bollocks and don’t really have a clue as to how the countryside really works. Bugger off back to the towns and give your barber wellie boots a clean
    • Your all a bunch of ill informed sheep trying to get everything banned that you don’t agree with and use lies and misrepresentation to get money from the gullible
    • As a member of the free church of country sports,I’m not a supporting wild justice
    • I think that the countryside should be left to be run by those that live and work within it, being either Farmers, landowners, gatekeepers. These are the true guardians of the countryside
    • Wild justice and a bunch of self important no it alls who know very little about how the country side actually works. There policies of protecting certain species seriously harms other species
    • People from towns Vegans Jumping on the bandwagon People who actually live in the country Think your parasites
    • I am pro hunting, shooting and fishing and am definite that those who participate in such sports have a greater understanding of how the countryside works, conservation, animal welfare than the sort of people who join Wild Justice, LACS and similar organisations.
    • I am interested in Wild Justice as I find they are a danger to existing conservation projects and do not have a clue how our country side works. They appeal to the fluffy bunny brigade at the expense of rural jobs and livelihoods
    • Wild justice is not needed just leave the countryside to country people to manage like they have for hundreds of years better concentrating their efforts on the mess the city’s are in
    • Wild justice haven’t a clue about wildlife and I really don’t think they care. The only shouting wildjustice do is for the predditors and nothing for their prey. HYPOCRITES the lot of them
    • You are all a bunch of wankers that don’t know what your doing and how your actions are doing more harm than good
    • More townsfolk with little or no knowledge of country life trying to mess with nature for their own ends. The cities are a shambles and now they want to move outwards. Probably never seen flocks of woodpigeon descend on a crop of wheat or what a single fox will do in a shed of 3000 chickens.
    • Don’t support at all. They have no idea about how the countryside works. Due to misinformation from people like Chris packham. The countryside is a workplace, not a free for all do as you like bunny hugging play ground
    • Load of tree huggers who have no idea about Countryside management
    • Wild justice are are bunch of delusional tossers ,who are trying to destroy our county side. Go away Chris packam your a prick
    • Wild Justice are liars,and scam money from gullible members of the public,justice will be seen in court.
    • I think your a despicable bunch with no true care for wildlife and you are only interested in your own agenda
    • Your organisation is an utter disgrace with a hidden agenda against the countryside.
    • Just a bunch of nutters who know nowt about the countryside. Should be declared a domestic terrorist organisation
  8. DEFRA omnishambles

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    Dear DEFRA, we asked you at a so-called stakeholder meeting in early November about the conditions applying to your (then) upcoming general licences for bird killing.

    On 23 November we emailed you asking the same question in writing ‘under the conservation licence, does DEFRA consider that its licences allow the killing of say, Carrion Crows, at any time of year or only in the breeding season when Carrion Crows take eggs and chicks?‘. You replied saying that you would get back to us – you didn’t.

    After the publication of the said licences we contacted you again, on 5 January, and you originally told us that the information would be published within two weeks, but then had to ‘phone back and say it might take longer than two weeks.

    More than a further two months have passed and you have not published the information and you have not got back to us. You will be aware of the judgment of Justice Jarman at which you were an Interested Party, where he stated ‘Mr Corner QC with Ms Sargent, on behalf of NRW, submit that the licences only authorise action where there is a present risk to the stated interests. Thus, in the example given above NRW accepts that the relevant licence (004) should be used only to kill crows during the months between egg laying and when the chicks are well grown, namely April to July, and only in those areas where curlews nest, which do not extend to urban areas. It should not permit someone to kill a crow in the autumn or in an urban area on the basis that that bird might someday at some place take a curlew’s egg or chick.‘.

    Our query is a perfectly reasonable request about a licence which applies to most of England and purports to license the killing of wild birds which would otherwise be a criminal offence. Please answer this query as a matter of urgency.

    In any case, as a Department your word cannot be trusted and you are an administrative shambles. Please let us know the route by which we can complain about your lack of responsiveness and repeated broken promises.

    Wild Justice

  9. Our letter to the Chair of Natural Resources Wales, Sir David Henshaw.

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    Dear Sir David

    We are writing to you following Wild Justice’s challenge of NRW’s general licences and following subsequent discussions with NRW staff.

    We write not to seek to change NRW’s policy but to ask you to improve your practice as a regulator and as the licensing authority for general licences. Our concerns are primarily with your GL004, the ‘conservation’ licence, but you might want to take these points on board for your other licences too.

    The Court found that the NRW general licences are lawful but there were useful and important constraints on the use of those licences in time and place. We were pleased that in sworn evidence to the Court NRW staff made it clear that lawful use of GL004 for conservation purposes required its use to be limited to the bird breeding season and limited to areas where species of conservation concern are nesting.  The judge referred to these important constraints in his judgment. Wild Justice is happy with this clarification of the circumstances of lawful use of NRW’s licences.

    You may remember, but your staff will be able to confirm, that the NRW position, which is shared by Wild Justice, and more importantly the judge, was not the position of BASC who argued that the law allows landscape scale culling of species on the general licences – we characterise this as ‘anywhere, anytime culling’.  The judgment, and NRW’s sworn evidence, makes it clear that is not the case.

    That is the first part of important background to this letter: NRW, Wild Justice and the Court are agreed on the legal basis of GL004 (but an important part of the user community, shooters, was not).

    Following the judgment we wrote to NRW on this matter, and had an online meeting eventually in late February. We asked that NRW clarified the conditions of lawful use of GL004 (about which NRW, Wild Justice and the Court are agreed) in order to make clear to any users of the licence the boundaries of lawful and unlawful behaviour. We simply asked that NRW posts words on its website to make these conditions clear.

    Your staff have refused to do so.  This is very disappointing and strikes us as poor practice by a regulatory body and licensing authority.  NRW has refused to clarify the legal basis for its own licences – that’s quite astounding! That is why we are writing to you now as a matter of urgency.

    We would ask you to do the following things please:

    1. copy this letter to your fellow Board members
    2. respond to this letter by Monday 29 March setting out what steps NRW will take to clarify the conditions of lawful use of its live, existing, general licences starting with GL004.

    In the absence of any satisfactory response we will consider other means of publicising the legal position of your licences.

    Wild Justice

  10. DEFRA’s terrible consultation on gamebird releases – let’s see.

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    Thank you to hundreds of Wild Justice supporters who responded to the DEFRA consultation on gamebird releases – see here, here, here and here for examples of your comments back to us.

    Wild Justice sent in a consultation response too. Our response included this warning;

    In the view of Wild Justice the proposals in this consultation fall far short of what DEFRA promised to the court in October 2020. The proposed measures will not, in our view, protect N2K sites in the way that is needed and to which DEFRA committed itself. If these proposals are implemented then Wild Justice will seek legal advice on how best to expedite a further legal challenge to gamebird releases in England.

  11. Thank you for your responses (4)

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    Hundreds and hundreds of you are responding to the DEFRA gamebird consultation and telling us that you have done so. We’ve been answering queries (we simply cannot answer every single one, sorry) over the weekend so far and will be doing our best to do so through Sunday and Monday too.

    Thank you for responding – every response is valuable, whether you basically cut-and-paste our suggestions, shorten or lengthen them, correct the typos or introduce some of your own, refine or embellish them, or indeed start from scratch and produce your own perfect consultation response.

    The closing date for consultations is Monday (time unspecified) so we expect many more people to have a look at this today and send off a response this evening. Here are our suggestions for how to respond – click here.

    And here are some more quotes (to add to these earlier selections – click here, here and here) from your messages to us:

    Thank you for all that you do. I’ve completed and submitted my response thanks to your clear guidance and suggestions.  I’ve signed many petitions but have never responded to a consultation before!

    Thanks for guiding us through this process. As I went through it I became almost incandescent at the transparent bias in the process.

    Just to let you know that I have responded to the consultation. I have also canvassed friends, family and various organisations that I belong to to do the same. Thank you so much for the work that you do to protect wildlife and wild places. You are helping empower people to act on behalf of the voiceless. We can make a difference and we are powerful.

    You might be interested in the response I gave at section A3;  ‘I live between two shooting estates and more than 500m away from their release pens; yet I always have pheasants in my garden, and I don’t feed or encourage them.  A gamekeeper once explained to me that pheasants and gamebirds wander about all day and then go to sleep wherever they happen to be when the sun goes down. Unless they are regularly shepherded back to where they ‘should’ be they will wander indefinitely. Therefore 500m buffer zones are ineffective and need to be much bigger.

    It is obvious to all reasonable people (and doubtless to the unreasonable ones, too!) that WJ’s challenge is completely justified and the only correct way forward. Unfortunately that won’t stop DEFRA, with their shooting world bias, pushing hard in the other direction wherever they see the opportunity. Knowing WJ is watching and ready to raise public awareness will make them think before they try to get away with things… which is brilliant!

    Phew I’ve completed and submitted the consultation – wasn’t too painful and I’ve learnt something

    Response submitted. I do wish you well with this. We have had gamebirds on land near to us – exotic they may appear, as visitors regularly exclaim when seeing them – but they are a nuisance and do wander from the pens, quite a considerable distance.

    Good evening!

    I have completed my response to the consultation document.  I spent many hours studying it and the  links to try to understand better what it was about and what it would likely achieve. I am just an ordinary member of the public and found the exercise  quite challenging.  I determined I was going to do it so am pleased to have done so.  I would probably have given up if I had not had the guidance from you.  I did a personal response but your suggestions were invaluable. 

    Please keep up the good work – there is so much to do and some of it is quite technical and necessarily political.

    I have responded to the DEFRA consultation on gamebirds along the guidelines you suggested, mainly a cut and paste response. I do very much hope we get some effective regulation of these releases, it is totally out of control at the moment. Some woodlands near me (Buckinghamshire) are in a very poor state, full of release pens and covered in tracks used by quad bikes. 

    Thank you for sending such useful information about the gamebird consultation (without your newsletter I would have had no idea this even existed). I have filled it in using your hints and my own thoughts. DEFRA is not giving the impression that it cares about the environment at all. This is nothing new, but to see it in black and white is still quite shocking.

    Anyway, I just wanted to thank you for everything you are doing and I look forward to supporting you in your future campaigns. I can imagine it is exhausting work. A few months ago I set up a small standing order to you – it’s not much (at all) but I am on maternity leave at the moment (from [a named conservation organisation]) and this is all I can afford. I hope it is useful.

    Thank you again for helping me to have a voice.

    Thank you! Please keep going! I have submitted my response and a made a donation. I no longer feel like such a lone voice. The consultation period is woefully inadequate and not impartial or linguistically accessible to other voices. DEFRA should not be the invincible leviathan it has become. I am shocked at the way it has already joined with the food industry to overturn the ban on the use of neonicitinoids in farming. Thank you for helping to give people and nature a voice.

    I sent my consultation response in yesterday. Followed your helpful advice – thank you – and made the most of the ‘precautionary principle’ with specific reference to my area and the [named] site. Had fun talking about the pheasants in our garden and all over the roads having strayed rather further than 500m

    I wanted to let you know that I have just completed and submitted a response to the DEFRA consultation on game bird release. This is the first time I have ever undertaken such a task but would like to thank you for your helpful notes on how to put our point of view across on this very important matter. It is high time politicians were forced to consider the weight of public opinion in favour of nature conservation and against its exploration by any minority.

    Just to say I have completed the DEFRA consultation; it took me ages but thank you for your suggestions.

    After mulling over it for so long, it almost feels that they threw the document together in the staff room over coffee and roast pheasant sarnies with their (shooting) mates, giggling the while.

    My final comment: the unseemly brevity of the consultation period is a cause of concern, especially in the context of the rapid report involving the shooting industry (and no-one else), resulting in a laughably biased and one-sided set of recommendations forming an embarrassingly low base from which to start. Being even-handed would be a good start.

    We experience  damage caused by pheasants from a local farm, 1000m away, wandering onto our own few acres, all of which we manage  for wildlife. I suspect they may have contributed in part to decreasing numbers of frogs toads and grass snakes in our plot in recent years. It is absurd and unacceptable that the shooting industry  should be at liberty to release game birds into the countryside so near or into areas protected for wildlife.

    Please keep up your hard work. It is wonderful to know that you are there to speak up for, challenge the current law, and fight for our precious wildlife. Thank you to everyone at WildJustice.

  12. Thank you for your responses (3)

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    Many hundreds of you are responding to the DEFRA gamebird consultation and telling us that you have done so – here are some more examples from your emails to us (see earlier selections – click here and here.

    Thank you for responding – every response is valuable, whether you basically cut-and-paste our suggestions, shorten or lengthen them, correct the typos or introduce some of your own, refine or embellish them, or indeed start from scratch and produce your own perfect consultation response.

    The closing date for consultations is Monday so we expect many more people to have a look at this at the weekend and send off a response then. Here are our suggestions for how to respond – click here.

    Here are some more quotes from what you have sent us:

    Just wanted to say a huge thank you for this email. I was able to respond easily with your suggested responses (on my phone with my thumb while feeding my 10 day old son!). I’ll also forward on to family and friends.

    For the first time in my life (65 years and counting) I have sat down and completed a government consultation. This is thanks to you for taking the time to provide me with the tools and information (and inspiration) to do so. I live in the countryside surrounded by trees and, it seems to me a lot of people who do appear to care about nature. Sadly, we seem to also have a number or people, generally wealthy landowners, who care more about exploiting nature to fill their coffers and to hell with everything else.

    I therefore really appreciate all you are doing and the inspiration you give.

    Thank you for providing all the information to fill in the DEFRA consultation on gamebirds. I’ve submitted mine and forwarded your email to birdwatching friends. Fingers crossed!

    Just to let you know I have just filled in the DEFRA consultation it was much easier with your guide points that you posted on Twitter earlier, I don’t think I would have bothered wading through the mire otherwise.

    We have some land which we are rewilding which has glow worms, slow worms and grass snakes (as well as pole cats and dormice) and our next-door neighbours release some pheasants and they just come straight on into ours and hoover everything up. It’s very disheartening.

    Thanks ever so much for everything you guys are doing for nature, you inspire me to get up and go out and do my bit…

    Thank you for emailing me about the government consultation document, which otherwise I would have known nothing about. I have filled it in using your own comments and hope this will be okay. I’m not skilled or knowledgeable enough to compile such answers myself, but i have read them and understand the replies. I will now share your newsletter. It did take a bit of reading, but worth it. Thank you ,

    Just to let you know that I have completed the DEFRA consultation form…thank you for the guidance, it was very helpful.

    It does seem very bizarre that a small minority can release such huge numbers of non native animals into the countryside with no assessment of the environmental impact just because they plan to shoot them…but try and reintroduce a beaver…..!!!

    Following your email this morning I’ve just submitted my response to the game bird consultation – phew!  Hopefully some of what I said even made sense.  Please keep up the work that you do – I think it is amazing and so vitally important. I’m not quite sure how you do it – I definitely need some time to recover from the DEFRA consultation experience!

    Hi thank you for sending out the structured response to the DEFRA gamebird consultation. I have just finished filling it out. No small task even with your excellent structured response. Thank you for being our voice and saying no to this ridiculous activity. Well done for your work in getting DEFRA to evaluate the situation as it stands. Fingers crossed at the very minimum it does mean Buffer Zones will be introduced even if they are not adequate, once the concept is in place it is easier to build from.

    Job done – response sent.

    Well done Chris, Ruth & Mark with taking on the Dinosaurs.

    I have completed the questionnaire. I got more and more angry as I did so. Releasing birds so that humans can practice their shooting skills.  Thank you for bringing this to my attention. 

    Given the scale of unregulated large game birds being released DEFRA should have never allowed the situation to get as bad as it has

    I have just filled in the form and responded.

    I would just like to add my gratitude and admiration for the work you have done in making this possible and also in making a difficult form easier for those of us who are on the side of the environment!

    There was FAR too  much on the form about monetary losses which gamebird releasers might suffer – they are a business – we should not kowtow to their profit margins in looking to save the environment.

  13. Thank you for your responses (2)

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    Hundreds of you are responding to the DEFRA gamebird consultation and telling us that you have done so – here are some more examples from your emails to us (see earlier selection – click here).

    Thank you for responding – every response is valuable, whether you basically cut-and-paste our suggestions, shorten or lengthen them, correct the typos or introduce some of your own, refine or embellish them, or indeed start from scratch and produce your own perfect consultation response.

    The closing date for consultations is Monday so we expect many more people to have a look at this at the weekend and send off a response then. Here are our suggestions for how to respond – click here.

    Here are just a few more quotes from what you have sent us:

    I enjoy your emails and have responded to your various campaigns, as they have always been worthwhile. I don’t always take the effort to write protest emails, but I did take the time to respond to the DEFRA consultation this morning. Much as I trust you all, and certainly a lot more than our current catastrophic government, I don’t like putting my name to anything unless I know enough about the subject. Consequently it took me a lot longer than forty minutes. This is because I felt I had to read the Madden and Sage review. But this did allow me to express your views in my own words, add a few of my own and include some additional facts from the report. Let’s hope that together we can make a difference. As it stands, these particular proposals seem designed to support the status quo (not one of my favourite bands: I consider myself an ageing punk, much like Chris!).

    I submitted my response to the consultation today. Bit of a long winded process but your guidance was really helpful. Here’s hoping they revise the proposal! Keep up the good work. 

    Hi – I’ve responded – wow – what a pig of a consultation – they really don’t want you to answer do they? Thanks for the helpful hints.

    Hi Folks. Just to let you know filled in the consultation survey. Living in Suffolk I am very aware of the game bird industry and what nasty things come with it . I wish you so much luck and thank you for being my voice , Take Care . Keep safe

     Wanted to let you know I’ve just responded (in full) to this, complete with the mini rant below (!) in answer to Part C

    I beleve that Defra should not allow any releases of gamebirds on N2K sites or within a min 1km buffer zone around them for at least 5 years. Also: This consultation has not had a long enough period for responses (only 3 weeks) It is heavily biased towards the shooting industry rather than protection of the countryside. Not only in terms of what would suit the shooting industry but also in biased presentation of so called ‘evidence’ that shooting BENEFITS the environment – when all genuinely independent evidence shows that nearly all the effects and impacts are negative It does not address the negative impacts – including financial – on other residents/businesses eg tourism etc etc – or communities in the countryside in the vicinity of shoots. I know from bitter personal experience how much shoots impact negatively on the wellbeing of those around them . A local wellknown area of great natural beauty and many rare species which is -or was – much loved and treasured by local people has been quite literally trashed by being sold and turned into a shoot for rich incomers who care nothing for the wildlife or local communities. And I can also assure you the birds roam a LOT further than 500m (or even 1km)! 

    Your suggestions were invaluable, I paraphrased but it saved hours of time, thank you!

    Dear Lovely People, Many thanks for the very helpful notes which helped me enormously in drafting my response to DEFRA. I think these government agencies make such consultation exercises as difficult as possible to deter members of the public from challenging their traditional role of supporting the vested interests of wealthy and powerful groups.
    Keep up the good work.

    I have just submitted my response. The 500m buffer zone is as you have pointed out inadequate and I have proposed a 5km buffer zone. When *********** Farming Ltd. took over the surrounding farmland around my village they introduced shooting and despite protests their response was ‘its going to happen whether you like it or not’. However, after numerous complaints to the police the shooting was stopped. Local properties were hit with lead shot, I experienced lead shot whizz past my house on several occasions and lead shot landed next to me whilst walking along the public highway. I have also experienced the shooting of a pheasant directly above my car as I passed by a group of shooters. These people involved in shooting have no respect for anything or anyone, including the law. The legacy of the shooting has left a significant local pheasant population which invade my garden on a daily basis with anything up to 25 birds. These birds cause much damage with their scratching and deprive the native bird species that I try to attract of vital food. Its no wonder so many of our native birds are in decline.

    Mark, Ruth and Chris, I have responded to DEFRA’s consultation. Many thanks for the guidance notes – great focus but I chose to put it in my own words. Keep up the good work.

  14. Thank you for your responses

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    We have been amazed by the number of people who have already told us that they have responded to the DEFRA gamebird consultation. This is an issue about which many ‘ordinary’ people, many living in the countryside, feel very passionate.

    Thank you for responding – every response is valuable, whether you basically cut-and-paste our suggestions, shorten or lengthen them, correct the typos or introduce some of your own, refine or embellish them, or indeed start from scratch and produce your own perfect consultation response.

    The closing date for consultations is Monday so we expect some people to have a look at this at the weekend and send off a response then. Here are our suggestions for how to respond – click here.

    Here are just a few quotes from what you have sent us:

    Hi team Wild Justice,

    I’ve been waiting for your email.

    I will certainly be responding to the DEFRA consultation despite concern of retribution from local gamekeepers. Thank you for the prompts for submitting my response.

    I’m boiling with rage at the narrow scope of this consultation and time window as I’m sure that you are !!!

    Please keep up the good work. Thanks for getting us this far whatever the outcome. I’ll keep the (modest) financial support coming for this and your other initiatives.

    parts of a much longer communication

    Thanks for being brilliant. Carry on doing an excellent job on our behalf please. 
    Game bird consultation response done.

    Response submitted (copy attached). Good luck.

    from a professor who proposed a 1500m buffer zone

    Thank you for circulating this, I have now submitted my response. I am appalled at the bias towards the shooting industry that was evident from the wording of the consultation. I can see a long fight ahead – keep up your great work.
    Best regards and warm wishes

    Greatly admire your sterling work fighting the corner for British wildlife against such powerful vested interests.

    Just to mention that I did respond. Distressing stuff indeed with a clearly stated intention of only pursuing a 3-year interim licencing regime, excluding 87 sites without any research/evidence basis, setting down a 500m buffer zone without adequate evidence , ignoring economic impacts and ecological/services impacts through selection of only 2 research components to be studied namely soil eutrophication and depletion of vegetation. I don’t see any evidence of research appreciation or need or “letting the science decide”.

    Dear  Mark Avery, Chris Packham and Ruth Tingay,

    Just to let you know that I completed the consultation and sent it in to DEFRA by email today,

    Best wishes,

    Filled in consultation and submitted.

    Signed petition too.

    Good luck and thank you for highlited quotes.

  15. How to respond to the DEFRA gamebird consultation

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    Seven week old pheasant poults, after being released into a gamekeeper’s release pen on an English shooting estate

    What the consultation is all about: Because of Wild Justice’s legal challenge settled in court last October DEFRA must  take measures which will protect sites of nature conservation importance in England from the impacts of vast numbers of Pheasants and Red-legged Partridges released for recreational shooting.  This consultation is necessary for DEFRA to regulate the release of non-native gamebirds so obviously we think it is important and we would encourage organisations and the general public to respond. You are entitled to respond wherever you live in the UK, and nudging DEFRA in the right direction should have implications for measures to be taken in Scotland, Wales and Northern Ireland.

    Responding to a government consultation is not a bundle of laughs, and it may take around 40 minutes to get it done.  Pro-shooting organisations are asking their supporters to send in responses, and we are sure that many of them will – it would be very helpful if you, as an individual, could make your views known too. What follows is our attempt to help you to do that. Wild Justice will make its own, more technical, response to the consultation.  

    Introduction to filling in the consultation:  the DEFRA gamebird consultation can be found here – click here. You can fill the form online (click here) or print it out, fill it in and pop it in the post (click here). Hint: reading the pdf version first to get an overview and then filling in the online version is a good way to do it.  

    The structure of the consultation: there are some brief questions about yourself and then four main sections;  Parts A – D. You don’t have to fill in each section. Indeed, Part D asks for feedback on the form where DEFRA is hoping you say that it was a bundle of laughs. You could safely ignore Part D or answer it in very few words. Part C asks you to suggest an alternative way forward to DEFRA’s proposals. You could safely ignore this section or answer it in very few words but we suggest that you do use that section and we suggest some points to make in it.  Part B asks you to fill it in only if you are an interested party who releases gamebirds into the countryside. We’re pretty sure that most readers of this blog do not fall into that category so you can safely ignore Part B. So really it is Part A that forms the main consultation response and that is the longest section but it isn’t too scary once you have a good look at it.   Below we take you through the consultation and the purple text indicates words that you might use in your response. At least they’ll give you some clues as to things that we think it is important to say.  

    Filling in your details – that’s easy  

    Completing Part A;

    Q A1: No, and then fill in the text box along these lines DEFRA is proposing an interim licensing regime. That should start in the most precautionary way and then remove restrictions on the basis of evidence as time passes. DEFRA should not exclude the list of sites in Group 2 for four main reasons; precaution, clarity, error, futility. This licensing regime must protect SPAs and SACs (hereafter referred to as N2K sites) from damage. It is not precautionary to remove sites before they have been properly assessed. The clearest measure for users is to include all sites in these interim licensing measures and adjust the list over time when better knowledge is available. There are sites in this list which are both SPAs and SACs and yet it is unclear whether both sites are affected and there are overlaps between sites which are and aren’t mentioned in Group 2. There are sites in this list which are vulnerable to impacts of eutrophication and are proposed for exclusion in error. We accept that some of these sites will not be affected by gamebird releases because gamebirds won’t ever be released on or near them – excluding them is therefore futile. This list looks like a rushed and inadequate job. See my response to Part C.  

    Q A2: No, and then fill in the text box along these lines This very consultation states that most studies of gamebird movement have been restricted to 300m and so cannot have looked at issues at greater distances. Moreover, the Madden and Sage review quotes studies that show that both gamebird species travel further than 500m. Those studies are mostly limited to the shooting season. Moreover, the 500m buffer erroneously appears to be based only on known impacts of droppings and physical disturbance and ignores issues such as predation of reptiles and amphibians, increases in predator populations as a result of increased gamebird carrion  etc. The GWCT’s Head of Advisory said on BBC Radio4 recently that ‘The majority of birds [Pheasants] don’t disperse more than a kilometre’ so a 500m Buffer Zone is clearly inadequate. You ask whether a 500m buffer zone will ensure that releases do not cause deterioration or significant disturbance of protected features of N2K sites and the answer is most definitely No as it is not based on science and is not precautionary. See my response to Part C.

    Q A3: Yes and then fill in the text box along these lines But not sufficiently effective to meet the requirement of protecting N2K sites.

    Q A4: No, and then fill in the text box along these lines This proposal allows releases to continue in undiminished numbers according to guidelines that are out of date (they were published in 2007) and where compliance is admitted by the shooting industry itself to be extremely poor (see ). These proposals do not limit the numbers of birds released, nor the number of release sites, nor their locations, only the densities of birds within release pens. These measures are totally inadequate and if implemented DEFRA will not be fulfilling its obligation to ensure that N2K sites are protected from damage. No gamebird releases should be allowed on N2K sites or in the Buffer Zone around them as the first step in licensing gamebird releases. See my response to Part C.

    Q A5: Yes and then fill in the text box along these lines This is welcome and very important as a first step in effective regulation.

    Q A6: Leave blank.

    Q A7:  I do not believe there should be any gamebird releases within the Buffer Zone. This is what is needed to protect N2K sites.

    Q A8: I do not believe there should be any gamebird releases within the Buffer Zone. This is what is needed to protect N2K sites.

    Q A9: Do not tick either Yes or No and then fill in the text box along these lines I agree with this and my representation is that this measure is essential and urgent.

    Q A10:  Do not tick either Yes or No but fill in the text box along these lines I agree with a sunset clause but I disagree that it should be after two years as this is too soon for the necessary research, analysis and consultation to be carried out. As far as I am aware DEFRA has not commissioned independent research or monitoring, nor provided Natural England with sufficient resources to carry out the necessary work. A period of at least five years is needed even if such resources are made available.  

    Completing Part B:

    Q B1: if you are not a gamebird releaser then answer No and move on.  

    Completing Part C:

    Q C1: Yes and then fill in the text box along these lines   My proposal is that DEFRA scraps Group 2 sites, institutes a 1km Buffer Zone around all N2K sites and that no releases of Pheasants or Red-legged Partridges should be permitted for a 5 year period in that zone or on any N2K sites. That is a precautionary, clear and effective interim arrangement that protects nature. If appropriate, these modest restrictions can be loosened on the basis of good evidence in future.  

    I would like to make some further points.  

    a.  I do not consider this consultation to have been properly conducted as it lasts only three weeks, was delayed and DEFRA has imposed ludicrously short word limits on answering complex questions.  

    b. DEFRA appears to have written the consultation with measures that the recreational shooting industry would want rather than ones which ensure protection of N2K sites of conservation importance.  

    c. This consultation clings to the myth of 500m being an adequate Buffer Zone despite DEFRA being well aware that there is little scientific evidence to support this (see here ) and so this consultation is knowingly misleading. And in any case, the measures proposed to apply to the Buffer Zone are nugatory.  

    d. Part B does not in any way properly address economic impacts, which in any case must be subservient to the need to protect N2K sites from damage. Since the measures do not limit overall release numbers, and hardly limit current practice, there can be no overall economic impact. The consultation simply invites unverifiable moans about impacts from the very industry that needs to be regulated in order to protect the environment. At most, any restrictions on release numbers locally can create opportunities for releases in less sensitive sites and so others, who are not invited to comment, will benefit. At this stage it is unclear whether, or to what extent, recreational shooting will be possible in any case in the 2021/22 shooting season because of COVID-19 restrictions. Further, there are economic impacts of gamebird releases on the general public which are completely ignored in this consultation.  

    Completing Part D: voluntary.  

    That’s it!     

    Remember, the deadline is Monday.  The more responses DEFRA gets the better. We’d be delighted to hear that you have responded – send us an email if you like. We hope this advice helps but you should make any points you wish and in any way you wish. If you have questions or queries about filling in the consulation then we may be able to help – email us at and give your email the title GAMEBIRDS and we will try to help but we cannot promise that we’ll be able to answer long or complex questions very quickly – we’ll do our best.

  16. Please sign #StateOfNature petition today!

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    Good morning!  

    Wild Justice is one of over 50 wildlife groups asking you to send a strong message in favour of wildlife to the Westminster government. 

    Today sees the launch of a major campaign to persuade Boris Johnson to add an amendment to the Environment Bill to set a legally binding target to reverse the loss of nature in England by 2030.

    Please add your voice to the #StateOfNature petition today – click here.   

    Even the Prime Minister’s father, Stanley Johnson, has written to ask for this amendment to be added!  

    Although the Environment Bill mostly deals with English matters we would ask all of our supporters, wherever they live, to sign the petition – you’ll be doing English wildlife a favour. And on this St David’s Day, and after Wales whipped England at rugby on Saturday, it would be particularly kind of supporters in Wales to do so.  

    Wild Justice is very happy to be part of this campaign and we hope we might be the first organisation to ask for your support.  We’ll be reminding you of the petition as the campaign gains momentum through the spring, but today you can be one of the people to get it off to a strong start.  

    Please add your voice on Day 1 of this campaign – sign here.  

    Thank you!

    PS And you can see that this campaign has support from a massive range of organisations including all of the big beasts of nature conservation, as well as lots of the tiddlers like Wild Justice.

  17. DEFRA launches gamebird consultation

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    This consultation was released today – over two weeks later than we were told. The consultation period is three weeks, closing Monday 15 March.

    This consultation is obviously of great importance to Wild Justice as it was our legal challenge which caused these measures to be proposed by DEFRA as laid out in this consultation. we would encourage interested parties to read the consultation carefully and to respond to it.

    We will evaluate the consultation document and reveal our thoughts through our free newsletter, probably on 8 or 9 March – click here to subscribe.

  18. In the post

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    Last week, a package arrived for Wild Justice in the post and it contained a cheque, a letter and some knitted keyrings in the shape of leaves.

    Here is most of the text of the letter – it is well worth a read.

    Dear Wild Justice

    Please find enclosed some knitted keyrings that I have made for you all.

    I also enclose a cheque to show my support for the magnificent work that you all do. Keep it up! I know that it can feel as though you are banging your head against a brick wall, but, rest assured, you are chipping away at ancient walls of cruelty and unfairness. Any time now they will come tumbling down. Well done for all the campaigns you have fought. Maybe not won them all, but you are getting the word out there and raising the profile of important issues.

    I have felt powerless, as a ‘little person’ watching the world go to hell in a handcart whilst I am forced into lockdown.

    At New Year I made a resolution – to be a Craftivist, We make gifts to give to people or to display publicly trying to persuade them to change their minds by a positive act, rather than negative arguments. I decided that I would knit leaves and make them into keyrings to give to my local councillors and to the Mayor of Greater Manchester. In my letter I explain how important green spaces are – not only to wildlife but to our own physical and mental wellbeing. My request is that they work towards saving as much of the green belt as possible from the impact of new house building. I am hoping that each time they use my keyring it will remind them of that request.

    I am well on the way to completing that project, but green wool is at a premium. I thought I’d take a break and knit some in different colours for people that I know are on my side. Is there enough green wool in the world to change those minds? I live in Hope.

    Isn’t that lovely? And isn’t it inspiring?

    We get lots of messages from supporters and all of them are read by us. It really is good to know that so many people support what we do. Thank you.

    To be kept up to date with our work please subscribe to our free newsletter – it’s how we aim to give our supporters our most up to date news (roughly once a fortnight) – click here.


  19. Sainsbury’s game meat

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    There’s a slogan on Sainsbury’s website stating that its vision is to become the UK’s ‘most trusted retailer’. Some might say it’s got a long way to go.

    In October 2020 we became aware that Sainsbury’s was stocking two products of interest: pheasant breasts and a mixed-game casserole (venison, pheasant & partridge).

    Both products were being manufactured by Holme Farmed Venison, a company based in North Yorkshire which, according to the product packaging, ‘sources Pheasants and Partridges from Traditional UK Estates, renowned for the quality of their birds, and within the guidelines laid down by the British Game Alliance using ‘The Code of Good Shooting Practice’’.

    Both products displayed the British Game Alliance (BGA) kite mark prominently on the packaging’s front sleeve but neither product included a warning to customers that the meat may contain toxic lead ammunition, a known poison that the Food Standards Agency advises is especially dangerous to young children and pregnant women.

    The BGA claims to be ‘the official marketing board for the UK game industry’ and claims on its website, ‘Through our ‘British Game’ assurance scheme we can ensure the provenance of our game meets rigorous and ethical standards‘.

    However, some of us aren’t convinced by the BGA’s claimed credentials, especially when we know that some of the BGA’s accredited members are currently being investigated by the police in relation to alleged wildlife crimes.

    So given this lack of transparency and thus confidence in the BGA, rather than taking the BGA’s word about these products we’ve asked Holme Farmed Venison to provide further detail about the provenance of their gamebirds and Sainsbury’s has been asked, repeatedly, whether these products contain any toxic lead ammunition.

    Holme Farmed Venison has not yet responded.

    Sainsbury’s has responded, with a generic corporate response:

    HFV products only select from meat that has no shot in it. Initially, visually inspected and then metal detected at the game processor and again visually inspected in the final pack”.  

    In a shocking display of complacency about its customers’ health concerns, Sainsbury’s went on to tell one customer:

    At present Sainsbury’s will not be providing any further update regarding your concerns, and we would encourage any further questions to be directed to Holme Farmed Venison, through their customer helpline‘.

    Since Sainsbury’s seems so reluctant to safety- test this food product it’s selling to families, we thought we’d do it ourselves.

    Over the last month we’ve bought some of those pheasant breasts and mixed-game casseroles from various Sainsbury’s stores and have prepared a series of samples using a rigorously-scientific process. These samples have just been shipped to a specialist laboratory where an experienced scientist will examine them to determine whether they contain any toxic lead ammunition and if so, in what quantities.

    The results are expected later this spring.

  20. It’s our birthday – we are two

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    Two years ago today we launched Wild Justice.

    Since then our action has:

    • led the reform of general licences across the UK
    • led to better protection of designated wildlife sites through increased regulation of recreational wildlife shooting.
    • challenged the licensing of Badger shooting in the courts (we are waiting for an appeal hearing) and through a petition which already has over 104,000 signatures – please click here.
    • put pressure on governments in England and Scotland through an e-action taken by 123,000+ people (together with RSPB and Hen Harrier Action) to protect blanket bogs from harmful burning and give birds of prey effective protection on grouse moors – we have seen progress (not enough) on both issues.

    In addition we have worked with other wildlife organisations on campaigns and advocacy across a wide range of conservation issues.  

    It’s not a bad start!

    There’s much more work for us to do and we have started several projects about which we will be able to tell you as they unfold over the coming weeks. Some are Wild Justice projects, and in others we are working collaboratively with other wildlife conservation organisations.  

    To hear about our work – subscribe to our free newsletter – click here.

    If you like what we are doing then please consider making a donation through PayPal, bank transfer or a cheque in the post – see details here. A small birthday present would be much appreciated – thank you.

  21. We write to DEFRA on their consultation failure

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    Seven week old pheasant poults in a gamekeeper’s release pen on an English shooting estate

    Back in October, Wild Justice won a historic victory regarding the regulation of shooting when DEFRA committed to bring in regulation of gamebird releases because of their impacts on sites of high nature conservation importance – see here.

    Wild Justice withdrew its legal challenge because DEFRA committed to do various things including adding the non-native Pheasants and Red-legged Partridges to Schedule 9 of the Wildlife and Countryside Act, creating a buffer zone around important sites in which no gamebirds will be released etc.

    Those commitments were made binding in a court order which ended the case:

    For months, DEFRA has intended to issue a consultation on the measures it will introduce, as it is required to do. Wild Justice has been looking forward to the consultation as it represents an opportnity for public pressure and evidence to strengthen the measures that DEFRA will take. That consultation was promised for this Monday, 8 February but on Monday afternoon DEFRA issued a curt email (referred to here) in which they only committed to launching the consultation in ‘the coming weeks’.

    Yesterday, Wild Justice wrote to DEFRA as follows;

  22. Our badger petition passes 100,000 signatures

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    Yesterday our petition to end the shooting of Badgers passed 100,000 signatures. Thank you for all your support.

    This means that it will, eventually, be debated in Westminster Hall by backbench MPs and a government minister will have to respond. Petitions of this type rarely, of themselves, change government policy but they keep up the pressure for change.  We would like to increase that pressure and will continue to promote the petition to gain more signatures right up until midnight on 24 March when it closes. 

    Support for the petition has come from right across the UK but has been particularly strong in those areas where Badger culling is taking place such as the southwest counties of Cornwall, Devon, Somerset, Dorset and Gloucestershire, and also in Derbyshire where plans for Badger vaccination were well-advanced but have been disrupted by government pushing ahead with culling.

    See the map of strength of support by Westminster parliamentary constituency here:

    Why we care so much:

    1. We care about Badgers and over 20,000 were shot in 2020, and in 2019 and DEFRA plans allow for tens of thousands more to be killed in the future. This is a massive government-sanctioned assault on a protected species.

    2. We care about farmers and cattle too, and we see the Badger cull as a distraction from the main means of controlling bovine TB in cattle: better testing, movement restrictions and vaccination as recommeded by a recent report by Sir Charles Godfray FRS.  

    3 Shooting Badgers is cruel – this government has never stuck to the recommendations of an expert group in 2014 that 95% of shot Badgers should die within 5 minutes of being shot – the usual figure is always around double that level and some Badgers take more than 10 minutes to die. We believe that monitoring is inadequate. 

    How you can help:

    1. If you haven’t signed this petition yet then please consider signing now, here is the link – click here.

    2. Ask your friends and colleagues to sign too please. You could send them this link to the petition

    3. If you use social media such as Twitter, Facebook etc then spread the word there please. By the way, our Twitter handle is @wildjustice_org

    4. Please note that the petition can be signed by anyone resident in the UK (not just in England, even though this is an English cull) and also by UK citizens resident abroad.  

    Thank you for your support.

  23. GWCT gets a ‘fail’ from us on its homework

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    In a blog here on Monday we asked the GWCT to fact-check the DEFRA myth that non-native gamebirds have no impacts on nature conservation at a distance of further than 500m from release sites.

    We asked three specific questions and GWCT has failed to answer two of them (but got the other one right – maybe because we gave them the answer). Any student knows that you should read the exam paper carefully and do your best to answer the questions. GWCT failed to answer the questions and did what many a failing student does – write down everything they can think of that pops into their minds in case it might be relevant. That’s a fail.

    We got something wrong too on Monday though – when we wrote ‘We appreciate that GWCT might feel uncomfortable correcting the factual errors of the Secretary of State for the Environment, Food and Rural Affairs but we are sure they will wish to stand by the scientific statements of their staff in preference to sucking up to DEFRA. we assumed that GWCT would stand by their own staff member in addressing question 3 which was:

    Does the GWCT stand by the view of their own Head of Advisory, Roger Draycott, who on BBC Radio 4’s Farming Today said, and we quote, ‘the majority of birds [Pheasants] don’t disperse more than a kilometre‘ which clearly means that some disperse more than a kilometre and suggests that many disperse further than 500m.

    We were wrong because GWCT have not stood by their own staff member, Head of Advisory no less, who said that some Pheasants disperse more than a kilometre and GWCT instead did choose to support DEFRA’s flawed buffer zone proposal. If you are taking advice from the GWCT just be aware that they might not stick by it if a politician says something else. So that’s a fail because GWCT didn’t even remember to answer the question.

    What about the other two questions?

    Question 1 was;

    Does the Madden and Sage review (see here, and Rufus Sage is, after all, a staff member of GWCT) mention anywhere that Pheasants and Red-legged Partridges have minimal impacts on biodiversity beyond 500m from the point of release? (hint – it doesn’t)

    GWCT do answer this question (although you have to look hard for the answer and they only attempt an answer in their twelfth paragraph) where they say ‘500m is not explicitly discussed in the review’. Yep, that’s what we thought, and said, and so GWCT at least get a few marks for anwering that question (eventually) and noticing that nowhere is a 500m buffer zone suggested, discussed or justified in that review. The answer was contained in the question though so GWCT don’t get many marks for that. The 500m buffer zone is simply a made up figure and it isn’t made up based on the science.

    Question 2 was;

    Do the references in Madden and Sage (eg Turner (2007), Beardsworth et al. (in prep), Sage et al. (2001)) state that Pheasants and Red-legged Partridges travel no further than 500m from their point of release in their first year of life?

    GWCT do not answer this question so that’s a Fail here too. What they do say is that they think 500m is too big a distance, whereas we think it is too small. We cite the relevant references in the Madden and Sage review and discuss why they do not in any way add up to justifying a buffer zone as small as 500m while the GWCT just wave their hands around and support the DEFRA 500m buffer zone myth without citing any science.

    Like a poor student, GWCT pad out their non-answers with lots of words to try and make it look as though they know lots and have been working extra-hard – but their homework adds up to ‘There is no scientific justification for a buffer zone as small as 500m but we know which side our bread is buttered so we are going to agree with DEFRA’.

    You’ll find that GWCT spend more time writing, inaccurately, about Wild Justice than they do about the biological issue at question. That speaks volumes too. We’re not going to respond to those inaccuracies here and now because that would deflect from our main message – the proposed 500m buffer zone is not based on science and even the supposed experts on gamebirds, GWCT, cannot point to its scientific justification. That alone should be enough to persuade you that there isn’t a scientific justification for it. We think that DEFRA will launch their consultation on the subject on Monday and then you will have the chance to say so.

  24. GWCT, please check these statements

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    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate.

    Wild Justice mounted a legal challenge to make DEFRA review harmful gamebird impacts which concluded last October when DEFRA agreed to license non-native gamebird releases – see here.

    We expect DEFRA to issue a public consultation on their plans a week today. We will encourage our supporters to respond to that consultation – to receive hints and information then subscribe to our free newsletter – click here.

    We expect one of the key issues (on which we believe DEFRA must do better) will be to increase the buffer zone around designated sites in which gamebird releases will not be allowed. At present, as best we can tell, DEFRA are planning a 500m buffer zone. We have written to DEFRA pointing out that their suggested buffer zone is not based on science and certainly not based on the review of the subject which Natural England (and BASC!) commissioned.

    This is a statement from George Eustice (Mr Eustice is a Cabinet minister and a farmer but not a professional biologist):

    The negative effects of gamebird releases on protected sites tend to be localised with minimal or no effects beyond 500m from the point of release.

    This statement has, as far as we can see, no basis in fact (see this long blog by Mark Avery).

    The Game and Wildlife Conservation Trust set up a fact-checking website last August – see here. We believe that DEFRA’s statement (which may have come from Natural England originally) is in serious need of checking and then correction.

    Here are areas where we would like GWCT to check the facts (and anyone else who wants to investigate the matter can do the same);

    • Does the Madden and Sage review (see here, and Rufus Sage is, after all, a staff member of GWCT) mention anywhere that Pheasants and Red-legged Partridges have minimal impacts on biodiversity beyond 500m from the point of release? (hint – it doesn’t)
    • Do the references in Madden and Sage (eg Turner (2007), Beardsworth et al. (in prep), Sage et al. (2001)) state that Pheasants and Red-legged Partridges travel no further than 500m from their point of release in their first year of life?
    • Does the GWCT stand by the view of their own Head of Advisory, Roger Draycott, who on BBC Radio 4’s Farming Today said, and we quote, ‘the majority of birds [Pheasants] don’t disperse more than a kilometre‘ which clearly means that some disperse more than a kilometre and suggests that many disperse further than 500m.

    We appreciate that GWCT might feel uncomfortable correcting the factual errors of the Secretary of State for the Environment, Food and Rural Affairs but we are sure they will wish to stand by the scientific statements of their staff in preference to sucking up to DEFRA.

  25. Badger petition update

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    Badger. Photo: Chris Packham

    Our e-petition has passed 88,000 signatures with several thousand signatures being added yesterday. Yes, we had given this petition a bit of a rest for a few weeks but now is the time to get it moving quickly and pass the 100,000 signature threshold which will entitle it to a debate in Westminster Hall (eventually).

    Derbyshire Dales still leads the list and approaches 500 signatures.

    This is a very Conservative, English and rural list – here are the constituencies with >250 signatures:

    Derbyshire Dales, Sarah Dines MP, 496 signatures

    High Peak, Robert Largan MP, 425 signatures

    Stroud, Siobhan Baillie MP, 390 signatures

    West Dorset, Chris Loder MP, 355 signatures

    Isle of Wight, Bob Seely MP, 335 signatures

    Wells, James Heappey MP, 342 signatures

    Torridge and West Devon, Geoffrey Cox MP, 325 signatures

    St Ives, Derek Thomas MP, 324 signatures

    Sheffield Hallam, Olivia Blake MP, 306 signatures

    Brighton Pavilion, Caroline Lucas MP, 294 signatures

    Lewes, Maria Caulfield MP, 288 signatures

    Devizes, Danny Kruger MP, 288 signatures

    Amber Valley, Nigel Mills MP, 287 signatures

    Bridgwater and West Somerset, Ian Liddell-Grainger MP, 285 signatures

    Shrewsbury and Atcham, Daniel Kawczynski MP, 283 signatures

    Bristol West, Thangam Debbonaire MP, 280 signatures

    Chippenham, Michelle Donelan MP, 279 signatures

    Somerton and Frome, David Warburton MP, 278 signatures

    Truro and Falmouth, Cherilyn Mackrory MP, 277 signatures

    Caldr Valley, Craig Whittaker MP, 273 signatures

    Mid Derbyshire, Pauline Latham MP, 271 signatures

    Camborne and Redruth, George Eustice MP, 271 signatures

    South Norfolk, Richard Bacon MP, 270 signatures

    Totnes, Anthony Mangnall MP, 270 signatures

    Rushcliffe, Ruth Edwards MP, 268 signatures

    Hastings and Rye, Sally-Anne Hart MP, 265 signatures

    Central Devon, Mel Stride MP, 261 signatures

    Arundel and South Downs, Andrew Griffith MP, 260 signatures

    Rutland and Melton, Alicia Kearns MP, 258 signatures

    North Devon, Selaine Saxby MP, 258 signatures

    North Norfolk, Duncan Baker MP, 258 signatures

    Skipton and Ripon, Julian Smith MP, 253 signatures

    Suffolk Coastal, Therese Coffey MP, 252 signatures

    Ceredigion, Ben Lake MP, 252 signatures

    North Shropshire, Owen Paterson MP, 252 signatures

    Please have a look at this petition and sign it if you can – thank you!

  26. Natural England slowly begins to get a grip on casual killing of birds

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    The National Gamekeepers’ Organisation is grumpily coming to terms with the changes to their job description that we explained back at the beginning of January – no longer can one kill corvids to protect released non-native gamebirds such as Pheasants and Red-legged Partridges and the conservation licence can only be used to ‘protect’ a list of species of conservation concern.

    On designated wildlife sites such as SSSIs in England the general licences do not apply unless specifically authorised by Natural England. Rightly, Natural England is refusing licences for casual killing of corvids on spurious conservation grounds and wrongly gamekeepers are moaning about it. This is just Natural England beginning to do its job and stems from the changes brought about as a result of the Wild Justice legal challenges. Have a look at the Natural England letter which spells this out – click here. [By the way, the letter isn’t perfect and we’ll be pointing this out to Natural England.]

    Wild Justice hasn’t changed the law, but we have changed the way that long-existing laws are now being implemented (see this Wild Justice blog from late December).

    Those responsible for casual killing of millions of birds over the years aren’t best pleased by these reforms. We see the gamekeepers are suggesting they might take legal action against Natural England on this matter. They probably won’t, but Wild Justice would be willing to help Natural England with the legal arguments should any such legal challenge arise.

  27. Making payments to our bank account

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    We bank with Triodos Bank because we like their environmental credentials – and they are efficient and friendly.

    Over the last few weeks we’ve had a few donors saying that they have had difficulty in transferring money from their bank to ours because they get a message saying that the name (Wild Justice) is not recognised or verified (or something like that).

    This is not because there is anything wrong with our bank account, nor anything wrong with Triodos Bank, it’s because the Confirmation of Payee system which was introduced last year does not yet include many of the smaller banks, such as Triodos. Triodos is in the queue to join this system and expects to get there later this year.

    So, in our case, if you see that message when you are trying to donate to us through bank transfer you can safely go ahead with your donation provided you are using the bank details on our website.

    However, we wouldn’t want our supporters to do anything that felt a bit scary so if you see a message like that one then please find another way to send us some money (PayPal or cheque through the post) or simply hang fire and send us a donation at a later date. Whatever suits you best.

    By the way, we receive about 125 donations through bank transfers each month, many of them regular monthly payments, so the system is working for lots of people.

    Thank you for all your continuing moral and financial support. Both mean a lot to us.

  28. Further success on general licences – this time in Wales

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    Earlier this morning, His Honour Justice Jarman handed down his judgment on Wild Justice’s judicial review of Natural Resources Wales’s general licences. His judgment further limits the casual killing of birds under general licences and has implications for general licences in other parts of the UK. 

    Wild Justice is delighted at the content of the judgment, and its implications, even though the judge did not go as far as saying that the current licences are unlawful.  

    The judgment:   The Wild Justice challenge of the Welsh general licences concerned the circumstances under which the licences can lawfully be used.  And our main concerns were about the conservation licence (GL004) which authorises the killing of four corvid species (Carrion Crow, Magpie, Jackdaw and Jay) for the purpose of conserving wild birds.   The judgment considered the following; For example, carrion crows, of which there are about 20,000 pairs in Wales, prey upon the eggs and chicks of ground nesting birds, such as curlews, of which there are less than 400 pairs left in Wales.‘ and later stated ‘Thus, in the example given above NRW accepts that the relevant licence (004) should be used only to kill crows during the months between egg laying and when the chicks are well grown, namely April to July, and only in those areas where curlews nest, which do not extend to urban areas.  It should not permit someone to kill a crow in the autumn or in an urban area on the basis that that bird might someday at some place take a curlew’s egg or chick.‘.  In other words, you can only kill Carrion Crows under this licence where the Carrion Crows are a present danger to species of conservation concern – in those places at those times. Wild Justice believes that this is a highly significant and very welcome clarification.   Justice Jarman further wrote ‘Written evidence was filed on behalf of WJ by one of its directors, Dr Mark Avery, on behalf of NRW by one of its managers Dr Sarah Wood, and on behalf of BASC by Glyn Evans, one of its heads. Whilst there was some disagreement between Dr Avery and Dr Wood, there was little if any difference between them on how the licences given for the purposes stated in them should work in practice.  Mr Wolfe [counsel for Wild Justice] made it clear that WJ welcomed such clarification but submits that these clarifications should have been expressly imported into the wording of the licences. He points to the fact that Mr Evans interprets the licences more widely than NRW, and submits that that is a cogent reason why the licences should specify the circumstances of their use in greater detail.‘.  In other words, the licensing authority (NRW) agrees with Wild Justice that the licence should only be used where there is a ‘present risk’, and the court agrees with us both, but BASC had a different view which was rejected by the court.  

    What should happen now:  

    1. Wild Justice calls on NRW immediately to clarify the details of their conservation licence. This only requires changes to a web page to reflect what NRW told the court it intended those licences to mean. Not to do so would constitute ongoing casual drafting of a licence which authorises otherwise unlawful actions.   

    2. Wild Justice believes these same issues appear to apply to the ‘livestock and crops’ licence (GL001) and so farmers should be aware that they may be acting unlawfully if they carry out ‘pest control’ at inappropriate times of year or in the ‘wrong’ places. This is not, currently, a matter of the highest priority for Wild Justice as all along we have concentrated on the ‘conservation’ licence GL004. But this judgment does have implications for other casual bird killing.  

    3. If NRW fails to move rapidly to clarify licence GL004 in line with what they told the court, and the court’s judgment, then Wild Justice may seek to gain evidence for private prosecutions of people killing Carrion Crows, Magpies, Jackdaws or Jays outside of the bird breeding season.   

    4.  What does this mean for England where DEFRA have, after a consultation, issued similar general licences for similar purposes? There is one important difference in the conservation licence for England as the NRW licence stipulates that it is to protect eggs and/or chicks from corvids whereas the DEFRA licence does not have that same helpful and biologically realistic detail (of eggs and chicks) attached to it.  Wild Justice has asked DEFRA for clarification of whether DEFRA believes that its licence can lawfully be used outside the breeding season for those species alleged to be protected by its conservation licence (and whether it regards corvid killing at all locations as being authorised by their licence) – as yet DEFRA has failed to clarify these points which now require urgent clarification by DEFRA for England just as they do by NRW in Wales.  

    5. Wild Justice will not be appealing the decision of Justice Jarman and we thank him for his clear, polite and helpful judgment on this matter.  

    6. In passing, Wild Justice would like to thank BASC for their intervention in this case. In our opinion, BASC’s presence did nothing to change the course of this court case, which hinged on the law, except that it made it abundantly clear that BASC wished the licences to be interpreted in a much broader way with none of the restrictions of time of year or location that NRW, Wild Justice and now the court understand them to have. We thank BASC for demonstrating the impacts of the vagueness of the current published NRW licences.    

    Dr Mark Avery of Wild Justice said: ‘We are very pleased. We expect NRW to move very quickly to clarify their online general licences in line with this important judgment. DEFRA too should consider the wording of its general licences for England’.

    Justice Jarman’s judgement can be read here:

  29. Ban driven grouse shooting debate postponed again

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    The forthcoming Westminster Hall debate on banning driven grouse shooting, triggered by our successful 2019 petition and scheduled to take place at 6pm on 25 January 2021 has been postponed again, due to Covid.

    A note from the Petitions Committee clerk says, ‘The House has agreed to suspend sittings in Westminster Hall until further notice. This means that petitions debates that were due to take place in the coming weeks are unable to go ahead, and have been postponed‘.

    We await further information from the Committee in due course.

  30. We’re waiting patiently

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    We are waiting patiently for the judgment on our judicial review of the Welsh general licences. There is no point in speculating on what the result will be as we have nothing much to go on. We’ll just have to wait and see.

    Most judicial reviews are unsuccessful – that’s the way things go. We are hopeful that the judge will say that NRW’s general licences are unlawful, in which case they will have to be rewritten and that would have implications for general licences in England and Scotland too. But let us imagine that the judgment goes the other way and the judge says that the current licences are lawful, there may still be elements of his judgment that help define more clearly aspects of the licensing system – that might be very useful and important in itself.

    So, we’ll have to wait and see.

    But we don’t have to wait and see to know that NRW’s general licences are very poor things (whether or not they are lawful). They allow the Jay to be killed for alleged conservation purposes while no conservation organisation kills Jays anywhere in the UK to the best of our knowledge. And they allow the purpose for which you can kill species to be for the protection of the eggs and chicks of species that have never nested in Wales. the conservation licence specifically says that it is to protect eggs and chicks but it leaves the circumstances under which you can take that action very unclear – can you cull Carrion Crows in November to protect some eggs and chicks somewhere or other in Wales next spring? Or not?

    If driving licences or TV licences were written with such lack of clarity then there would be uproar. We think there should be uproar over the casual licensing of the casual killing of birds in Wales. Wild Justice believes that NRW is not doing its job properly and that whether or not its current licences are unlawful (we think they are) they are such awful licences that NRW should be upgrading them as a matter of urgency.

  31. This is a surprise…

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    This petition was submitted in July 2019, published by the Westminster Parliament in August 2019, reached 100,000 signatures in September 2019 and closed because of a general election in November 2019 … and debated in January 2021!

    It’s a pity that this is in the middle of Winterwatch – just a coincidence no doubt.

    Watch this space for suggestions of how you can help.

  32. What will DEFRA do?

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    Thanks to the legal challenges made by Wild Justice, and our subsequent lobbying and that of others, the general licences in England have improved significantly in the past two years: there are fewer species that can be killed and for much more specific purposes than before. And some species have been removed from the general licences altogether and so now anyone with a good reason for lethal control of those bird species has to apply specifically for a licence for their particular issue and circumstances.

    In the big scheme of things, these are the most fundamental and far-reaching changes over the past decades, but Wild Justice believes that there is still some way to go to make the licensing of bird killing, through general licences, fit for purpose. We believe that the current DEFRA general licences are legally flawed but are awaiting full disclosure by DEFRA before we can consider whether or not to mount further challenges.

    We are hopeful, but not the least bit certain, that our legal challenge to the Welsh general licences will move things on further still. We should find out, probably, in the next 10 days or so.

    We have asked DEFRA for clarification on a number of issues since they published their new general licences in November, ahead of them going live on 1 January. We contacted DEFRA yesterday to say , very politely, ‘Oi! You promised us some answers to our questions’ and were told that answers to our questions and those of others would all be published within two weeks. Then we had a call from DEFRA a little later saying it might be longer than two weeks.

    Wild Justice is primarily concerned with the so-called conservation licence under which it is possible to kill a small, and reduced, number of corvid species (Carrion Crow, Magpie and Jay (and the non-native and rarely encountered Indian House Crow)) for the purposes of conserving threatened bird species (as listed on the Red and Amber lists of Birds of Conservation Concern). In England there is a further narrowing of scope introduced which is that Jays can only be killed to protect woodland species (which are listed).

    Wild Justice’s scientific position is that this is better but not good enough; Jays should be removed from this list completely (as arguably should Magpies) and the list of species actually affected by predation by corvids in numbers large enough to be a conservation issue is much, much smaller than the Red and Amber lists. These are matters of science, and cannot easily be addressed in the courts, but we believe that DEFRA has not taken much notice of the science in only moving as much as they have so far.

    Carrion Crows, Magpies and Jays are scavengers and predators. They will eat the eggs and chicks of many species, and have been doing so for thousands of years. That doesn’t make them a conservation problem any more than Blue Tits eating caterpillars are a conservation problem. Species eat each other – it’s ecology. The conservation general licence in Wales helpfully makes it clear that it is designed to protect the eggs and chicks of species of conservation concern, not adults. Presumably DEFRA thinks the same as ecology does not differ in that respect on either side of Offa’s Dyke.

    If predation on eggs and chicks is an issue (which we would contend for most circumstances) then this can only possibly occur in the avian breeding season. Although different species nest at slightly different times, being at this latitude in the northern hemisphere means that the breeding season for UK breeding birds is essentially March-July inclusive – those dates would capture over 95% of all nesting attempts each year in the UK.

    So our question to DEFRA (and to NRW by the way) is very simply ‘under the conservation licence, does DEFRA consider that its licences allow the killing of say, Carrion Crows, at any time of year or only in the breeding season when Carrion Crows take eggs and chicks?’. So would killing a Carrion Crow today, in England, where the person killing that Carrion Crow claimed it was for a conservation purpose under the general licences, be lawful or not?

    We’re interested in DEFRA’s answers to this and are surprised that in nearly two months they have not given us one – and we believe that these answers are relevant to others’ actions too. DEFRA must know their own intentions in writing their revamped general licences. Is a gamekeeper killing a Jay today in England, allegedly for conservation purposes, covered by the current general licences or not?

    DEFRA have had more than long enough to get their thoughts together on this issue but Wild Justice fears we are still confronted by casual licensing of casual killing of huge numbers of birds every year.

  33. Gamekeeping gets a change of job description

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    Following reforms introduced as a result of Wild Justice’s legal challenges, the job description for gamekeepers in England has changed dramatically. No longer is it legal to kill corvids to protect the adults, chicks or eggs of wild Pheasants and Red-legged Partridges under general licences issued by DEFRA. Under the terms of the conservation licence, General Licence 40, published on Friday for 2021, corvids can only be killed to conserve red-listed and amber-listed bird species of conservation concern and not the 60 million non-native Pheasants and Red-legged Partridges released into the UK countryside in a normal, non-COVID-affected year.  

    The Red and Amber lists of species of conservation concern include two main commonly-shot gamebirds; Grey Partridge (Red List because of large population decline) and Red Grouse (Amber List).   

    Captive gamebirds, such as in rearing facilities or release pens are classed as livestock and if serious damage occurs (which it hardly ever does) then corvids can be killed but only if non-lethal methods are impracticable (see General Licence 42).  However, after release in late summer those captive-bred birds are no longer classed as livestock and cannot be protected by killing of corvids (see British Game Alliance, William Powell Sporting, DEFRA .   For most circumstances, the ‘protection’ of the two gamebird species shot in highest numbers (Pheasant 15m/year, Red-legged Partridge, 4+m/year) no longer provides a lawful purpose for killing corvids under the general licences.  

    Wild Justice suggests that a number of websites describing the role of gamekeepers, particularly lowland gamekeepers, will need to be updated to catch up with this legal change.  Gamekeepers operating crow traps will have to learn a new vocabulary to explain to the public what they are doing and why.  

    The job of a gamekeeper in England, particularly a lowland gamekeeper, is different in 2021 from what it has been for decades before.

  34. General licences in general and our challenge to the NRW general licences in particular

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    This blog is about the licensing system for killing birds in Wales which is licensed by Natural Resources Wales. There are similar in essence, but different in detail, licensing systems in England and Scotland. Wild Justice has been active on challenging general licences throughout our short existence. On Friday our challenge of the legality of the Welsh general licences was heard and the judge indicated that he would hand down his judgment in the first weeks of January so we know how he will be spending some of his lockdown Christmas.

    This rather long blog sets out some of the background to general licences and how we ended up in court on Friday, what the judicial review process looks like, and what might come out of this challenge. We end with some relevant FAQs on this subject.

    The protection of Wild Birds by the law

    This is a good place to start because it is simple and everything else flows from it. All wild birds are protected by law – that’s the starting point (gamebirds are the main exception). Notice, the same is not true of mammals for example and Wild Justice will be doing some work on that. . Although all wild birds are protected by law the drafters of the laws recognised that there may be some good reasons why limited exceptions should be made to this general rule. They did not decide that all birds except corvids were protected by law but they decided that all birds were protected by law but exceptions can be made for particular purposes and under particular circumstances.

    The purposes for which you can kill otherwise protected birds seem to us to be quite sensible. They are for such purposes as preventing serious damage to livestock or crops, to protect public safety and to conserve birds. And those are the types of purposes under which you can kill a Robin, a Carrion Crow or a Bar-tailed Godwit. But you’ll need a licence to carry out that killing because all wild birds are protected by law.

    General licences and specific licences

    There are two types of licence under which you can legally kill wild birds and they are specific licences and general licences. They both have to identify the purposes for which the bird killing is legal and the circumstances under which it is legal. Let’s start with specific licences.

    If you believed that the Robins were causing serious damage to crops then you could apply for a specific licence to kill them. You’d contact your statutory nature conservation agency and probably have a phone chat with them first and then you’d have to fill in a form. And then you would either be issued with a licence or not. In the case of Robins purportedly causing damage to crops you would probably be asked things like: Are you sure they are Robins? What sort of damage are they doing? Is it serious damage? What non-lethal means have you tried before seeking a licence to kill? Are you really sure they are Robins? And then you might be issued with a licence that would specify how many Robins you could kill, in what period, in what geographical area, after carrying out what alternative methods. And you would have to send the licensing authority details of what you actually did after you’d done it. If you went ahead and killed Robins after being refused a licence you would clearly be committing an offence. If you broke the terms of the licence you would be committing an offence. The important thing though, is that if you had a good reason you would get a licence. But your case would have been scrutinised and the licensing authority would have decided that this particular, specific exception from ‘All wild birds are protected by law’ was justified. We know that such a system is not likely to be perfect, but that depends on the ability of the licensing authority to do its job properly. How about general licences?

    General licences to kill birds exist in all four UK nations. What is a general licence? It’s a means of setting out the purposes and circumstances under which killing otherwise protected birds is legal. Instead of arguing your specific case under purposes and circumstances in order to get a licence to kill, those things are set out in a general licence which these days is published on the internet (here are some examples; England, Wales, Scotland).

    We don’t have a pest list, but the general licences are as close to such a thing as we come in the UK. The species that have been killed under general licences over the past decades are generally corvids (such as Carrion Crow, Magpie, and Rook) alongside Wood Pigeon, some gulls and a range of non-native species.

    Why Wild Justice cares about general licences

    The fact that all wild birds are protected by law is important to us. It is a cornerstone of bird conservation in the UK. And yet millions of birds are estimated by shooting organisations to be killed under the terms of the general licences. These estimates come from asking people what they do and we aren’t confident that the right people are asked nor that they are all telling the truth. By their very nature general licences are difficult to monitor because there is no list of people who claim to be operating under their terms and no requirement to gather centralised information on the number of birds killed – so there is a lot of guesswork involved.

    Across the UK there are certainly millions of birds killed under general licences and this has been going on for decades.

    Species have come and gone from the lists over time. Getting the way these licences work fit for purpose is an important strategic goal. We wouldn’t want to see future general licences being flawed in detail and having more inappropriate species added to them.

    Wild Justice is primarily a conservation organisation and we have been primarily concerned with the general licences in all UK nations that purport to be for the purpose of nature conservation. Until recently it has been legal to kill Rooks, for example, under the conservation licence to protect wild birds. This is simply ridiculous and our actions have led to Rooks being removed from these licences across the UK.

    We believe that the conservation licences across the UK are badly flawed and are simply a cover for shooting interests, not conservation interests, to carry out casual killing of birds. The licences add up to casual licensing of casual killing of birds – and remember, all wild birds are protected by law.

    Let us illustrate the point with respect to the Jay – a beautiful woodland bird that feeds on a variety of things including, yes, some eggs and chicks of other woodland birds. Jay is currently listed on the conservation general licences in England, Wales and Scotland. Who kills Jays for conservation purposes under these general licences? We really don’t know! It isn’t the RSPB who kills no Jays, Magpies or Jackdaws for conservation purposes across its 200 nature reserves in the UK. And it isn’t statutory land-managing organisations in England, Scotland or Wales that have a conservation remit – across our public forests Jays are not killed in anything other than tiny numbers. Note that this includes by NRW itself – NRW is the licensing authority in Wales but is also a land manager and it does not kill Jays on the land it manages, nor does it allow others to do so, despite being the author of the very licence!

    Jays are only listed on general licences now for conservation purposes and yet conservation organisations do not kill Jays. So who does? We have no idea except gamekeepers seem very keen to kill Jays. GWCT tell us that 10,000+ Jays a year are killed for conservation purposes in the UK. By whom? Why? How many of these Jays would still be killed if their killers needed a specific licence before they could kill Jays?

    A short history of Wild Justice’s challenges of general licences

    Wild Justice’s first legal challenge was of Natural England’s general licences in spring 2019. Natural England agreed the licences were unlawful and clumsily withdrew them at a few days notice causing alarm and despondency amongst shooters and some farmers. Natural England then embarked on writing replacement general licences and these looked better to us, but not good enough, and so Wild Justice started a new legal challenge of aspects of those licences. DEFRA caved in, as they so often do, to ill-informed lobbying and took over the licensing job from Natural England. DEFRA held a very brief consultation and then issued new flawed licences but committed to carry out a further review and recently they have issued new licences, still flawed in our view, but better in some respects. We are still examing those licences since their final shape has only been made clear in the last few days.

    In Wales, NRW issued new improved licences for 2020 but those licences were still, in our view, unlawful because of lack of clarity over circumstances under which they could be used, and so we started a legal challenge of those licences in 2020 (see below) and that’s how we ended up in court on Friday.

    What Wild Justice has achieved so far

    Since we challenged the Natural England general licences in February 2019 there have been significant and welcome changes to the general licences in place across England, Scotland and Wales – although not enough! Our action has made a huge difference. Here are some changes:

    • the species that can be killed have been reduced in number
    • the species that can be killed for alleged conservation purposes have been reduced
    • the species for which conservation licences can be used for their conservation have been defined and listed for the first time – the lists are pretty bizarre but the task now is to make them better
    • in Wales (well done Wales) the circumstances under which the killing of some species to conserve certain other species can be lawful is only to protect eggs and chicks which suggests that it is only valid when those species have eggs/chicks which severly limits the time of year
    • the places the licences apply now exclude SSSIs etc where special permission is needed
    • the killing of species to protect gamebirds has been limited
    • the wording has improved (but not enough)

    We believe this is the start and not the end of progress on this important issue.

    What happens in a judicial review before you get to court?

    To get to court on Friday we had to go through a variety of stages, all time-limited. We sent a formal Pre-action Protocol letter to NRW on 3 February 2020. Here is the start of that 10-page letter (and note that correspondence had started months earlier);

    …some bits from the middle:

    …. and the end:

    NRW asked for more time and replied on 2 March (thus causing delay).

    Wild Justice took the next step by filing papers with the court on 17 March; these included a Witness Statement from Wild Justice, outline grounds for the case, a financial statement of means and a permission bundle!

    NRW then had to file similar papers with the court and on 3 August we heard that a judge had given us permission for judicial review – in front of a different judge, and that’s what happened on Friday. Ahead of Friday both sides (we are the Claimant, NRW the Defendant) have to provide more paperwork including the skeleton legal arguments on which they will rely.

    It’s a process with bouts of high activity and long periods of waiting to see what is going to happen. COVID-19 won’t have speeded things up, nor will BASC, DEFRA and the NFUW applying to be interested parties. BASC were originally turned down as interested parties but got through in the end – we feel their intervention was rather more helpful to our case than NRW’s case as it happened (although we expect BASC may disagree)..

    What happened in court on Friday

    The hearing took place online – so we all had the joy of logging in and then watching a screen for ages. Our barrister, David Wolfe QC opened proceedings at 10:30 by setting out the general legal framework and what our particular legal gripes were. This took around two hours. Then the Defendant’s barrister had a good chunk of time (interrupted by an hour off for lunch) and followed by shorter speeches by two of the three interested parties’ barristers, first the government’s top lawyer Sir James Eadie (which shows that DEFRA is paying close attention to the implications of this challenge for their own licences) and then the BASC barrister. And then our guy, David Wolfe, gets a slot to say why Defendants and interested parties have got it all wrong. The hearing ended on time just before 4:30.

    The judge, His Honour Judge Jarman, asked a few questions but basically listened and took notes. The questions he asked were potentially useful to our case but since we cannot read his mind we’d better not speculate.

    Basically what we asked for was that the judge declare the 2020 NRW general licences unlawful because they do not specify the circumstances under which their use would be lawful. You may notice that the 2020 licences have less than a fortnight to run but if they are called unlawful then that has implications for all future licences (and potentially knock-on implications for general licences across the UK, which is why, we imagine, Sir James Eadie was present throughout).

    What happens next?

    The judge considers the arguments, consults the legal tomes, decides what is right and writes his judgment. The judge said he would be able to do that in the first weeks of January which is very good of him.

    What might he decide? We have a strong case, so the judge might, in different words, decide that Wild Justice has NRW bang to rights. That would be great! We’re not banking on that but it is entirely possible.

    He might decide that Wild Justice has got it all wrong and NRW has got it all right. We’re hoping this doesn’t happen but most judicial reviews fail so it is a possibility. That would be a shame for us but at least we have tried, and we have shone a light on the whole murky process of general licences – particularly those allegedly for conservation purposes.

    Or it might be somewhere in between with each side gaining something, either ‘the licences are unlawful but they aren’t far off being lawful’ or ‘The licences are lawful but they aren’t far off being unlawful, and should be redrafted either now or next time around’.

    What happens next 2?

    When the judge delivers his judgment we and other parties will have to read it, discuss its implications and decide what to do next. There is the possibility of appealing the judgment if it goes against us. but let’s look at the rosier side of things; success, even limited success, in our challenge has implications for future general licences in Wales and England and Scotland. Wild Justice will be keen to make futher progress in making these licences fit for purpose. Remember, all wild birds are protected by law except under very limited circumstances.

    Sorry, that’s a long and somewhat technical blog but we hope it explains many of the issues and the work that goes into taking such a legal challenge. also, we are sometimes asked questions about the process and this blog sets out some answers to regular questions below.


    Q1: Why is Wild Justice trying to end the killing of pest species?

    A1: We’re not (although we don’t like the term pest species) we are trying to make the licensing system both lawful and reasonable. We accept that there are valid reasons for killing bird species but we believe that there is a lot, an awful lot, of casual killing of birds which goes on. And notice that the agencies have removed several species that should never have been on the general licences in the first place from the conservation licences so our action has made them think again.

    And, of course, we haven’t challenged the specific licensing system which is another means of licensing bird killing under the law.

    Q2: Why does Wild Justice want to see general licences scrapped.

    A2: We’ve never asked for them to be scrapped. It’s up to the agencies to come up with general licences that are fit for purpose and lawful. They seem to be struggling, we agree.

    Q3: Nobody is going to wipe out Carrion Crows by shooting and trapping them. This isn’t a conservation issue.

    A3: General licences allow unregulated unlimited killing so how do you know what could happen in future? Would you say the same about Herring Gulls and Lesser Black-backed Gulls which have been removed from the general licences after our challenge? In those cases there was good evidence that unlimited culling under the general licences did cause population declines. And in any case, the law doesn’t say anything about that – it says all wild birds are protected by law. You could kill Robins, Blackbirds and Avocets, up to a point, without reducing their populations but the law doesn’t allow that either.

    Q4: Why don’t you do anything in Scotland on this issue?

    A4: As you probably know, there is a separate legal system in Scotland although the laws are basically similar. We know that Nature Scotland and the Scottish government are watching events south of the border with interest and, we believe, with some trepidation. we are prepared to take legal action in Scotland too – but we’d have to find a new bunch of lawyers and barristers with whom to work whereas our legal team, who can operate in England and Wales, are now right up to speed with these issues. Watch this space.

    Q5: Everyone was perfectly happy with the general licences until you lot came along and stirred everything up. Everything was fine as it was.

    A5: Ha! Ha! We’re often told that everyone knew that the general licences weren’t fit for purpose but that the agencies and the major wildlife NGOs were to scared to change or challenge them. We prefer that version. The scale of change already brought in shows that you are wrong, and we believe there is more to come.

    Q6: You’re ripping off the public so that yourselves and a bunch of lawyers can get rich on the proceeds.

    A6: That’s very rude of you and completely untrue. Wild Justice is a not-for-profit company and none of its members, the three of us, are paid or get any benefit from the company. In fact, we get death threats and abuse from some quarters and we give freely thousands of hours of our time and experience in bringing these legal challenges to court to make a difference for wildlife.

    Our lawyers are brilliant and work long hours and offer us heavily discounted fees. You can see how much our legal challenges cost from our crowdfunders. We have access to the finest legal advice and some brilliant legal minds and pay moderate fees (Shhh! Don’t tell them!).

    We don’t have the resources ourselves as individuals to fund such challenges. Nor do lots of other people who support them, but by all chipping in to a crowdfunder together we can mount such challenges and make a difference. Arguably some of the larger wildlife NGOs could have been doing what we are doing, and arguably should have been, but they weren’t, so we stepped in and we have considerable public support for which we are very grateful.

    Q7: You’re just anti-shooting aren’t you?

    A7: Yawn! No! We are, remember, challenging the shooting of Badgers under Natural England licences – Badger shooting isn’t a fieldsport as far as we are aware. We’re still waiting for an appeal date on that. And if you subscribe to our newsletter – click here – you’ll know something of our plans for the future. Use of pesticides is not a shooting issue is it? The next issue of our newletter goes out tomorrow – you’ll learn more about what we do in that.

  35. Thank you!

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    Thank you for all your messages of support – these come in a wide variety of forms and we get a lot of really lovely cards – especially at Christmas.

    Here are a few of your recent messages:

    Eat scouse – not grouse!

    I’ve agreed with a friend to make donations instead of buying Christmas presents. So please find enclosed a cheque on behalf of my friend ***** ****

    Thanks for all your hard work this year and many congrats on your success.

    Thank you for what you are doing, you give us all some hope in a very bleak world.

    I thank you for your hard, effective work.

    Hope you can keep up the good work – thanks!

    Thank you for all the important work you do.

    Well done and thank you!

    There are lots and lots more along those lines – thank you very much.

    And thank you for your donations too – today three cheques, each for £50, arrived in the post and a very generous donor made a donation of £1000 through PayPal. It must be Christmas!

    Thank you all for the various forms of support you give us.

  36. Thank you for your suggestions and kind remarks

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    If you are signed up to our free, occasional, newsletter you will have noticed that we asked for suggestions of future areas that Wild Justice could explore. Newsletter: sign up here. Email us with your suggestions: with SUGGESTIONS as the email subject please.

    Already, ie since Wednesday, we have plenty of good suggestions and you’ve been very kind in sending us lots of uplifting messages too. Here are some of each:

    Your messages (just a small selection):

    • Firstly I’d like to say a massive thank you for what you are doing. It’s high time that our government were taken to task for its treatment of our wildlife, and you are doing just that. You’ve achieved so much in such a short period of time.
    • Hello, I have been following the progress of Wild Justice closely and I am encouraged by the positive change that has already been made.
    • Hello lovely people!
    • Thank you so much for what you are doing and all the best.
    • With heartfelt thanks for all you are doing and achieving,
    • Hello Brilliant inspiring Wild Justice

    Your suggestions (a selection):

    • trail hunting
    • lead ammunition
    • mowing of verges
    • felling of trees in bird breeding season
    • hedgerow destruction
    • raptor persecution
    • Beaver protection
    • planning regime
    • chemicals used on pets
    • low-flow rivers
    • funding for statutory agencies
    • pesticide use
    • wildfowling on SPAs
    • shooting of Snipe and Woodcock
    • grants to farmers
    • use of snares
    • glue traps
    • rewilding of unused green spaces
    • overgrazing in National Parks
    • urban trees
    • countryside rangers

    Thank you for these ideas, some of which are things we have been thinking about, and some of your emails had useful details, and some were new ideas for us to think about.

  37. Wildlife crime podcast

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    Wild Justice Director Ruth Tingay was interviewed on Planet Pod recently, discussing wildlife crime in the UK with podcast host Amanda Carpenter and Richard Benwell, CEO of Wildlife & Countryside Link.

    You can listen to this 40 minute chat here

  38. General licences in England – Wild Justice legal challenges bring about significant reform

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    Magpie. Photo: Tim Melling

    Today DEFRA released new general licences which will apply in England from 1 January 2021 for the calendar year. This is the most recent move in a sequence which started with Wild Justice’s successful first legal challenge to the legality of these licences’ predecessors back in spring 2019.   Things have certainly moved on thanks to the pebble we threw into this particular pool and the ripples have probably not stopped spreading yet.   All should now stop talking about ‘pest species’ – the licensing system has partly caught up with the science and with the law.  All wild birds are protected by law and can only be killed under specific circumstances when non-lethal measures are ineffective. No native species is listed on all three of these licences any more.   Since spring 2019, and our legal challenge, the following major changes have been made:

    1. The general licences do not automatically authorise killing of species on SSSIs
    2. Herring Gull and Lesser Black-backed Gull are removed from these general licences and treated differently under a better (though imperfect) licensing system which has more controls built into it
    3. Rook and Jackdaw are removed from the conservation licence – it will be illegal to kill these two species in future and claim that it is for conservation purposes
    4. The conservation licence is only valid (for killing Carrion Crow, Magpie and Jay) for the purpose of conserving a list of species of conservation priority (not necessarily exactly the right species but certainly a step forward)
    5. There are more details to come on animal welfare aspects of killing these species.

    Less than two years ago there were 156 species/purpose combinations under which you could possibly kill species but those combinations have now been reduced to 41. That represents a massive change brought about by our legal challenge.  

    We have yet to talk to our lawyers in any detail about these licences and suspect they may identify remaining problems with them, but our judicial review of the Welsh general licences in mid December will possibly elucidate those legal issues (and DEFRA will have to react to the results of that legal case, whatever they might be).  

    DEFRA carried out a consultation on these licences last year. We’d like to thank all of you who contributed to that consultation – your views made a difference, without a doubt.  

    In all modesty, Wild Justice’s legal challenge has prompted the biggest and most far-reaching reform of general licences ever.  

    The general licences for England from 1 January 2021 can be viewed here:

    Conservation licence – click here

    Serious damage to crops and livestock licence – click here

    Public safety – click here

  39. Wild Justice statement on gamebird licensing

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    Wild Justice secures an historic environmental legal victory

    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate

    Just days away from facing a barrage of legal arguments in court (on 3 and 4 November) DEFRA has agreed to license the release of Pheasants and Red-legged Partridges to control ecological damage to wildlife sites.  

    Wild Justice mounted a legal challenge to make DEFRA review harmful gamebird impacts and introduce proper protection for wildlife sites and we have got DEFRA to address both.  There is more to do to make sure this regulation is made to stick but we have reached the limit of what the legal system can do at this stage. 

    Wild Justice expects that a proper licensing system, compliant with the Habitats Directive, will require the following actions: 

    • Adding the Pheasant and Red-legged Partridge to Schedule 9 of the Wildlife and Countryside Act, which contains species which cause ecological, environmental or socio-economic harm (such as Signal Crayfish, Grey Squirrel, Ruddy Duck, Japanese Knotweed).  This means that those species can only be released under licence.  
    • Refusing to license gamebird releases on or within 1km of Natura 2000 sites unless stringent conditions on numbers of birds released are met.  
    • A ban on the use of lead ammunition on or within 1km of all Natura 2000 sites. 
    • Further research on impacts of predation by Pheasants on threatened reptiles such as Common Lizards and Adders. 
    • Further assessment of the influence of gamebird droppings on soil and water chemistry. 
    • Further monitoring of impacts of gamebird releases on densities of scavenging and predatory birds and mammals. 
    • Monitoring by Natural England of a large number of sites to ascertain the extent of damage caused by non-native gamebirds.  

    Wild Justice said: 

    We’re delighted! And we thank our brilliant lawyers at Leigh Day and Matrix Chambers and hundreds of people who contributed to our crowdfunder which allowed us to take this case.

    This is an historic environmental victory by the smallest wildlife NGO in the UK against the massed ranks of government lawyers, DEFRA, Natural England and the shooting industry.

    Thanks to our legal challenge, the shooting industry faces its largest dose of regulation since a ban on the use of lead ammunition in wildfowling in England in 1999.  Pheasants and Red-legged Partridges are now recognised by government as problem species where their numbers are too high and they cause damage to vegetation, soils, invertebrates, reptiles etc.

    This move forward was only possible because of the legal protection given to the environment by the EU Habitats Directive (incidentally, largely drafted by Stanley Johnson, father of the Prime Minister). On 1 January, at the end of the Transition Period, the Habitats Directive and other EU legislation will still be relevant to UK environmental protection but each government in the UK could, in theory and in practice, start amending those laws.  Society should be vigilant that environmental protection is not whittled away.

    There is more to do in making sure this regulation is made to stick but we have reached the limit of what the legal system can do at this stage. We called for review of gamebird impacts and proper protection of wildlife sites and we have got DEFRA to address both’.

    Leigh Day solicitor Carol Day said:

    The decision to establish a licensing regime for the introduction of some 60 million gamebirds a year is a major breakthrough in regulating the impacts of these non-native birds on our most valuable wildlife sites. Our clients will be examining the detail of the proposed scheme very carefully to ensure that it fulfils the Secretary of State’s obligations under the EU Habitats Directive‘.

    Media enquiries to


    1. Wild Justice is a not-for-profit company set up by Dr Mark Avery, Chris Packham CBE and Dr Ruth Tingay
    2. Pheasants and Red-legged Partridges are non-native species which are bred in captivity and released in vast numbers (around 60 million a year) for recreational shooting. These birds are omnivores and their huge numbers can damage vegetation, fragile invertebrate communities and soils. Their droppings can affect soil and water chemistry. They may spread diseases to native wildlife. They provide abundant food for some predator and scavengers whose elevated population levels may then affect other species.
    3. Natura 2000 sites are those designated under the Birds Directive and Habitats Directive, and form some of the most important sites for nature conservation in the UK. 
    4. BASC described the Wild Justice legal challenge as ‘an attack on shooting’, ‘vexatious’ and ‘deeply flawed’ back in January and pledged to fight the legal action.
  40. Raptor Forensics Fund opens with £10K

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    Earlier this year we proposed a new fund to help the police tackle wildlife crime. The idea was that this fund would help speed up the analysis and assessment of forensic evidence in wildlife crime investigations relating to the illegal killing of birds of prey, where police budgetary and resource constraints were impacting on the progression of potential criminal investigations (see here).

    This week we’re delighted to announce the launch of the new Raptor Forensics Fund, which has a very healthy initial budget of £10K. These funds have been donated by Wild Justice, Northern England Raptor Forum, Tayside & Fife Raptor Study Group and a number of individuals who wish to remain anonymous.

    The Raptor Forensics Fund will be administered solely by the PAW Forensic Working Group (a sub-group of the Partnership for Action Against Wildlife Crime) and is open to any regional or national statutory agency in the UK, specifically to support forensic testing in wild raptor crime investigations.

    The fund will support investigations in two ways:

    Support for early investigations

    We anticipate this fund will be most useful in circumstances where there is suspicion of a crime but insufficient evidence to meet the criteria required to submit a carcass for Government testing. To prevent any delay in progressing an incident, which could also involve a live injured bird of prey, immediate access to funds of up to £200 will be granted for x-rays and post mortems as long as the investigating officer submits case details to the PAW Forensics Working Group (FWG) within 24 hours.

    If initial forensic costs are estimated to exceed £200 (e.g. there are multiple birds), officers must first receive approval from the FWG before work begins.

    Support for criminal investigations

    Once it has been established that a crime has been committed, a criminal investigation can proceed. Additional evidence that may have been recovered with the dead birds or during follow-up enquiries may require forensic testing. Investigators are encouraged to discuss forensic options with the FWG and apply for subsequent funding which, if approved by FWG, will be 100% recoverable from the Raptor Forensics Fund.

    Detailed specifics about the availability of the new Raptor Forensics Fund are currently being prepared by the PAW Forensic Working Group and will be distributed to the Police Wildlife Crime Network imminently. The FWG website will also highlight the fund and provide information about how officers can apply for funding support.

    Thank you to those who have provided donations for this new fund and thank you to the PAW Forensics Working Group for its willingness to administer the funding applications. We look forward to seeing the money being put to good use to help bring the raptor-killing criminals to court.

  41. RSPB AGM and gamebirds

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    Tomorrow is the RSPB AGM and one of many interesting items will be the revelation of the RSPB’s new improved shiny policy on gamebird shooting. The RSPB announced at last year’s AGM that it was doing the review and the shooting organisation have been whipping themselves up into a frenzy over it ever since (as they do!).

    See here the Wild Justice response to the RSPB consultation .

    In a predictable attempt at a spoiler, shooting organisations are trumpeting a rather meaningless list of principles of game management (BASC, GWCT, Countryside Alliance, Moorland Association). Principles? The Countryside Alliance? Hmm!

    Let’s see what the RSPB comes up with tomorrow.

  42. Our Badger petition – end of Week 2.

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    Badger. Photo: Chris Packham

    We’ve just come to the end of Week 2 of our Badger petition – and we have over 55,000 signatures already!

    Thank you for your support for this wonderful mammal.

    We are angry at the scale and inhumanity of the NFU-driven, government-sanctioned, Natural England-licensed cull. And the amazing response to the petition is a sign that you are angry too.

    We’ll be asking for your help in various ways over the weeks ahead and we’re doing some thinking about that now. We’ll keep you informed of how you can help through our newsletter (sign up, free, here) but in the meantime please just spread the word of the petition to your friends, family and workmates.

    All UK residents and UK citizens living abroad can sign the petition – here is the link.

    And if you follow that link you can also see where the signatures come from:

  43. Gamebirds subtract adders

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    This story in the Guardian today backs up our worries about the impacts of massive, unregulated releases of gamebirds on wildlife in our countryside, included on designated sites.

    Nigel Hand, a reptile expert, describes the impacts of Pheasants in particular in gobbling up young snakes such as the declining Adder. We have made these points in our case for judicial review of gamebird releases. It’s very helpful to have this support.

    Teresa Dent of the Game and Wildlife Conservation Trust (more for the conservation of game shooting than wildlife we think) says that GWCT has carried out detailed research but fails to come clean on the fact that their research was not on Adders, so probably best to go with the Adder expert Nigel Hand who believes that, of all the factors affecting Adders, and causing their decline, the massive releases of gamebirds is the most important.

    Wild Justice’s case will be heard in court on 3 and 4 November, and it may force DEFRA to regulate gamebird releases in future.

  44. Our Badger petition – the first week

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    Badger. Photo: Chris Packham

    We’ve just had the first week of our Badger petition – and we have over 48,000 signatures already!

    Thank you for your support for this wonderful mammal.

    We are angry at the scale and inhumanity of the NFU-driven, government-sanctioned, Natural England-licensed cull. And the amazing response to the petition is a sign that you are angry too.

    We hope to get to the threshold of 100,000 signatures which almost certainly triggers a debate in parliament but we also hope to get further than 100,000. After all, we’re at the end of Week 1 and we have 25 more weeks to go!

    We’ll be asking for your help in various ways over the weeks ahead, but there is a very simple way that you can help and that is to spread the word of the petition to your friends, please.

    All UK residents and UK citizens living abroad can sign the petition – here is the link.

    And if you follow that link you can also see where the signatures come from:

    There’s great support from across the UK but particularly in rural areas, and particularly in South West England and Derbyshire.

  45. Our Badger petition

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    Badger. Photo: Chris Packham
    Tony Juniper, Chair of Natural England

    It’s Tony Juniper’s birthday today and the House of Commons Petitions Committee have inadvertently given him a present from Wild Justice – a petition against the free-shooting of Badgers which Natural England licenses. For his birthday present Tony, Chair of Natural England, is seeing that the licensing of Badger shooting is one of the most unpopular actions that Natural England has ever taken.

    Our petition – thanks to all of you out there – has just passed the 10,000 signatures mark which triggers a response from government. It’s taken just eight hours to reach this landmark total.

    There’s a long way to go to the next landmark, of 100,000 signatures, but let’s see whether we can get there with a little help from our friends. Click here to have a look at the petition please.

    We’ll keep you up to date with progress on this blog but also on our free newsletter which also provides a wider view of Wild Justice’s work – click here to subscribe.

  46. Natural England Annual Report and Accounts

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    And on page 5, in the Chief Exec’s statement, after ‘We’ve had cuts to our budgets’ comes this…

    Killing things is bound to be contentious, and rightly so, but that is not the only point to be made about Natural England’s approach to wildlife licensing. In 2019 Natural England were forced by Wild Justice to admit that their general licences were unlawful. That isn’t contentious, it’s simply not good enough.

    Wld Justice’s challenge, and the potent threat of further legal action, has prompted a long (will it have been thorough?) review of general licences in England whose results we should see in the next four weeks or so. We look forward to seeing what DEFRA has come up with.

    Meanwhile, Wild Justice has been given permission for judicial review of the Welsh general licences too – see here, here, here.

    It is horrifying that we have to fight our own government to save the environment.

    Ansel Adams, American photographer and environmental campaigner

  47. Our legal challenge on gamebird releases features in The Guardian

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    In a week where gamebird shooting has been in the media spotlight following its exemption from the so-called ‘rule of six’ measure to tackle the spread of Covid19, our legal challenge against the unregulated annual release of almost 60 million non-native gamebirds for shooting has featured in The Guardian.

    You can read the full article here

    In June this year we were given legal permission to take our case for judicial review and our court hearing is scheduled for early November.

  48. Fight back on Badgers

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    Last week we had a setback on our Badger case when we heard that the Hon Mr Justice Johnson had refused permission for judicial review of Natural England’s licensing of Badger shooting.

    This week, after consulting with our legal team, we’ve decided to appeal the judge’s order and today we lodged court papers to this effect.

    Our view remains unchanged that Badger shooting is inhumane and that Natural England is not taking full account of the animal welfare aspects of Badger culling.

    We now await the court’s decision.

  49. 123,678 e-actions!

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    An amazing total in just 24 days.

    If you’d like to continue to take action on this issue then sign up to our free newsletter for some tips over the coming weeks (and all Wild Justice’s news on other subjects).

  50. 100,000+ e-actions – thank you!

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    Chris Packham and Iolo Williams live on Twitter as the counter passed 100,000 e-actions a little while ago.

    Three weeks ago on Hen Harrier Day (online) we launched an e-action with Hen Harrier Action and the RSPB. Since then over 100,000 people have contacted MPs in England, members of the Senedd in Wales, MSPs in Scotland and Assembly Members in Northern Ireland to bring the plight of the Hen Harrier and the unsustainable management of grouse moors to the attention of elected politicians.

    The response from the public has been fantastic. And some politicians have responded well too. Here at Wild Justice we will be contacting those people who subscribe to our newsletter to help them carry on the advocacy with their elected politicians. The main targets to influence have to be the parties of government in the two UK nations where grouse shooting is a major land use – the SNP in Scotland and the Conservative Party in England.

  51. Setback on Badgers

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    Yesterday evening we heard that we have been refused permission for judicial review of Natural England’s licensing of Badger shooting. This is a grave disappointment.

    The Hon Mr Justice Johnson said:

    We will, of course, need to discuss this with our legal team and consider whether to appeal this judgment.

    This setback on legal grounds does not in any way affect our view that Badger shooting is inhumane and that Natural England is not taking full account of the animal welfare aspects of Badger culling. We submitted a petition in the Westminster government petition system calling for an end to shooting of Badgers almost four weeks ago and we are waiting for it to emerge…

  52. The DEFRA/NE/BASC/GWCT/Exeter University review of released gamebird impacts

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    This review forms a major part of DEFRA’s response to our legal challenge over the impacts on sites of high conservation importance of unregulated releases of tens of millions of non-native gamebirds. It was commissioned last autumn, appears to have been completed this spring but was only published last week, in late summer (over a year after our legal challenge started).

    Wild Justice’s position on the science is that because this review does not rule out ecological impacts then DEFRA should act as though such impacts exist until it has done the necessary work to investigate further. Lack of proof for an impact cannot be taken as proof for lack of an impact, particularly where there is evidence that such an impact is entirely feasible.

    And that, essentially, is where we think the science leaves DEFRA – not being able to discount impacts of exactly the sorts that the Wild Justice challenge identified. We’ll have to leave it to the lawyers to figure out where we go from here but if DEFRA had hoped to put a line through all of our concerns then this review doesn’t do that.

    Overall quality of, and findings of, the review

    We regard this as a sound piece of work. It comes to essentially the same conclusions that everyone else does, that there are some potentially harmful impacts of releasing very, very large numbers of non-native birds into the countryside, these are not foolish concerns but because they have not been studied in great detail their magnitude is unknown – unknown, not nonexistent. In other words they might be big impacts and that possibility has not been ruled out. Moreover, the more birds that are released the greater these impacts will be.

    We do not mean to disparage this review by saying this, but it hasn’t moved knowledge on very much. The view expressed in the paragraph above could probably have been agreed over a couple of pints in a pub by the authors of this review, Wild Justice, GWCT and a bunch of ecologists. DEFRA, NE and others have spent the last year confirming what we all knew a year ago.

    Limitations with this review

    This review is a sound piece of work but its value to DEFRA in addressing the science of the Wild Justice legal challenge is somewhat limited. This is partly because of the scope of the review (which was presumably decided by DEFRA and Natural England (and perhaps, bizzarely, BASC) rather than by the authors).

    To recap, Wild Justice says that millions of released gamebirds (Pheasants and Red-legged Partridges) are likely to have impacts on Natura 2000 sites (Special Protection Areas for Birds and Special Areas of Conservation) which need to be assessed. These impacts include physical impacts of trampling, grazing, eating of invertebrates, removal of seed resources otherwise available to wild native species, increases in predator and scavenger populations (eating live or dead gamebirds), increased fertiliser input of defecating gamebirds, increases in persecution of birds of prey and increased use of lead shot.

    Because gamebirds move around, and Wild Justice has already demonstrated that Pheasants and/or Red-legged Partridges are found on all Natura 2000 sites or in their very close neighbourhood, then all Natura 2000 sites are potentially affected by gamebird releases. We are not concerned with sites on which gamebirds are released, we are concerned with sites on which released gamebirds occur, and not just lowland sites but all sites as was eminently clear in our legal papers (which the authors of this review may well not have seen) which have been with DEFRA for months and months.

    So, some headline limitations with this review include:

    • very little attention has been paid to upland sites (this is a bit odd in that we know from BTO data that Pheasant numbers have increased more rapidly in upland areas)
    • there is very little attention given to Red-legged Partridges (presumably because more of the literature is on Pheasants)
    • there is no analysis of impacts specifically on SPAs and/or SACs (and yet that is the focus of our legal challenge)
    • the impacts of lead ammunition use on shoots is not covered (presumably because it is embarrassing to DEFRA that a very thorough review of ecological (and health) impacts of lead ammunition use was provided to DEFRA in 2015 which recommended phasing out of lead ammunition and this has never been implemented by DEFRA).
    • the authors say they can’t find any link between gamebird releases and raptor persecution incidents but, as they must know, there is no complete database of raptor persecution incidents for them to use in analysis. (The authors have ignored the fact that the great majority of convictions for crimes against birds of prey are by people whose jobs are associated with gamebird shooting).

    These are fairly significant limitations. However, we accept that the major limitation is not the fault of the authors nor solely the fault of the commissioners of this review, and that limitation is that the necessary studies have not been carried out.

    There are several studies which show that at high densities, often in or near release pens, gamebirds have detrimental impacts on vegetation or invertebrate biomass. These are important because if they had shown no impact at all then that would be strong evidence for no harmful impact. However, because at high densities there is a discernible impact then, biologically, we must assume that there is a more widespread but lower impact when all those gamebirds are released to roam around over a larger area. They do not stop eating invertebrates, pecking at vegetation or defecating for the months that they are outside of the release pens it is just that any impacts are spread over a much wider area and for a much longer period of time.

    So, Wild Justice’s concerns are confirmed and endorsed by this review. What will DEFRA do as a result?

    There are other quibbles we have with this review, which we may add in here as time goes on and on re-reading of the work.

  53. Generous donation from WILD Sounds

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    Huge thanks to Duncan from WILD Sounds for a very generous donation of £600, collected from sales of Dara McAnulty’s debut book, Diary of a Young Naturalist.

    Ironically, the cheque was written on the Inglorious 12th!

    Duncan is a long-time friend of Wild Justice and we are enormously grateful to him and to everyone else who continues to support our work. Without it, we couldn’t do anything!

  54. Wild Justice in conversation

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    A couple of weeks ago the three of us (Chris Packham, Mark Avery and Ruth Tingay) were interviewed by raptor ecologist Jimmi Hill from the charity Raptor Aid to find out what makes us tick and what drives us to make change.

    The interview is available to watch on our YouTube channel:

  55. Our e-action – an update on numbers

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    Exactly 10 days ago we launched a joint e-action with the RSPB and Hen Harrier Action on Hen Harrier Day. Your response has been incredible – over 55,000 e-action messages have been sent to elected politicians across the UK.

    This e-action will close at midnight on 31 August and we are wondering how high the numbers can reach. Please tell your friends about it and turn to the person closest to you right now and see whether they will sign up, please.

    All MPs in England have heard from their constituents with the sole possible exception of Julian Lewis in New Forest East who doesn’t have an email address!

    The leading England constituencies for this e-action look like a familiar list to those who have campaigned on environmental matters: Here are the top 20 constituencies colour-coded by the party (Conservative, Labour, LibDem or Green) of the sitting MP.

    Derbyshire Dales, 136 e-actions

    High Peak, 135 e-actions

    Coastal Suffolk, 131 e-actions

    Sheffield Hallam, 131 e-actions

    Central Devon, 125 e-actions

    Isle of Wight, 121 e-actions

    Somerton and Frome, 119 e-actions

    Wells, 119 e-actions

    Thirsk and Malton, 114 e-actions

    Bristol West, 114 e-actions

    Totnes, 114 e-actions

    Skipton and Ripon, 110 e-actions

    South Cambridgeshire, 109 e-actions

    Brighton Pavilion, 108 e-actions

    West Dorset, 108 e-actions

    Calder Valley, 106 e-actions

    Southeast Cambridgeshire, 106 e-actions

    Keighley, 105 e-actions

    Westmorland and Lonsdale, 103 e-actions

    South Norfolk, 99 e-actions

    A good mixture of constituencies with high support in some grouse shooting areas. Nice to see Therese Coffey MP being reminded by her constituents that she should have done more on this subject when she was a DEFRA minister. The number of Conservative seats in this list should bring home to individual MPs that this is an issue for them and their government is expected to take more action on raptor persecution and unsustainable grouse moor management.

    We will provide further updates here for other parts of the UK, on overall numbers and information on how you can make sure that your MP (or other elected politician) does take notice of your views on this subject.

    And please ask your friends to add their voices to this e-action – here is the link.

  56. Permission granted for judicial review of Welsh general licences – we’re going to court.

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    Jackdaw. Photo: Tim Melling

    Good news! This morning we heard from our legal team that the Hon Mr Justice Griffiths has granted us permission for judicial review of Natural Resources Wales’s (NRW’s) general licences – we are going to court!  

    Moreover, we have been granted an expedited hearing which is excellent.  

    This challenge is to the legality of NRW’s general licences authorising the killing of a variety of bird species as ‘pests’ or for nature conservation purposes.  See these posts on the Wild Justice blog for more details if you are interested in the technicalities – see here, here, here and here.  This challenge is, thanks to you, fully funded – see here.   

    We don’t know when this case will come to court but some time in the autumn looks likely.  

    Mr Justice Griffiths refused BASC’s (British Association for Shooting and Conservation’s) application to be added as an Interested Party ‘because the Defendant [NRW] and Secretary of State [DEFRA, as an Interested Party] sufficiently represent the interests engaged by the claim and can advance the evidence and arguments to oppose it. The addition of BASC as a further Interested Party is neither necessary nor desirable and would only serve to increase the costs and prolong the proceedings.‘.  We expect BASC, having blown one gasket (see here) to blow another one on this correct characterisation of their value to these proceedings; neither necessary nor desirable.  We wonder what the BASC membership will make of this as undoubtedly BASC will have incurred staff and legal costs already in getting nowhere…  

    Still, we mustn’t gloat…  

    These legal cases often seem quite long drawn out affairs. And then news, often good news (but it won’t always be good news) pops out all of a sudden.

    It’s a good way to start the week.

  57. Thank you for emailing Nicola Sturgeon (7)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the seventh tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Dear Ms Sturgeon and Cunningham,
    I am saddened to read of the poisoning of another white-tailed eagle, in the interests of grouse shooting.
    The poisoning of a sensate creature is an offence against empathy of course, but so is the whole leisure activity of shooting birds, as a pastime.  It’s time it was stopped.
    Yours sincerely,

    Dear First Minister and Cabinet Secretary,I am writing to you after seeing the photograph of this poor bird on the Wild Justice email that I subscribe to. It is yet another example of the flagrant breach of environmental law that is all too common on and near the grouse moors of Scotland and England. 
    I annually visit Scotland to enjoy its magnificent scenery, wildlife and hospitality after spending a year at Stirling University over 40 years ago. The persecution of wildlife to support a small minority interest is unacceptable and often illegal. Tourism is a much more important part of the Scotish economy and the publicity surrounding the continual persecution of wildlife to support driven grouse shooting will not help to boost tourist numbers. I am not advocating a ban on grouse shooting as such but driven grouse shooting and the damaging practices surrounding the activity must be much better controlled or banned. Some estates practice rough grouse shooting and do not kill raptors and mountain hares and do not practice widespread heather burning and bog drainage. This allows people who wish to pursue shooting to do so in a less cruel and environmentally damaging way. 
    I urge you to set an example to those estates that flout environmental laws that it is unacceptable and there will be real penalties for those that continue with these barbaric practices. This must include much more effective investigation of incidents and prosecution of offenders. I hope too that it will send a strong message to the UK Government that similar action needs to be taken to stop similar practices in Northern England.
    Yours sincerely,

    Dear First Minister,  I am sure that, like me, you were disappointed and saddened to see the recent pictures released by Police Scotland showing an example of poisoning of another animal in Scotland’s countryside. You cannot fail to be aware that this bird probably represents the tip of the iceberg and was only discovered thanks to the tracking device that was attached to the bird. Whilst not all grouse moors are as poorly managed as this one appears to be it cannot have escaped your notice that there is a serious problem in these areas with illegal persecution of wildlife of all kinds. I am sure I do not need to remind you of the obvious negative impacts of grouse moors in terms of wildlife but also in their amenity value in flood prevention, carbon storage as well as biodiversity which forms an important part in Scotland’s offering for tourists. The negative publicity this sort of story attracts is not good for Scotland and is likely to deter visitors.    Whilst I know that there are important issues of Public Health on your agenda at the present time please take a moment to remember that this will pass and human life will recover (we have the ability to shape our environment). But for our wildlife things are on a knife edge, and someone like yourself who clearly cares passionately about Scotland and its heritage have the chance to do something positive whether it be banning grouse shooting or just funding the police so they have the resources to investigate persistent offenders against inhabitants of Scotland who cannot speak for themselves.
    Whatever you choose to do, please just do something to help

    Dear First Minister and Cabinet Secretary, I have this evening been sent a photo (attached) of a beautiful white-tailed eagle that had been poisoned on a grouse moor in the Cairngorms National Park. I am so saddened by this I feel compelled to write to you to see if you can make a difference, for example by giving extra support to the police to pursue wildlife crimes, increasing surveillance in the area or banning grouse hunting, as the crime is almost certainly carried out by those with hunting interests. I’m sure none of us want to see these fabulous birds needlessly and painfully killed. Thanks in advance for any action you may take, best regards

    Dear First Minister,
    I hope this letter finds you safe and well in these troubling times. You seem to have done a great job with controlling the Covid virus outbreak in Scotland, well done indeed.
    I have to raise the issue of the poisoning by banned chemicals of the White-tailed eagle in Cairngorms National Park.
    These beautiful birds of prey have been re-introduced, not just in Scotland, due to having already been shot, trapped and poisoned to extinction. To see this happening all over again in your beautiful country beggars belief.
    The cause for this poor bird’s death and countless other raptors, are the driven grouse moors and their need to present as many grouse as possible for shooting. Why or how this still carries on in Scotland in 2020 is beyond most people’s comprehension. Traditions are one thing but grouse shooting is just outrageous in this day and age. And to kill everything else to maximise the event is barbaric. It needs to stop now.
    Kind regards,

    Dear First minister of Scotland, The recent poisoning of a young white-tailed eagle in the Cairngorms demonstrates how vulnerable birds of prey are to this form of attack, and how little protection current legislation offers. The crumpled image on the ground is in stark contrast to how they are in life – flying high and determined to survive.  This determination in adversity can be matched by you and your government to stop this practice of the deliberate killing of birds of prey in Scotland. Help to protect eagles and other birds of prey by increasing police surveillance of large birds of prey and harsher sanctions for when people are caught deliberately killing birds of prey. Show you care by investigating this practise. So that people understand that these casual killings which lead to such devastating effects will not be tolerated. So that eagles and other birds of prey can be helped to survive in Scotland in future.  Best regards,

  58. Thank you for emailing Nicola Sturgeon (6)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the sixth tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Dear Ms Sturgeon
    I am sure that you are aware of the recent tragic and illegal poisoning of a young White-tailed Eagle, found on the Strathdon Estate. My social media feeds are full of the story, and to make matters worse, it happened within the Cairngorms National Park, a short way up the road from where I am currently holidaying in Grantown on Spey.
    I am equally sure that you would like to avoid seeing such stories in the future, which are a slap in the face for Scottish conservationists and a stain on the reputation of the country. Please consider making driven grouse shooting illegal, or if that is a step too far, insist that shooting estates need to be licenced and those licences could be taken away for such happenings. Vicarious liability ought to stop the iniquitous situation where if a prosecution takes place, the land-owner is not held liable. Perhaps if raptor numbers are below those that ecologists think ought to be present, then licences would not be issued? 
    I know that there is money in shooting, but there is also money in wildlife tourism. A friend of mine runs a dedicated wildlife-watching hotel in Grantown and photographers pay good money to shoot birds as well. With a camera, after which they can fly away and carry on with their lives. There is another future for Scotland and its wildlife. 
    Thanks for taking the time to read this and I hope that wildlife protection will get the resources and enthusiasm it needs in what I expect will become a sovereign nation in the years ahead.
    Yours sincerely

    Dear Ms Cunningham,
    No doubt you will be aware of the incident detailed below:

    My constituency is Skye, Lochaber and Badenoch and I went to a surgery to talk to Kate Forbes about raptor persecution following the publication of the Werrity Report.
    At that meeting I highlighted the issues around intensive grouse shooting including raptor persecution and urged Ms Forbes to support the immediate introduction of licencing for grouse moors. Her response was that she favoured the consensus view that a review would be carried out after five years to see if self regulation of grouse shooting would work. Is this the SNP view? If so, how many raptors is the Scottish Government prepared to sacrifice before it takes action.
    This is happening in a National Park. A park which has intensive grouse shooting as a major land-use. A park that is devoid of raptors over these areas. A park where visitors struggle to see Golden Eagle. It need not be this way.
    Clearly this incident demonstrates that this is an “industry” incapable of self-regulation, out of control and dependent on criminality to continue its activities.
    I would urge to support the immediate introduction of licencing.

    Dear First Minister,
    I write this in sadness, but not shock. In despair, but not surprise. 
    Certain crimes, it appears, are permitted to happen in Scotland with impunity. If a criminal connected with a grouse moor wishes to commit a wildlife crime they can do so in Scotland, it seems, knowing there will be no legal consequences for them. If owners of grouse moors direct wildlife crimes to be committed on their property it seems they can do so knowing there will be no legal consequences for them. 
    The poisoning of a white-tailed eagle is only the latest known incidence of rampant wildlife crime on Scotland’s grouse moors. Of course the known cases are the tip of the iceberg of the horrific suffering of Scotland’s wildlife that must be going on unreported. And yet despite the mounting reputational damage to Scotland, just at a time when attracting tourists to Scotland is more important than ever to protect livelihoods and support the economy, despite the casual unlawful killing of some of Scotland’s most spectacular wildlife, it appears nothing is being done. 
    Your handling of the Covid-19 crisis has been brilliant. You have shown compassion for Scotland and its people. You have been able to take decisive measures and have explained to Scotland’s people why those measures were necessary and you have brought Scotland along with you. You are the envy of many other less able political leaders. Please First Minister, if you want, you can get this growing national scandal under control. Consulting with the grouse moor people won’t work. That’s been tried. 
    I don’t live in Scotland, but have holidayed many times over the years. The last time we came we avoided going to areas of recorded wildlife crime, besides, the land in those areas has been all but destroyed. Sadly, I can’t envisage another holiday in Scotland any time soon. It seems too much like a wildlife crime hotspot with weak law enforcement. I know this view may not be accepted but that’s how it appears. 
    Will you take a look at this issue and see what you can do? 
    Thank you for taking the time to read this note and I wish you well in your continued dealing with the pandemic.
    Yours sincerely,

    Dear Ministers
    This has to stop! Please bring these criminals to )serious) justice and protect what is far more important than the survival of reared game birds.
    We are coming on holiday to the highlands next week with the specific intent of seeing wildlife and sea eagles in particular 
    Please act – our world depends on your actions
    Respectfully yours

    Dear First Minister and Cabinet Secretary
    I have, this evening, been made aware of the appalling death – by poisoning – of the White-tailed Eagle, in the Cairngorms National Park.  I wanted to register my intense sadness at this – presumably deliberate – act against a beautiful and rare Scottish treasure of a bird.
    May I urge you to do what you think is morally right to ensure this does not happen again to other valuable and much-loved birds of prey?  Banning driven grouse shooting and licensing all wildlife shooting would seem to be a good place to start and should, apart from some administrative cost (which could be covered by license fees), be low effort measures.  Whilst there is clearly going to be a pressure on public services in the aftermath of Covid, increasing police resources to tackle wildlife crime, I’m sure, would engender support from the public – particularly the Scottish common man and woman.
    Thank you for considering my views.
    Yours sincerely

    I’ve just seen the photo provided by Scottish Police of the young white-tailed Eagle found poisoned on the grouse moors. Its a really tragic photo, one which I see on Twitter too many times of raptors killed over grouse moors. 
    I’m not a political person I just love to see raptors in their habitats. I love Scotland and driving up the A7 to my sisters in the Borders and seeing the countryside change, the mountains and the birds. 
    Can you do anything to tackle  this? The more you hear about the grouse moors the more it would seem that anything that isn’t a grouse that earns a few people money and status needs to be shot, poisoned , trapped,  you name it. Protecting the hares was wonderful, but how can we help these beautiful raptor from these painful terrible deaths at the hands of gamekeepers? Or how can you standback and not use your power to find out why and who? 
    You are doing great work, can you stop the people who are doing this? 
    Many thanks

  59. Chris Packham writes to Nicola Sturgeon and Roseanna Cunningham

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    Chris writes: Today I sent this letter to Nicola Sturgeon and Roseanna Cunningham. I’ve had enough of the criminal slaughter of our raptors on driven grouse moors . Please send polite emails yourself to

    Dear Nicola and Roseanna

    I hope you are both well in these strange and worrying times.

    I’m writing about the White-tailed Eagle which has recently been found poisoned in the Cairngorms National Park , which by now you will be familiar with . And I’ll speak candidly and frankly.

    We, that’s every decent , law abiding , well informed and committed conservationist in the UK, have had enough of this relentless criminal slaughter. We, and you, know precisely who the criminals are and we want you to put an end to it now. Not later, now. We are justifiably incensed by the ever growing pile of corpses which represents not only a considerably negative impact on the ecology of Scotland’s landscape, but also the vile destruction of our natural national heritage.

    This increasingly high profile vandalism is not compatible with the Climate and Environment Emergency which you have declared. It is not compatible with the need to protect biodiversity and it is not compatible with Scottish Tourism. People come from all over the world to visit the Highlands and . . . to see eagles.

    We cannot wait for the consultation following the Werrity Report, like so much else in life this is taking too long and will be corrupted by parties with a vested and nefarious interest in protecting their criminal element. Figures suggest that almost one fifth of Scotland is given over to driven grouse shooting and yet if Scotland’s economy were the size of Ben Nevis this industry’s contribution would be the size of a small banjo. Why are you hesitating to act against this environmentally destructive practice which is irrefutably underpinned by illegal activities?

    There is not a single case of a successful prosecution for the killing of an eagle in Scotland. Not one. And yet, as your own report into satellite tracked birds revealed, a disproportionate number of these magnificent creatures disappear under suspicious circumstances on driven grouse moors . And as you know, this is just the visible tip of an iceberg of death.

    You are in dereliction of your duty to protect Scotland’s wildlife. You are demonstrating a wilful blindness to a national disgrace which shames your government, people and country.

    Please act now to root out these criminals and stop this cruel destruction of our most treasured birds.


    Chris Packham

  60. Thank you for emailing Nicola Sturgeon (5)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the fifth tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Dear Roseanna Cunningham, I am writing to express my disgust at the poisoning, accidental or deliberate (though I believe the latter most likely) of a juvenile White Tailed Eagle in the Cairngorms National Park.
    I am horrified that killings of birds such as this rare and beautiful eagle are still prevalent in Scotland, particularly in a National Park.
    I am angry that the Scottish Government, like many others in the UK and elsewhere in the world (though that is no defence) is still not doing enough to protect all wildlife, not just rare birds such as the White Tailed Eagle.
    It is time the Scottish Government took this more seriously.
    Grouse shooting for sport should be banned. Indeed, shooting for sport should be banned.
    The police should be tasked and resourced sufficiently to take action against any and all illegal actions that deliberately harm our wildlife and environment. Laws should be enforced, and enacted where insufficient or non existent, to ensure that wildlife and the environment is fully protected.
    Scotland must show it is leading the world and take strong action to end killings such as this.
    I hope that you can take such action and demonstrate the Scottish Governments commitment to wildlife and the environment and its willingness to take action to protect and enhance it for future generations.
    Best wishes.

    Dear Ms Sturgeon, I have admiration for you and how you are coping with this pandemic and really feel that Scotland shows England how it should behave, but the wholesale killing of wild life on grouse moors really lets you and all your countrymen down – just to pander to rich guys who find it a sport to shoot birds. I imagine a lot of them are English too. I realise that jobs and money are involved but so is respect – what an example you could be to the rest of the world – well at least to those politicians in the UK. Please do what you can to make sure wild life, which is one of Scotland’s attractions, is protected better. Yours,

    This email is to plead with the First Minister for Scotland and Cabinet Secretary, people in power, to stop this outrageous illegal killing of wild animals.
    How, in 2020 do we still allow the illegal persecution of birds of prey. This fabulous protected bird died the most horrible death by poison AND in the Cairngorms National Park on grouse moors….well there is a surprise!!
    I thought the Cairngorms National Park was given National Park status for the protection it affords the animals and landscapes that all locals and visitors love, treasure and visit in their thousands, myself and my husband included!
    Something needs to be done to stop this heinous crime!!
    Why is driven grouse shooting still allowed?
    All wildlife shooting should require a license, why not take that step to protect?
    Why can’t money be made available to increase police resources? After all the tourist industry in Scotland is worth millions, so use a little of that to support what tourists come to see?
    Will we visit the Cairngorms National Park again if nothing is done ? The answer is…NO!
    Please, please do something to stop this sad and barbaric crime continuing, you have responsibility!
    Thank you from the bottom of my heart

    Dear Cabinet Secretary,
    I was horrified to hear today of the poisoning of a white-tailed eagle in Strathdon in the Cairngorms National Park, but, sadly, not surprised. I am a keen paraglider pilot and captain of the Southern team in the annual UK North-South Paragliding Cup. Four years ago we held the competition in the beautiful surroundings of the Cairngorms. We had some of the best flying I’ve ever had, taking us across stunning remote scenery, but I was most stunned by the complete absence of birds of prey. I have never experienced anything like it anywhere in the world and I have flown extensively in the Americas, Europe, Africa and Asia. I implore you to clamp down on this barbaric behaviour.
    Yours, with best wishes,

    Dear First Minister. 
    It was brought to my attention tonight the horrific death of a young endangered White-tailed Eagle.  It’s beautiful body was found in the Cairngorms National Park. An area we have previously holidayed to specifically try and view these amazing birds. They have to be a real asset to Scotlands tourist industry and should be protected at all costs. It is therefore such a tragedy that this young bird has died. The way it died is however abhorrent and a criminal act. It was found in grouse moors in Strathdon poisoned, I would imagine by gamekeepers managing this area for the shooting season. A cruel painful slow death. This surely now puts into question this whole industry. The vast majority of the UK public are without question against these so called “sports” which are lead by cruelty for the blood thirsty rich or landed gentry. This activity serves no place in a modern civilised society. It’s no longer 1880 when these pastimes were acceptable and they must now be banned. I look forward to your response to this incident and hope you stand for the rights of Scotlands unique, amazing wildlife and can be strong and protect and prevent this happening time and time again. 
    Yours sincerely 

    Dear First Minister and Cabinet Secretary Ref: crime, no. CF0160960720 In December, on one of my then frequent visits to the Cairngorms, I was lucky enough to have a long, silent, encounter with a majestic young white-tailed eagle. It was a magical seven minutes or so, as the two of us stared at each other, while the hares kept a low profile, the kestrel gave up and headed north and the eagle hung in the air above me. It wasn’t shy, this sea eagle. It was inquisitive, intelligent, curious. Anyone can enjoy an encounter like that, even the unfit and the unarmed – I wasn’t on a summit, just up the Geal Charn Mhor path in the Monadh Liath. There were small defunct mammal traps around – this is an old grouse moor – but right here, no one’s shooting grouse, so the eagle was safe, as were the ever-more-scarce hare thankfully, and indeed the grouse. In that same month, hundreds of people could, quietly, individually, have enjoyed breathtaking, inspriring, memorable encounters like mine that day. So when a landowner, businessman, gamekeeper or any other single individual takes it upon themselves to poison any of these creatures, they rob you and all the other people in your extraordinary beautiful country. I’ve not been to Scotland since February because of the pandemic. Partly I don’t want to add to the traffic your poor Highlands are being swamped by. Partly, the current crop of wild-crappers are ruining the hills, lochsides and peace for the usual bunch of us – walkers and climbers who respect Scotland, its people, land, water, history and wildlife. But even without the pandemic, the filth and the litter, as long as the country panders to people who know how to shoot with a gun, but apparently not with a camera, and their lackeys who poison and trap, I feel it’s not just the wild-crappers who are killing Scotland. It’s anyone in power who lets this keep going on without at least withdrawing these people’s shooting licences, and ideally encouraging a better use of the land. Yours sincerely

  61. Thank you for emailing Nicola Sturgeon (4)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the fourth tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Dear Madam, as the First Minister of a fine country, one of much outstanding beauty, I’m sure you will be as shocked as saddened by the poisoning of a White-tailed Eagle in your Cairngorms National Park.It is, of course, the tip of a wicked iceberg of illegal wildlife destruction, Grouse shooting being at the root of most of these acts.No doubt your police and environment officers will try to pursue the culprits, who are killing the jewels that grace the wild parts of your visitor-hungry country.

    Dear Ms Sturgeon and Ms Cunningham, I am sure you are both aware of the young White-tailed Eagle recently found dead, poisoned, in Strathdon, an area of grouse moors which, despite being in a part of the Cairngorms National Park, is unfortunately known as a wildlife crime hotspot. I have for some years been aware of the ongoing persecution of birds of prey in areas used for driven grouse shooting, both in England and Scotland. This latest incident, involving a young bird that will no doubt have died an agonising death, has both saddened and angered me. As a life long bird watcher and lover of all wildlife, I have visited Scotland, and specifically the Cairngorms, a number of times, but this relentless persecution of birds of prey has made me reluctant to visit again – if your government and the authorities are unable to prevent these blatant criminal acts, then I fear for the future of what is supposedly a national park – will it just be left, as seems increasingly likely, for the minority of people who revel in the killing of birds (and mammals) for supposed ‘sport’, but ultimately, in my view, just for their perverted pleasure.   I have supported a number campaigns over the years which call for the banning of driven grouse shooting – an activity which can only be sustained through the destruction of many other mammals and birds, some legally but many not, including Mountain Hares, and an activity which is also detrimental to the landscape and general biodiversity. Surely there is no place for such barbaric pastimes in today’s society. I urge you to consider the appalling effect this latest killing, in a string of similar incidents, will have on many people who might otherwise enjoy Scotland’s wonderful wildlife, much of which is unique to the United Kingdom, and to please consider banning this outmoded activity which continues to reflect badly on Scotland. Yours faithfully,

    I was shocked and saddened to learn from Wild Justice that a young White-tailed Eagle has apparently been poisoned in the Cairngorms National Park. Apart from the serious criminal aspect of this killing, how can the Scottish Government, knowing the practices of grouse moor landowners and keepers, allow a grouse moor within a National Park?

    Dear Roseanna Cunningham, I’m sure that by now you must have been made aware that a satellite-tagged White-tailed Eagle has been found dead in the Strathdon area of the Cairngorms National Park.  Apparently the bird was poisoned and must have died a horrible, painful death. If this was an isolated incident it would be shocking and shameful enough but the killing of birds of prey on the grouse moors of Scotland has become routine.  The area where this latest death occurred is known to be a wildlife crime hotspot but raptors aren’t safe anywhere that there is driven grouse shooting. So, my obvious question is: when is something going to be done to stop this national scandal?  We in the UK have been vocal in the past about the awful slaughter of song birds around the Mediterranean and countries like Malta and Cyprus have gained a terrible reputation not just for the killing but also for the lack of effective government action to put a stop to it.  There is clearly a danger that Scotland will soon have a similar reputation. Surely it is time now for action to be taken to end the illegal killing of birds of prey in Scotland.  Increased resources for police to investigate these crimes would be an obvious start but the reality, I suspect, is that only a complete ban on driven grouse shooting will stop these criminals. Kind regards

    Dear First Minister  The horrific saga of raptor killing in Scotland cannot have escaped your attention during your incumbency. The most recent poisoning of a White-tailed Eagle is heart-breakingly typical. Why is the Scottish Government allowing landowners to get away with breaking the law like this ? It does not redound to the good reputation of Scotland, its government, or your party.  On the contrary it makes Scotland look primitive, its government in the palm of the rich and the SNP as bad as any other political group in terms of looking after Scottish interests, especially with regard to the environment. This is one area where you could easily differentiate yourself from Westminster, who are similarly doing nothing to protect eg hen harriers from grouse farmer persecution south of the border. Sincerely

    Dear First Minister and Cabinet Secretary,
    You will no doubt have heard and seen todays report of a poisoned sea eagle found in a grouse shooting area of Strathdon in the Cairngorm National Park. We assume that you are both as shocked and horrified at the images as we were. Poisoning is particularly horrific as it is a horrible death and it is also indiscriminate, any animal could have become a victim, including someones pet.
    We strongly urge you to make this the final straw. The grouse shooting industry has had decades to put its house in order and has failed to do so. Wildlife crime is rife in Scotland and we are only seeing the tip of the iceberg as it is so hard to detect. The Werritty report has already recommended licensing of grouse moors, but 5 years is too long to wait. The industry has repeatedly demonstrated that it is incapable of respecting the law so the time to act is NOW. Enough is enough and we are sick and tired of reading report after report of wildlife crime on Scottish grouse moors.
    Please, please act NOW. Implement licensing of grouse moors, increase police resources to enable them to properly police the industry and make wildlife crime in Scotland a thing of the past.
    Thank you.

  62. Thank you for emailing Nicola Sturgeon (3)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the third tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Dear First Minister, I would like to register my huge sadness that the poisoning of birds of prey continues in Scotland without effective redress. Last year I visited the Isle of Mull with my family to see the white-tailed eagles nesting there, and it was truly thrilling. Such a huge amount of effort has gone into their care, monitoring and positive promotion, that it is shocking to me that the protection of these birds is not considered a top priority. As well as being the spectacular apex of the wild Scottish ecosystem, they are such a wonderful promotional opportunity for Scotland to attract visitors from all around the world. That opportunity is being wasted by letting an environmentally catastrophic industry (driven grouse shooting) get away with appalling wildlife crime. Please look very hard at the terrible cost to our wildlife of  the ‘Driven Grouse Shooting’ industry, which benefits so few individuals, and consider an outright ban of this outdated activity. Please also act immediately act on the legal protection given last month to Mountain Hares, which I understand could be killed in unprecedented numbers this year ahead of new laws coming into force to protect the species. The new Bill must be fast-tracked before the start of shooting season to prevent a “blood bath”. Scotland is loved for its unique wildlife. Please act to protect it as the priority it deserves to be. Yours sincerely,

    Dear First minister, It seems a regular occurrence these days to hear about yet another raptor going missing or being found dead on or near a grouse moor. Unfortunately the grouse shooting industry for reasons I do not understand seems unable to resolve the problem. They claim it is a few bad apples, which would be easily dealt with, the conclusion therefore is that it is rife in this community and self governance does not work. I therefore ask you to bring in laws that regulate the industry and halt this illegal slaughter. After all, tourism is an important part of the Scottish economy and Scottish wildlife is a major part of the attraction. Yours sincerely

    Dear Nicola and Roseanna, Although I am English, I studied at Glasgow University and holiday when I can in Scotland. I love Scotland and admire Scots’ forward thinking, their valuing of education, their radicalness.  However, when it comes to the tolerance of the corrupt industry of driven grouse shooting, it appears that the political establishment are as cowed by (or bought by?) the rich and powerful landowners as are the English. This puzzles and depresses me. Because yet again a fabulous bird of prey, this time the iconic white-tailed sea eagle, has been illegally poisoned on a grouse moor. With the introduction of vicarious liability I hoped that things would change, but nothing has. The obvious conclusion to reach is that these crimes will not stop until driven grouse shooting is banned. Please, please be as brave as you can be in other matters. Stand up to the landowners, please ban driven grouse shooting and re-wild the uplands for the benefit of all. Regards,

    Dear First Minister and Cabinet Secretary, I was distressed and dismayed to see the image of a magnificent white-tailed eagle illegally and cruelly slaughtered in Strathdon. I believe Scotland is shamed and diminished by the continual onslaught on such beautiful, majestic creatures – quite possibly just to misguidedly ‘protect’ game birds bred by the million for so-called sport. Whilst I realise it is difficult to point a finger in particular cases this is the latest in a long line of such killings, and I have followed the cases brought by RSPCA, RSPB and others and know the evidence is fairly conclusive. I was so delighted that Holyrood voted to protect the mountain hares, as were all my friends, but please can we see a genuine campaign to rid Scotland of the criminals who think it acceptable to put the profits of a few landowners, and their vested interests, above the richness and variety of our wonderful wildlife. Otherwise how can we hold our heads up on the international stage and ask other countries to protect the other many endangered species in the world? I live in Arbroath, and used to love going out into the highlands to enjoy the scenery and wildlife and have even thought of moving to those areas, but over recent years have found the takeover by driven grouse-shooting estates off-putting to say the least.  I know many others who feel this way and have even moved back to towns because of it.  How many more visitors, national and international, who truly care about and respect the countryside and our natural heritage, would Scotland be attracting if it only became known as a true haven for species as special as the white-tailed eagle? I know that it is argued that grouse shoots bring a lot of money into the country, but I really don’t think the income stays in Scotland; beaters are paid a pittance (and often endangered), and as the shoots are sold as all-inclusive experiences, participants don’t even leave the estates.  The real income goes to the investors in the industry, often not based in the UK. This can surely be compared to some of the few areas being managed for wildlife, where visitors are dispersed around different towns, hotels, b&bs, cafes and so on.
    Please can this be addressed with urgency, I believe Scotland will need every asset it has post-Brexit and post-Covid, in order to get back on its feet, Yours most faithfully,

    Dear First Minister, I am writing in relation to Schedule 1 raptor killings across Scotland, but firstly would like to thank you and your advisors for your efforts during the Covid-19 pandemic. The professionalism and humanity within your approach has been a steady for many people I know and most of us are glad that you all are genuinely acting for the benefit of us all throughout the emergence. In relation to the illegal killing of protected birds, I am heartily sickened by yet another poisoning of another white-tailed eagle within the Cairngorms National Park Authority boundary. I have had the pleasure of spending many hours over many years as a researcher and consultant surveying Schedule raptor species, and feel that we as a civilised country have a duty of care to these animals. Unfortunately, I have direct experience of poisoning incidences in the late 90’s, when working at RSPB Geltsdale. I found a poisoned hen harrier and raven (carbofuran), saw the keeper putting out the poisoned starlings, police raided his house: no prosecution. Carrying around a beautiful but dead hen harrier in a plastic shopping bag when I had spent tens of thousands of hours watching them skydancing, watching the chicks grow to fledging from a hide, watching them waft across the moor into a winter roost on a frosty winters day… sorry, don’t have the words. Wildlife brings more money to the economy, more employment and more enjoyment by many factors that driven grouse shooting. Driven grouse shooting has preserved some of our uplands in a seemingly more biodiversity favourable condition compared to sheep walk or commercial forestry, employing a few people in the hill who seem to pay little attention to UK or EU law, but that is not enough to allow this to continue. There is a saying, don’t blame the player-blame the game: this game is rotten, but most of the players are not. I would urge the Scottish Government to look at these birds as they are: our national and ancient heritage. They are as important, as historical, as beautiful and as important as any painting or building. They are also our future, driven shooting based on illegality is not. So I would urge you to work towards the licensing of driven grouse and all shooting activities, alter the law so that e.g. we don’t have nonsense relating to people escaping justice as they didn’t give prior permission to be filmed committing a crime, and make this industry mires in illegal activity shape up or be shipped out. Thank you for you time.

    Dear Excellency Sturgeon and Cabinet Secretary Cunningham, I am writing with great sadness at evidence of a beautiful young white eagle that was poisoned near grouse moors in the Cairngorms and recently found by conservationists who had been tracking it. I am a Scot in exile in Cambridge/Guernsey who yearns to come home. It is my dream to return to Scotland and support efforts to rewild the lowlands (I must just find my academic husband a job up north). My father was a timber merchant, based in Glasgow, who in the 1930s through to the 1950s began his business deforesting the highlands. On the other hand it was his passion for Nature and stories of escapades in Loch Lomond and sailing with basking sharks in the Scottish Isles which enthused me with an environmental consciousness that has driven my career to date. I am passionate about wildlife and conservation and have built a social venture which operates internationally to help the mining and minerals sector contribute to resilient futures for everyone. I have spent the past year on sabbatical in Guernsey building my understanding of climate action and (re)wilding and formulating a plan to be part of the movement that is gathering such pace around Europe, with Scotland in a leading position. I was due to spend a week with Trees for Life helping reforest Dundreggan in September, but due to COVID this has been cancelled. I have been so proud in recent years to be a Scot in exile. To witness your excellent handling of the COVID crisis and putting England to shame in this regard. To note the extent to which the SNP put climate change, Nature and social justice at the heart of its 2019 election manifesto. (And don’t get me started on Brexit). Thank you from the bottom of my heart for these values which you lead with, and lead the UK with. I only wish I could vote for you but being in Cambridge, I can’t. Grouse moors are a colonial excuse for elite entertainment, representing a myth of ‘scottishness’ that is outdated and destructive. In today’s world we must put biodiversity, climate action, sustainable food production, and local communities at the heart of our land management. Grouse moors contribute to climate change and low biodiversity. It is time to let Scotland live to its full potential to be a leader in nature based solutions to global challenges. This means doing grouse moors differently – or minimally. One dead eagle may seem a sorry starting point for my heady story-telling, but it ties in. if we can protect our iconic species, our predators, we can have our ecosystems thrive. Where they thrive they sequester carbon, offer ecosystem services, and generate new economic opportunities that can drive Scotland’s rural economies forward. If eagles do well, I believe we can do better too.

    My request is that a more enabling environment is created to enable Scottish biodiversity to flourish; that landowners curating grouse moors are incentivised to be climate smart and biodiversity smart; that all shooting of wildlife should be licensed; that more resources are put into preventing and prosecuting effectively wildlife crime.

    Thank you for your time.

    With sincere regards,

  63. Thank you for emailing Nicola Sturgeon (2)

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here. This is the second tranche of examples.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Ladies, I know your inboxes are full and getting fuller so I will be brief; Prompted by the recent poisoning of a white-tailed eagle in the Cairngorms National Park I note; 1) That none of the measures put in place to protect Scotland’s birds of prey seems to have any effect 2) No one has ever been convicted of killing an eagle in Scotland 3) Satellite-tagged eagles can be killed with impunity right up to the Edinburgh bypass 4) The Werritty Review’s outcome of a five year period of self-regulation is infuriating and futile 5) Your party appears not to have the stomach to take on serious, organised crime by landed interests in Scotland 6) Indeed your appointment of Richard Scott’s financial adviser Benny Higgins (a former colleague of mine) as an economic advisor suggests the opposite – that you regard these people as trustworthy or reputable in some way 7) Lots of people (including me) are extremely angry about your hand-wringing and inaction 8) I expect action from you. Driven grouse shooting is a moral disgrace, drives out productive land use, wrecks our uplands and depends on rampant criminality. It needs to be banned right now. 9) The Cairngorms National Park should either become an actual nation park with no sport shooting or it should come to an end. If it has no power to tackle this carnage there’s little point in it existing. Thanks for reading,

    Dear First Minister, I wanted to let you know how sickened and saddened I am to learn that yet another satellite-tagged bird of prey has been found dead in Scotland. I believe this bird was poisoned – a particularly horrible way to die, and one which puts other wildlife, dogs and even humans at risk. It would seem that Scotland has a problem with out of control game-keepers, who persecute and kill our precious and beleaguered wildlife to protect the interests of a few wealthy land owners who make their money through grouse shooting – itself a frankly disgusting waste of life for a few seconds ‘fun’. Although I live just over the border in Cumbria, and have family in Edinburgh, I am increasingly reluctant to spend any time in the Scottish countryside for fear of what I may witness in terms of wildlife persecution, be it dead and dying birds of prey, shot or beaten beavers, or the mass slaughter of mountain hares. At a time when the world is facing the very real threat of ecological collapse, and when it has never been clearer that we need to radically change our relationship with nature if we are to survive, I urge you, please, to address the wholesale persecution of wildlife in your country, and work towards making Scotland a land rich in wildlife and biodiversity. We owe it to ourselves and future generations to do no less. Kind regards,

    Dear – – – – – –  It is with a heavy heart and, indeed, tears in my eyes that I find myself appealing to you for action by the Scottish Government. Yet again, I am reading of another hideous wildlife crime perpetrated in a grouse-shooting area in Scotland. I am also conscious of the fact that the Government response to this particular incident seems to be platitudes that ‘the law will be upheld’ and ‘penalties have been increased’ – attitudes that seem meaningless when not a single wildlife crime has yet resulted in a conviction, other than for possession of illegal substances. My wife and  I have been visiting Scotland once or twice a year for the past ten years. We’ve mainly stayed in Grantown on Spey and, for the past four years, I have led groups and given talks there – sadly, not this year, due to Covid-19. I have often wondered why, when I am passing through the Strathdon area on my way to and from Grantown, I have not seen raptors, as it would appear to be ideal habitat – I now know why! This whole raptor persecution business has got out of hand and it seems to me that the perpetrators are ramping up their efforts in defiance of the authorities. Controls are not working and so I believe that it is time that the antiquated and barbaric pastime of shooting living things for pleasure should be stopped for all time. Much as we think that the Scottish Highlands is one of the finest places on earth for scenery and wildlife, We are increasingly finding that the depressing situation with wildlife crime, plus the slaughter of Mountain Hares and other abhorrent practices involving wildlife , is cancelling out the joy of being there. Until the situation improves, sadly, we have no intention to return to the Scottish Highlands. Please, please, please take action! 

    Dear First Minister, The dead White-tailed Eagle in the photograph below was discovered by scientists who had been tracking it via its satellite tag. It had been poisoned, and will have suffered horribly. The dead bird was discovered in an area of grouse moors in Strathdon, which is within the Cairngorms National Park. The White-tailed Eagle was, as you will know, almost rendered extinct in the 20th century because of illegal killings, which makes this poisoning even more appalling. I wonder whether the First Minister shares my disgust at this wildlife crime, likely to have been committed by someone working within the lucrative driven grouse shooting “sport”. I also wonder whether you agree that cruel and needless killings like these badly tarnish the image of Scotland. If so, I ask you to ban driven grouse shooting to remove the motivation to kill White-tailed Eagles and other birds of prey. If the First Minister feels unable to do that, I should be grateful to know why, and what steps would be taken instead to put an end to such wildlife crimes.

    Dear First Minister,Whilst I live in England, I have many friends and relatives in Scotland and have visited on many occasions, so I would, first of all like to thank you for the good work you have been doing to protect them during the covid-19 crisis. I am, of course, disappointed that I was unable to visit as planned earlier this summer, but fully understand why and hope to visit again now things are improving. A major attraction for me has been the wildlife and, in particular the magnificent Birds of Prey that make Scotland their home, if only for the breeding season. So, you can probably imagine my disappointed and anger at the continued persecution of these magnificent birds. This has been brought into focus in the last few days by the reported poisoning oa White-tailed Eagle within the Cairngorms National Park. You don’t need me to tell you the value of these birds to the Scottish economy since their re-introduction over the past 20 years or so. They have become an iconic symbol of Wildlife tourism. But, it is becoming increasingly evident that the perpetrators of this criminal activities, and their employers, are making no attempt to curtail their activities despite discussions on how to end the persecution have been ongoing for several years. They seem to be incapable or unwilling to ‘self-regulate’, so legislative action is now the only course of action. The Werritty review has made its recommendations, so I think it is time for action. I appreciate how busy you are with the aforementioned crisis, but wonder if you could find the time to instigate proceedings to regulate the Driven Grouse Shooting Industry, at least through licensing or better still banning. The latter would have the added benefit of providing an opportunity to restore the moors to a more environmentally friendly state. Such action I believe, would be of considerable benefit to the Scottish economy through increased.Eco-tourism. May I thank you in advance for your kind attention.
    PS. thank you for been such a good sport in relation to Janey Godley’s videos.

    Dear First Minister and Cabinet Secretary,
    I live in England but every year I spend my holidays (and money) in Scotland because I love the nature and wildlife of Scotland. It breaks my heart to see that one more beautiful and rare bird of prey you are so privileged to have in Scotland has been illegally killed. Do you understand how privileged you are to have such magnificent birds flying in your skies? And even if it wasn’t a beautiful bird, surely illegal practices of any sort should be stopped immediately? Why are they allowed to continue at the detriment of nature and all the people who love and enjoy it? For the economic gain of a small (already rich) minority who continuously burn and ruin the countryside killing anything that they don’t like (mountain hares, for example)? Why do you still allow this destruction of your beautiful country to continue?
    I hope you will answer my questions with honesty.

  64. Thank you for emailing Nicola Sturgeon

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    Yesterday evening we sent out a newsletter asking our supporters to email Nicola Sturgeon about the scale of wildlife crime in Scotland, exemplified by the poisoning of this young White-tailed Eagle that was found on a grouse moor inside the Cairngorms National Park.

    Poisoned White-tailed Eagle. Photo: Police Scotland

    The response has been amazing so we thought we’d post a few examples here.

    Have a look at the examples below and please add your own voice. Tell Ms Sturgeon how you felt when you saw the image above. Ask her to act now. You don’t have to send a long email, or a clever email, or a learned email – just speak from the heart. And you don’t have to be Scottish or to live in Scotland.

    If you are prepared to send a polite, but firm, email to Nicola Sturgeon, First Minister of Scotland, then this is her email address;

    Thank you!

    Here are half a dozen examples of emails sent already – six of the most recent so they are at the top of our inbox – we’ll post more examples later today:

    Dear First Minister,
    Whilst I appreciate that you and our government are working flat out to manage the current situation, I wanted to bring to your attention the fact that the killing of wild birds of prey is obviously still happening in Scotland.
    A young White Tailed Eagle which was satellite tagged for scientific research has been found poisoned in Strathdon, Cairngorms National Park.
    How much longer are we going to allow people to carry out this cruel practice for monetary gain?
    Under the Scottish Government we think of ourselves as a progressive, just society. Surely the killing of wild creatures anywhere let alone in our national parks flies in the face of this view. The fact the bird was found on a grouse shooting area lends suspicion to the idea it was poisoned on purpose to stop it predating creatures that some humans want to shoot for their own pleasure. When you break down the arguments surely the practice will be seen as unacceptable by the majority of decent folk and abhorrent by many.
    At this pivotal moment in the way we view our place in the world, I urge you to take another look at the issue of protection of these birds and whether the Parliament think it right that a few landowners or wealthy citizens can control our wild areas for their own gain rather than reinstating the natural world. This is indeed an opportunity to show the world we really are a progressive fair society which does the right thing.
    I appreciate your time considering this issue.
    Many thanks and best wishes,


    I don’t live in Scotland, but regularly visit and have friends who have moved there recently. Seeing this photo of a poisoned white tailed eagle found dead in the Cairngorms – it doesn’t matter where you live – this sight is deeply sad. You have an opportunity to lead the rest of the world in stamping out these horrible acts of cruelty driven perhaps by the barbaric so called sport of grouse hunting – that is where you can take a stance – breeding birds to kill is morally wrong surely? I want my legacy to be that I made a lasting positive difference to our animal kingdom – my feelings are so strong that I even believe that our planet would be so much better without us humans – that may sound extreme so instead can we live as nature intended in harmony and find the true reasons and stamp that out? If anyone can  – you can.

    I have just seen an image of a young dead, White-tailed Eagle. It was  found in the Cairngorms National Park, Scotland.  It had been poisoned.This is shocking and sickening.
    To think that this happened in an area where there is driven grouse shooting is a further indication that criminal activity goes hand in hand with the shooting fraternity.It should make Scotland feel ashamed and indeed many people will be turned against her. It is high time driven grouse shooting was banned. Those who engage in it believe themselves to be above the law and indeed, get away with these crimes time and time again because the shooting industry is governed by those who put wealth above all else and seem to walk arm in arm with politicians for protection.
    Please take action now and put an end to the persecution of wildlife by those in pursuit of profit out of those who enjoy killing. Supporting blood sports is not a good image for Scotland. She has beautiful scenery and wildlife to attract tourists. Allowing its wildlife to be persecuted will only drive them away.

    Dear First Minister and Cabinet Secretary We are writing to express our extreme disappointment at the news of yet another bird of prey dying in suspicious circumstances in the Cairngorms National Park. We wonder whether the Scottish government is taking seriously the message that this sends to all of those who enjoy wildlife in this country. We visit Scotland on holiday fairly regularly, specifically to enjoy it’s natural beauty and iconic wildlife. This sickening assault on an incredibly valuable attraction makes us question whether we wish to return. Unsurprisingly, a lot of this criminal activity appears to be focused around driven grouse moors. Is it time to consider banning these, or at the very least licensing/policing their activities? We feel the Police are under-resourced in this area, and when perpetrators are caught, the punishments do not fit the crime. There does not appear to be much deterrent. We would appreciate this being looked at again, with more action taken, as things cannot continue as they have been. Yours sincerely

    Dear Nicola Sturgeon,
    In almost every respect the Scottish government has shown itself, under your excellent leadership, to be humane, efficient and intelligent.  However, the grouse moors of Scotland have been the location of illegal and cruel practices, which have involved the mass shooting of mountain hares and now the poisoning of eagles and other precious wildlife in Strathdon, Cairngorms National Park.
    Police Scotland said: “As well as being illegal, poisoning is a cruel way to kill a bird. It also puts the lives of other creatures and plants at risk and impacts negatively on our environment.”
    My daughter lives in Scotland and although I am an Italian mother living in England and miss her badly, I am consoled by knowing that the quality of her life has greatly improved since her move to live and work in Scotland.  I understand people in Scotland love hill-walking and are rightly proud of the natural beauty of the breathtaking Scottish landscape.  But the balance of nature is precarious and the mass killing of wildlife, including the poisoning of eagles, by people involved in the highly profitable grouse-shooting industry is affecting the balance of Scottish nature.  The coronavirus pandemic has surely shown us that we must not exploit wildlife for cultural or monetary reasons because nature will strive to redress this imbalance in ways which may be dangerous to humans as well as animals.  How we treat our wildlife is a measure of our humanity and if the laws which are intended to protect wildlife are not effective, then please consider legislating to protect our precious and fragile wild animals.  Laws could be passed to ban driven grouse shooting or to licence all shooting of wildlife, the police could be given more resources and encouragement to pursue and prosecute illegal practices.  
    I appreciate that Scotland probably does not want to be lectured by a woman living in England, but the protection of wildlife is a global issue.  Wildlife has so little power to protect itself, people must watch over the welfare of animals with compassion, wisdom and imagination so that they can live the free, healthy lives they deserve and not experience unnecessary cruelty or suffering.  If this cruelty is led by a profitable industry founded on the mass killing of animals for sport, then laws need to be rigorously passed and implemented and police need to be given powers, resources and support.  Whatever we mean by ‘The Balance of Nature’ we know we human beings are not doing well on that front at the moment, so please use all of your intelligence, courage and thoughtfulness to protect our fragile wildlife – and particularly the eagles currently being poisoned on the grouse moors of Strathdon.
    Thank you,

    Today I learnt of yet another horrific poisoning of our precious and protected wildlife heritage, a rare juvenile White Tailed Eagle. It appears this bird was discovered dead because it was fitted with a satellite tracking device, a device fitted to allow a degree of security to be afforded to protect and study this rare animal. The eagle was found at Strathdon, an area of grouse moors, within the Cairngorms National Park, so it is more than certain that this bird was killed by someone involved in the shooting and game industry. I appeal to you to put a stop once and for all to the persecution of birds of prey as a result of a most questionable practise in this day and age, namely grouse shooting, which leads to gamekeepers poisoning eagles, harriers, falcons and hawks to preserve the grouse that will ironically be shot as sport by people who put their ‘sporting’ practise above the practise many tens of thousands people enjoy – simply enjoying the amazing spectacle of Scottish wild places and the incredible animals that live there. Please take notice of the outrage I and many many people feel at the seemingly never ending blind eye that is turned towards the shooting establishment. In other parts of the world, namely Africa, practises of shooting wildlife for sport has been driven out and replaced by people paying good revenues to governments to simply visit a national park to watch and photograph stunning wildlife. When is this government going to wake up and challenge the perverse and outdated practises of hunting and shooting and get on with promoting the idea to land owners to stop killing everything and promote their wildlife and wild places for tourism. Above all, bring these criminals – who poison our flagship wildlife heritage to death in the name of keeping their employers profits high – to justice so we may build a momentum to radically change and see the back of this outdated and barbaric so called sport. Yours sincerely,

  65. What others say (said) about us

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    There is a lot of comment about Wild Justice from others (we may even have been given a tangential mention from the Secretary of State for DEFRA, George Eustice, yesterday – see transcript about too many lawyers). A lot of the comment comes from the shooting community and most of it is incredibly ill-informed and way off the mark. It’s very funny to see how wrong they usually are (and we do mean usually, in the sense of almost always).

    Just as an example we came across this example from March last year only a few days ago and we, the three of us, have been exchanging jokey emails about it ever since.

    Here are some quotes from the article and comments from us:

    • Although ostensibly united by their common antipathy to fieldsports‘ – that’s not what we are about as our work on glyphosate and Badgers probably shows! It’s not all about you, shooters.
    • one suspects that required to work collaboratively under the auspices of a company structure, not for profit or otherwise, may prove very challenging‘ – there’s no ‘or otherwise’ about it, and we are having a blast thanks. We don’t agree about everything – that’s part of the strength of our collaboration – but we have never had a fist fight (go ask BASC about those).
    • Presumably they will be able to count on pro bono support from those in the legal profession who share their beliefs‘ – no, we pay our way, although we get very good rates we know.
    • the question is just how will they get the sort of funding which their ambitious manifesto demands?‘ – we ask people to donate and they do. Our recent crowdfunder for our current Badger challenge raised £48,500 in three days – sorry we were so slow.
    • The problem is that the three people who have taken it upon themselves to do so, are single issue fanatics each blessed with an abundant ego and obsessed with shooting. Chuck into the pot questionable people skills and it becomes a matter of if rather than when the bust-up happens.’ – you’re such sweeties, with such great people skills although you seem a little obsessed with shooting…

    A writer about shooting was sure that we established Wild Justice to take private prosecutions in Scotland – we didn’t and we haven’t but we might, thanks for the suggestion.

    Another bunch of shooters were sure that the generous donation of £10,000 to our crowdfunder was coming from Brian May, Mark Constantine or the League Against Cruel Sports – all wrong. And as far as we know (though we wouldn’t necessarily know if they contributed to crowdfunders) we have received no donations from any of those. We thank HSI-UK for their funding.

    If you are hearing about Wild Justice for the first time then sign up to our free occasional newsletter – click here. Then you’ll know what we are doing – shooters welcome!

    If you are minded to donate to our work then thank you! and have a look here for options.

  66. Thank you HSI-UK!!

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    This time last week we were approached by Humane Society International – UK offering us support for our challenge of the legality of licensing of free shooting of Badgers as part of the DEFRA Badger cull.

    We had a chat, filled in some forms and the money was on its way which meant that we could close our crowdfunder after just three days, and having raised £48,500.

    Wild Justice said ‘We are very grateful to everyone who has supported our crowdfunder to challenge the legality of the current licensing of free shooting of Badgers. HSI-UK came along at just the right moment last week to take the crowdfunder, already supported by over 1000 individuals, past its target of £48,500 in just three days. Wild Justice thanks HSI-UK for this generous grant of £10,000 and also for the confidence they have shown in us and our legal team.‘.

  67. Press release from Leigh Day

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    Wildlife campaigners launch legal case to challenge the humaneness of the badger cull

    Wildlife campaign group Wild Justice has launched a legal case challenging Natural England’s failure to ensure that badgers are being killed humanely as part of the annual cull to help prevent the spread of bovine TB.

    Natural England published 10 licences for supplementary badger control on 15 May 2020. Further licences are expected to follow in Autumn 2020. Condition 21 of the licences states that all reasonable steps must be taken to ensure that badgers shot under the licence are dispatched “swiftly and humanely”.

    Wild Justice, led by Chris Packham CBE, Dr Mark Avery and Dr Ruth Tingay, claims that in order to work out whether steps being taken are reasonable, Natural England must have some idea what is meant by “humanely” – but it would appear to have no basis for measuring what that means. 

    The group has applied for a Judicial Review of Natural England’s failure to clarify how it sets a benchmark for humaneness and argues that a lack of clarity means that an unacceptably high proportion of badgers could be left to an inhumane death. 

    Wild Justice is represented by Leigh Day, which sent Natural England a  Pre-Action Protocol letter calling on the Government’s advisers to explain what measure for humaneness it was using after it had chosen not to apply the approach to humaneness agreed in 2014 by an Independent Expert Panel (IEP) established by Defra to report on pilot culls in Somerset and Gloucestershire

    The Panel considered that for the controlled shooting of badgers in the field, the percentage of animals surviving for more than five minutes after being shot, and the percentage being wounded but not retrieved (the “non-retrieval rate”), should not together exceed five per cent. i.e. at least 95 per cent of badgers that are shot at should die within five minutes.

    The Government accepted that steps should be taken to improve shooting accuracy in its response to the IEP report but, despite efforts to improve the overall quality of marksmanship, Natural England’s annual reports demonstrate that the non-retrieval rate alone has consistently remained above 10 per cent since 2014, i.e. double the level recommended by the IEP.

    The Protection of Badgers Act 1992 requires that Natural England be satisfied that licence applicants “are able to deliver the cull as safely and humanely as possible” and only permits two culling methods: cage trapping followed by shooting and/or controlled shooting of free-ranging badgers.

    In the Judicial Review application Wild Justice argues that Natural England is acting unlawfully because it has imposed a condition which is entirely vague and unenforceable. It therefore provides none of the necessary certainties to ensure that reasonable steps are being taken to ensure the culling of badgers is humane.  Wild Justice will ask the court to quash the licences and declare them unlawful.

    In a statement, Mark Avery, Dr Ruth Tingay and Chris Packham said:

    We’re very grateful to over 1,100 individual donors who have funded our legal challenge. Badgers are wonderful creatures and they need all the friends they can get these days. We believe Gandhi was right to say that you can judge the greatness of a nation by the way it treats its animals, and by that measure this government, DEFRA and Natural England are doing a very poor job.”.

    Wild Justice is represented by Carol Day and Partner Tessa Gregory.

    Solicitor Carol Day said:

    The Government set up the Independent Expert Panel (IEP) to look at issues arising from the pilot badger culls, including humaneness. If Natural England has chosen not to use the IEP threshold, it must have some other basis for determining what constitutes “swiftly and humanely”. Since Natural England has not clarified what measure it is using to ensure that contractors are dispatching badgers swiftly and humanely, our client believes it has no alternative but to apply for Judicial Review to ensure the licence conditions are complied with.”.


  68. Companies House

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    Wild Justice has filed its first-year accounts with Companies House – click here. We also paid our Corporation Tax last week – a month ahead of the deadline.

  69. Extracts from our Pre Action Protocol letter to Natural England.

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    Wild Justice has been in fairly lengthy and detailed correspondence with Natural England and DEFRA on the matter of Badger culls.

    Here we post extracts from our last letter to Natural England, dated 22 May 2020.

    You can see that the beginning of the letter sets out what the letter is and names Natural England as the proposed defendant in any legal case.

    Then there is a lot of legal stuff but some of the most important aspects of the letter follow here:

    An independent expert panel recommended one thing but Natural England has continued to license Badger culling by free shooting which fails, always, to meet this criterion of humaneness, and Natural England have not specified any alternative criterion. What would a humane culling programme look like? Why is Natural England continuing to licence a programme which every year fails to meet some fairly basic standards of animal welfare?

    As far as para 29 is concerned we received a reply in June but then we would refer you to para 27.

    We’ll have more to say about the state’s inhumanity to Badgers over the coming days and weeks.

  70. High Court permission granted to Wild Justice for legal challenge on annual release of 50 million+ non-native gamebirds

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    We heard this morning that Wild Justice’s application for judicial review of the impacts of vast releases of non-native gamebirds on sites of high nature conservation importance has been granted.

    Thank you the Hon Mr Justice Kerr! 

    This means that after scrutiny by a Judge, it has been decided that there is a substantive case to answer, and that case should be made in court (by the end of October 2020).  We have, after quite a long wait, got everything we could ask for at this stage. 

    We may win in court, or we may not, but there is no doubt that there is a case to answer. If we were to be successful then this would have big impacts on Pheasant and Red-legged Partridge shooting in 2021. 

    We asked the court for a hearing this autumn so that any implications of the eventual judgment would be known long before gamebird shoots were making plans for ordering imports of birds for 2021. 

    Wild Justice is represented by Carol Day and Tessa Gregory, solicitors at LeighDay, in this legal case; Carol said “Defra was prompted to launch a review into the release of gamebirds on protected sites following the threat of legal action by Wild Justice in 2019 and on the issue of proceedings sought to argue the case is academic and premature. In granting permission for Judicial Review and ordering a hearing before the end of October, the Judge has clearly recognised the importance and urgency of this case, which will now be given a full and proper airing in Court.” 

    Thank you to all those who donated last summer when we started this challenge. We have the money in the bank to carry it through to the autumn. 

  71. Wild Justice response to RSPB consultation on gamebird shooting

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    The RSPB has asked for views on 7 draft principles around the issue of gamebird shooting. It is expected that the RSPB will adjust its position fairly substantially after taking such a long time to review its position and policies. Wild Justice was consulted by the RSPB and this is what we submitted.



    Draft Principle 1: Shooting must not adversely affect the population of any native species targeted for shooting

    Yes, Wild Justice agrees with Draft Principle 1. And we take ‘shooting’ to mean the actual deaths, the injuries and the impacts of all other management practices (positive and negative) on those species.

    And an unavoidable consequence of that is that there must be sufficient monitoring of quarry populations and of shooting pressure to make any necessary adjustments to current practice. In many countries this involves licensing of shooting and reporting of bags by recreational shooters. The UK does not have such a system in place. While such proper monitoring and regulation is absent the RSPB faces a choice over whether to support shooting because it could be done well or to oppose it because it is not done well. Which will it do?

    The term ‘adversely affect’ requires clear definition and an acknowledgement of scale, i.e. local, regional, national and international population status. In addition to the issue of a species’ distribution and abundance, it should also include aspects such as disease caused by intensive management techniques, e.g. cryptosporidiosis spread by use of medicated grit stations.

    Mandatory pre-shooting season population data should be collected at a local level and submitted to an overseeing statutory agency to compile and assess at scale. It should be the statutory agency’s duty to impose appropriate temporary and spatial restrictions if required.

    Mandatory bag size data to be collected and submitted for analysis/monitoring purposes as above.

    Disease/health monitoring to be undertaken on a suitable sample size (i.e. cf with current poor monitoring effort by Veterinary Medicines Directorate on approx. 10 Red Grouse samples per annum).

    Voluntary self-regulation by the shooting industry is unreliable and untrustworthy.

    Costs for independent monitoring and assessment to be covered by shoot licensing costs.

    The question asked refers to native quarry species. The elephant in this particular room is that most birds shot for recreation are not native to the UK. The numbers of Pheasants and Red-legged Partridges shot annually in the UK number in the low tens of millions of birds whereas the number of Grey Partridges, Snipe, Woodcock, Red Grouse and wildfowl shot annually number in the low millions. Shooting in the UK has moved considerably from a harvesting of native species to the shooting of captive-bred live targets. In addition, probably low hundreds of thousands of birds (and mammals) are killed each year by the shooting industry allegedly to protect gamebirds.

    Shooting of Snipe, Woodcock and Golden Plover might well be having an impact on the status of these species in the UK and wider (since many of the birds shot will be migrants visiting the UK in winter).

    Although native quarry species may be affected by overshooting they may also be expected to benefit from the fact that shooting interests will seek to protect their populations. There is little evidence in the UK for this being effective when one looks at the historical trends in population of Grey Partridge (the logo of a pro-shooting organisation), Black Grouse, Red Grouse, Capercaillie, Snipe, Woodcock.

    In the UK shooting interests have not been effective at protecting native resident species from wider land use changes and the shooting industry now depends for its existence mainly on winter visitors from abroad and non-native species captive bred for release just before the shooting season.

    For the avoidance of doubt, Wild Justice believes that driven grouse shooting should be banned.

    Draft Principle 2: Effective measures should be in place to ensure that shooting operates within the law and those not complying with the law must lose their permission to shoot.

    Yes, Wild Justice agrees with Draft Principle 2.

    Generally speaking the laws in the UK are not bad but their enforcement is hopelessly inadequate. The RSPB needs to consider whether its position should be ‘We’ll try to improve enforcement’ given decades of failure to make any noticeable difference, or whether it should adopt a position of ‘Since effective self regulation is absent, and so is effective enforcement, we cannot support the continued existence of shooting in its current form. Neither industry nor government is serious about the law being upheld’.  

    The well-known and persistent persecution of birds of prey on grouse moors is a classic example. What is the point of investigating crimes when everyone knows that they occur but government and the industry involved are both wilfully blind to the situation and sit on their hands doing nothing, only occasionally getting their hands out to wring them in false horror as another raptor goes missing or is found dead.

    There needs to be a substantial increase in penalties for wildlife crime associated with game shoots to ensure those penalties meet the criteria for a ‘serious’ offence that attracts a custodial sentence of five years. This would provide the police with the authority to apply for permission, under the Regulation of Investigatory Powers Act 2000 (RIPA and RIPSA in Scotland), to install covert cameras on private sporting estates for the purpose of detecting wildlife crime. This is currently being considered in Scotland as part of The Animals and Wildlife (Penalties, Protections & Powers) (Scotland) Bill.

    The UK authorities should use Spain as an example of deterrent policing and enforcement. E.g. routine and unannounced inspections including the use of specially-trained dogs to detect the use of banned substances, on conviction the suspension of shooting rights, substantial fines and custodial sentencing.

    Additional penalties for crimes with an impact on conservation and in a protected area (i.e. National Park, AONB, SPA, SAC etc).

    In addition to the suspension of an individual’s shooting rights, shooting should also be suspended on the landholding where the offence was commissioned.

    Remove all public subsidies for landholdings where there is evidence that employees/tenants have committed wildlife crimes, based on a civil burden of proof.

    Automatically remove firearms and shotgun certificates for 10 years following any individual’s conviction for any wildlife crime, regardless of the sentencing tariff.

    A new law for England and Wales to make it an offence to possess specified banned poisons commonly used for wildlife crime, as in Scotland.

    Introduce the offence of vicarious liability for all landowners in England and Wales, to make them responsible for wildlife crimes on their land as is the case in Scotland.

    Create a national, multi-agency response unit to investigate all offences that fall under the National Wildlife Crime Priorities. To be funded by shoot licensing costs.

    All wildlife crimes to be made recordable offences using official Home Office codes to enable effective monitoring.

    The English and Welsh governments to publish an annual wildlife crime report, as they do already in Scotland.

    Draft Principle 3: Management must not adversely affect the population of any native species in order to increase the shootable surplus of gamebirds and it should be underpinned by transparent reporting of the number of animals killed.

    Yes, Wild Justice agrees with Draft Principle 3 although the definition of ‘adversely affected’ requires clarity.

    And we know that management does adversely affect the populations of some native species, notably Hen Harrier, Golden Eagle, Peregrine and Red Kite – so what stance should the RSPB take?

    And in addition to the above named avian species, this draft principle should also apply to other bird species as well as Red Fox, Pine Marten, Hedgehog and a range of other mammals given the RSPB’s wider conservation remit.

    There is a serious ethical question to be addressed here – regardless of whether a population is adversely affected, should native wildlife be killed simply to increase the availability of another species to be killed by recreational shooters?

    Also, the killing of native species is primarily allegedly to protect non-native gamebirds i.e. Pheasant and Red-legged Partridges. Wildfowling and shooting of some waders requires no predator culls because the quarry populations breed outside the UK.

    Draft Principle 4: Species in favourable conservation status, killed for the purposes of maintaining or enhancing the activity of gamebird shooting, should be managed in accordance with best practice guidance.

    Yes Wild Justice agrees with Draft Principle 4, but that assumes that the best practice guidance is good enough and that compliance is good.

    There are questions around what is considered to be ‘best practice’, who defines it and most importantly, what happens when best practice isn’t reached? It doesn’t have statutory authority (e.g. see current Code of Good Shooting Practice’) so no enforcement options available if best practice isn’t met. It’s a waste of time in this particular context because the shooting industry has proven itself incapable of self-regulation.

    We take this to be a question about predator control which we know is a difficult issue for the RSPB because the RSPB carries out some limited, lethal predator control on its own nature reserves (and for which it is criticised by some (and always has been)).  However, the RSPB position on this subject, though not universally popular, is entirely consistent with the position that lethal predator control is a last resort, only to be taken when non-lethal means have failed, and only where there is good evidence for a conservation benefit and where welfare aspects are carefully considered.

    The RSPB position is one that is so much better than that adopted by the shooting industry as a whole where predator control is seen as a first resort and where standards of humaneness are low – and of course where the main aim is for protecting gamebirds that are to be killed by recreational shooters.

    The RSPB is not an animal welfare charity but then neither is it a social welfare charity (and yet it has expertise and sensitivity to issues such as social inclusion) and nor is it an economic charity (and yet it deals routinely these days with economic issues with considerable expertise). The RSPB needs to develop a much clearer public position on animal welfare issues rather than putting them in a box labelled ’Too hard, too contentious, not our job’. 

    The RSPB needs to seek guidance from those more expert in these matters but not to avoid them. The scale of killing native wildlife which underlies commercial shooting is far too high for a conservation organisation to ignore.

    Draft Principle 5: Land used for gamebird hunting should be managed in a manner that protects and enhances the natural habitats and ecosystem services it supports.

    Yes, Wild Justice agrees with Draft Principle 5 but not just the natural habitats, the man-made habitats too e.g. farmland.

    The RSPB does not have a clear position on rewilding. What is a natural habitat? 

    The RSPB has for too long sought to maintain the practice of driven grouse shooting on man-made unnatural habitats when the evidence has long been clear that this activity prevents a natural ecosystem establishing (in National Parks, AONBs, SPAs and SACs for heaven’s sake!). If the RSPB were signed up to this Principle itself then it would oppose the very existence of driven grouse shooting and not seek to introduce licensing as a means of better regulating an almost completely unsustainable activity. On this particular issue, based on this particular Principle, the RSPB does not have a principled policy. 

    Draft Principle 6: Some practices associated with shooting need to be assessed for their environmental impacts and, if necessary, to be better regulated or stopped.

    Yes, Wild Justice agrees with Draft Principle 6 but surely the word ‘some’ is unnecessarily restrictive.

    Luckily for the RSPB, Wild Justice is seeking a judicial review of the unregulated release of tens of millions of non-native gamebirds into the countryside as a first step towards fixing this issue.

    In the case of driven grouse shooting the need for assessment is long gone. The combination of impacts on natural habitats, ecosystem services, protected wildlife and welfare of native species adds up to a very strong case for opposing the current situation. Attempting to tinker with one or more aspects of a totally flawed land use is not what is expected of a leading wildlife conservation organisation.

    Draft Principle 7: Mechanisms should be developed and implemented to ensure that gamebird hunting, across all parts of the UK, is carried out in accordance with these principles. 

    Yes, Wild Justice agrees with Draft principle 7 and where mechanisms do not exist then the RSPB should oppose the status quo.

    This isn’t a debate that is starting with this RSPB consultation; there is a lot of background and history with which the RSPB has not adequately engaged.


  72. Wild Justice supports Beavers and Beaver Trust

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    Wild Justice is one of very many organisations and individuals asking DEFRA to facilitate Beaver reintroductions in England. Here is a joint lettter sent this week to DEFRA. When you look at the list of signatories it is pretty impressive.

    The Rt Hon George Eustice MP, Secretary of State

    The Rt Hon Victoria Prentis MP, Minister for Agriculture

    Tony Juniper, Chair, Natural England and Ex Officio Board Member

    Department for Environment, Food and Rural Affairs,

    2 Marsham Street,


    SW1P 4DF.

    8th May 2020


    Dear Minister Eustice, Minister Prentis and Mr Juniper,

    The Government has declared a climate and ecological emergency. Britain is one of the most nature depleted countries in the world, ranked 189th out of 218. Only 14% of our rivers are in good ecological condition. 

    The 6 goals of the Government’s commendable 25 Year Environment Plan commit to provide clean air, water, a thriving ecology, a reduced impact from natural events, to use resources from nature sustainably and to ensure ‘beauty, heritage and engagement’ with our natural environment. They are all in large part entirely satisfied by the ecosystem engineering activities of the Eurasian beaver (Castor fiber).

    Beavers are nature’s builders. Scientists stress that this single species is not a keystone element in nature but rather an entirely unique force on its own. Beavers create complex wetland mosaics along the length of water courses. These features slow the flow of water and purify it of toxins; store water during droughts and, when widely present in upper water-sheds of wooded catchments, reduce the impact of flooding events. And, they regenerate biodiversity in great abundance, providing food-rich habitats for wildlife.  

    Beavers are a native species. Our remaining, but diminished, kaleidoscope of wetland wildlife from fish to frogs, water voles to great white egrets, is entirely attuned to their activity. The only reason for their absence from our modern countryside is our past overhunting for their lustrous fur, meat and valuable scent glands. Their critical importance is evidenced by broad scientific research indicating we can only recover nature sustainably, and with its desirable socio-economic functions, if we restore the beaver. 

    A decade of learning from Scotland, combined with the 5-year project now concluded on the River Otter in Devon demonstrate unambiguously the benefits of beavers far outweigh the issues. With a wealth of experience from Europe, any undesirable beaver impacts can be mitigated swiftly by professional field staff. The species’ presence is entirely tolerable in many modern, cultural British landscapes.

    Public support for beavers from town and country is high and rising, with recent newspaper editorials backing their return. When indicating political support in the Telegraph for the engineering activities of the ‘humble, native beaver’, Minister Eustice encouraged innovative solutions to help prevent a repeat of the disastrous 2020 floods.  

    As a result, many owners of the great estates and prominent NGOs have, while a final decision on the Otter Report is awaited in August 2020, applied for licences to keep beavers in large, near-natural securely fenced enclosures. Community groups, including local government, are planning wild releases across catchments and regions too.

    The Eurasian beaver, but not the Canadian (Castor canadensis), is the only rodent species in the world (including the dangerous larger porcupines and the pony-sized Capybara) which requires an enclosure permit in England – but not in Wales or Scotland. The security and standards of these projects have been unprecedented. Since they began, not a single instance of escape has occurred. If new permits are terminated as an option, and in the absence of any ability to import beavers from Europe, the availability of British born beavers for any wider programme of release in the near future will be critically limited. Without demand from new English sites, translocation of further beavers in low numbers under licence from Scottish Natural Heritage from intensively farmed, arable landscapes will cease and result in them being shot.

    We believe this is inappropriate and missing an opportunity. It is now time to focus our collective efforts on a swift and active process of beaver restoration. We will produce a position paper regarding details of this shortly.

    This letter is to state our whole-hearted support for beavers and the tenets of the Governments’ 25 Year Environment Plan which their restoration will greatly assist. We would like to ask you 2 questions:

    1. Will you commit to making policy decisions this year on producing a pragmatic and ambitious strategy for beaver reintroduction in England?
    2. Will you ensure there is no moratorium on the current, effective system of beaver licensing and to expedite applications if they are reasonable and competent?

    We invite you to meet with Beaver Trust and relevant signatories to discuss these questions. Together we can reconnect people with nature, incentivise them to relearn how to live with beavers and build climate resilience.

    Thank you for the energy and resources you are committing to secure a brighter future for us all.

    Yours sincerely,

    James Wallace, for Beaver Trust, and the signatories below.

    Environmental NGOs  
    Beccy SpeightChief ExecutiveRSPB
    Craig BennettChief ExecutiveThe Wildlife Trusts
    Darren MoorcroftChief ExecutiveWoodland Trust
    Dominic JermeyChief ExecutiveZoological Society of London
    Hilary McGradyDirector-GeneralNational Trust
    James RobinsonDirector of ConservationWildfowl and Wetlands Trust
    Jamie PetersDirector of CampaignsFriends of the Earth
    John SauvenExecutive DirectorGreenpeace UK
    Mark RoseChief ExecutiveFlora and Fauna International
    Mike BarrettExecutive Director of Science & ConservationWWF-UK
    Environmental Organisations  
    Alasdair HarrisExecutive DirectorBlue Ventures
    Andrew KerrChairmanSustainable Eel Group
    Andrew SimmsCo-FounderNew Weather Institute
    Chris PriceChief ExecutiveRare Breeds Survival Trust
    David Gasca-TuckerPrincipal HydrologistAtkins Global
    Dean GodsonDirectorPolicy Exchange
    Derek GowDirectorDerek Gow Consultancy
    Fiona MathewsChief ExecutiveThe Mammal Society
    Frans SchepersChief ExecutiveRewilding Europe
    Gary RumboldDirectorNational FWAG Association
    James ThorntonChief ExecutiveClientEarth
    James WallaceCo-DirectorBeaver Trust
    Jan StannardChief ExecutiveHeal Rewilding
    Jeremy BiggsDirectorFreshwater Habitats Trust
    Jill NelsonChief ExecutivePeople’s Trust for Endangered Species
    Julie WilliamsChief ExecutiveButterfly Conservation Trust
    Lesley DickieChief ExecutiveDurrell Wildlife Conservation Trust
    Liz HoskenDirectorGaia Foundation
    Louise RamsayChairScottish Wild Beaver Group
    Martin LinesChairNature Friendly Farming Network
    Nick FoxFounderBevis Trust
    Paul ListerChief ExecutiveThe European Nature Trust
    Peter CairnsDirectorScotland the Big Picture
    Philp LymberyChief ExecutiveCompassion in World Farming
    Rebecca Wrigley, Alastair DriverChief Executive, DirectorRewilding Britain
    Roy DennisDirectorRoy Dennis Wildlife Foundation
    Ruth TingayPartnerWild Justice
    Sara LomChief ExecutiveThe Tree Council
    Shaun SpiersDirectorGreen Alliance
    Toby AykroydCoordinatorWild Europe Initiative
    Tony GentChief ExecutiveAmphibian and Reptile Conservation
    Archie Ruggles-BrisePartnerSpains Hall Estate
    Charlie Burrell and Isabella TreeOwnersKnepp Estate
    John Mildmay-WhiteOwnerFlete Estate
    Lady Elizabeth AshcombeOwnerSudeley Castle Estate
    Merlin Hanbury-TennisonOwnerCabilla Farm
    Mish KennawayOwnerEscot Estate
    Sam GalsworthyOwnerTrewin Estate
    The Duchess of RichmondOwnerGoodwood House
    The Duchess of RutlandOwnerBelvoir Castle
    The Duke of SomersetOwnerMaiden Bradley Estate
    The Marquess of CholmondeleyOwnerCholmondeley Estate
    Thomas MacDonellDirector of ConservationWildland
    Axel MoehrenschlagerChair IUCN SSC Conservation Translocation Specialist GroupIUCN Conservation Translocation Group
    Charles CloverExecutive DirectorBlue Marine Foundation
    Craig ShuttleworthResearch FellowBangor University
    Deborah MeadenEnvironmentalist, entrepreneurDeborah Meaden
    George MonbiotGuardian columnist, author, environmental activistIndependent
    Hugh Fearnley-WhittingstallEnvironmentalist, TV presenterIndependent
    Iolo WilliamsNaturalist, TV presenter, conservationistIndependent
    Jonathon PorrittEnvironmentalist, writerIndependent
    Sacha DenchUN Ambassador for Migratory SpeciesUnited Nations
  73. Tayside & Fife Raptor Study Group contributes to our new Raptor Forensics Fund

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    In April we announced a new fund to help the police tackle wildlife crime. This Raptor Forensics Fund will help speed up the analysis and assessment of forensic evidence in wildlife crime investigations relating to the illegal killing of birds of prey.

    This week the Tayside & Fife Raptor Study Group has stepped up and made a £750 contribution to the fund. Kelvin Thomson, Chair of the Tayside & Fife branch of the Scottish Raptor Study Group said:

    We are delighted to help fund the fight against the illegal persecution of birds of prey no matter where it occurs.  Over many years, we have ourselves experienced several incidents of persecution involving birds of prey across the Tayside & Fife area. It’s a great frustration to us all that this insidious crime still persists across the UK and in making this donation we are helping law enforcement agencies to more swiftly collect and forensically analyse evidence to help bring those responsible to account”.

    This generous donation brings the fund total to just under £7K following additional contributions from Wild Justice, the Northern England Raptor Forum and a private individual.

    We anticipate that guidelines for police officers on how to apply for funding support from the Raptor Forensics Fund will be published shortly.

    If anyone else would like to contribute to this new fund, please get in touch: and enter ‘Raptor Forensic Fund’ as the subject header.

    Thank you

  74. Thank you, thank you, thank you!

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    Thank you so very much. Our third major crowdfunder has been fully funded by over 900 generous donors.

    The English general licences are being reviewed – there have already been minor changes and we are sure more change is on the way. Anyway, we haven’t given up.

    The release of gamebirds is being reviewed – we are keen to see what if any changes come about – but we are also ready to take further legal action whenever necessary.

    And now we have a fully-funded legal challenge of the Welsh general licences too – we believe they are unlawful, unscientific and unjustified. Thank you for your support.

  75. Applications for gull cull licences fall short of required standards.

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    Natural England is waking up to the shambolic state of knowledge amongst those seeking licences for lethal killing of birds under new licensing regimes.

    In a recent update, Dave Slater, the Natural England director for licensing makes it clear that many applications to kill large gulls in rural settings (now removed from general licences following Wild Justice’s legal challenge last year) have been received after the deadline and lacking the necessary information to justify a licence being issued.

    Rather extraordinarily, Natural England’s response to this is to allocate more staff to the issue rather than simply sending out letters rejecting the licence applications. Wild Justice has several times suggested to Natural England that if workloads are high on processing licences then charging for licence applications is a completely reasonable response. Where licence applications are late or inadequate it is difficult to see why public money should be spend on hand-holding applicants.

    If large shooting states, owned by some of the wealthiest in the country, charging massive fees for shooting days, and employing land agents, shooting agents and teams of so-called professional gamekeepers cannot fill in some forms and submit them on time then it is unclear why the taxpayer is picking up the bill.

    But more broadly, and more importantly, this is an insight into the reality of the casual killing of wild birds under the discredited former and current general licences. Mr Slater had to remind the world that:

    Natural England will issue licences where there is enough evidence and information in applications for us to conclude that:

    – there is a genuine problem to resolve or need to satisfy for which a statutory licensing purpose applies;

    – there are no satisfactory alternatives, including that non-lethal solutions have been tried and/or shown to be ineffective;

    – the licensed action will contribute to resolving the problem or meeting the need; and,

    – the action to be licensed is proportionate to the problem or need.

    This is what the law has always required except that in their former and current general licences, DEFRA, Natural England (and Natural Resources Wales) left it to the licence user to go through those steps on their own rather than, as Wild Justice believes is required, making sure that these conditions are met. Here we see that those requesting (often demanding) licences to kill protected birds (all birds are protected by law) fail to meet the simple requirement of filling in a form properly.

    As an insight into the shambolic and unjustified casual killing of birds, and the urgent need for reform of the licensing system for bird killing across the UK, we couldn’t have come up with a much better example.

    Wild Justice is challenging the current general licences in Wales – our crowdfunder is almost at its target.

    Wild Justice is waiting eagerly for the results of the long drawn out DEFRA review of general licences.

    To keep up to date with Wild Justice’s news, sign up to our newsletter – click here.

  76. Northern England Raptor Forum (NERF) contributes to new Raptor Forensics Fund

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    Following our launch last week of a new fund to help support police investigations in to the illegal persecution of birds of prey, we’re delighted to see that the Northern England Raptor Forum (NERF) has stepped forward and made a contribution.

    NERF is a collaborative, self-funded organisation representing voluntary raptor field workers whose expert monitoring provides the statutory agencies with vital data on species’ distribution, abundance and conservation status. NERF understands the need for this fund only too well.

    A quote from NERF’s press release:

    Unfortunately every one of our member groups has experience of raptor persecution within their own study areas. Many of us have also been involved in cases where the search for forensic evidence, vital to support the case, was not pursued because of lack of funding thereby resulting in the investigation being abandoned prior to trial. We believe that this initiative will make a very significant impact on the investigation of raptor related criminal cases‘.

    Steve Downing, NERF’s Chair said:

    As a former Wildlife Crime Officer I fully appreciate the complex decision making process that is used to assess competing applications for funding the forensic analysis of potential exhibits. Every application for forensic funding is justifiable, however it is understandable why some crimes take precedence over cases of raptor persecution. This raptor related forensic analysis fund is a very valuable tool that will make a tremendous difference in the battle to detect wildlife crime and Wild Justice is to be commended for introducing the scheme“.

    To read NERF’s press statement in full, please visit here

    If anyone else would like to contribute to this new fund, please get in touch: and enter ‘Raptor Forensic Fund’ as the subject header.

    Thank you

  77. Getting close

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    Our crowdfunder is approaching its target – thank you to everyone who has contributed at this very difficult time.

    We were able to transfer £15,000 of funds originally raised for our similar, and successful, case on Natural England general licences, to this challenge. Those funds have been sitting in the Crowdjustice system until now. It has taken Crowdjustice longer than we expected to carry out this transfer but now it’s done.

    Also, many people have donated direct to Wild Justice and we have recently transferred those cleared cheques to this crowdfunder. Everything, understandably, has taken longer than expected with the current situation affecting the speed of the post, banking transactions etc.

    But the good news is that we are close to meeting our target and so we are now confident that we will be able to see this case through the courts. We are now in the hands of the legal system, itself showing signs of strain under current circumstances.

    Thank you to everyone who has contributed to this crowdfunder already – we are very grateful.

    Let’s hope that we can make progress in forcing Natural Resources Wales to adopt a lawful and scientifically defendable approach to lethal killing of birds.

  78. Wild Justice proposes raptor persecution forensic investigation fund and calls for more organisations to contribute

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    Wild Justice has proposed a new fund to help the police tackle wildlife crime. This fund would help speed up the analysis and assessment of forensic evidence in wildlife crime investigations relating to the illegal killing of birds of prey.

    This idea emerged following several conversations with Police Wildlife Crime Officers who have been frustrated at having to persuade senior officers to authorise such costs in a number of recent investigations.  

    Many police forces struggle with slashed budgets and reduced resources, and senior officers aren’t always keen to consent to payment because if the cost of analysis is higher than any likely penalty a judge imposes then it’s hard to justify the costs of laboratory work. These discussions can delay the analyses being undertaken and in some cases may affect the condition of the sample to be tested (e.g. through biological deterioration), resulting in a missed opportunity to secure evidence of sufficient quality to proceed with a prosecution.

    Other schemes, such as the PAW Forensic Analysis Fund, provide only partial funding support (of up to 50% match funding) for a wide range of national and international wildlife crimes using a variety of forensic techniques. Wild Justice proposes that this new fund be administered via the National Wildlife Crime Unit and be focused specifically on providing full funding to cover the cost of specialist forensic analysis to support police investigations into the illegal killing of birds of prey in the UK. This may include something as simple as an x-ray to establish whether a raptor has been shot to more complex techniques such as DNA testing of illegal traps or the analysis of game bags, knives, containers, vehicles and clothing for evidence of both DNA and banned substances.

    Wild Justice will contribute £5,000 to establish the fund and is calling on other organisations to contribute. Case costs could range from a £40 x-ray to several thousand pounds for more specialist analyses. We’re told repeatedly that organisations from the game-shooting world want to see an end to illegal raptor persecution so this is the perfect opportunity for groups such as the Moorland Association, British Association for Shooting and Conservation, National Gamekeepers Organisation, Scottish Gamekeepers Association, Scottish Land & Estates, Countryside Alliance, the Game Fair, Shooting Times etc to put their money where their mouths are.

    Police Superintendent Nick Lyall, Chair of the Raptor Persecution Priority Delivery Group (RPPDG) said: “I welcome this initiative from Wild Justice. As in all criminal investigations, evidence gathering needs to be undertaken swiftly and thoroughly to secure any chance of a prosecution and wildlife crime is no exception. Long delays caused by budget deficits can, and have, impacted on raptor persecution investigations. I believe that this targeted fund will help police officers to be in a stronger position to solve these horrendous crimes and I look forward to seeing RPPDG partners support the initiative”.

  79. Through the post

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    This card arrived in the post recently…

    And on the back was the message;

    Dear Wild Justice

    I thought I would just send this picture to remind you of why you do all that you do, and to say thank you for doing it.

    Thank you to all our supporters for all types of support.

  80. Pheasants everywhere

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    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeeper’s release pen on an English shooting estate

    This post describes a piece of scientific analysis carried out by Wild Justice and friends.

    Estimating the occurrence of Common Pheasant Phasianus colchicus and Red-legged Partridge Alectoris rufa in terrestrial Natura 2000 sites in England.

    Layperson’s summary (written by Wild Justice and approved by scientific collaborators) Wild Justice is taking legal action against DEFRA on their failure to assess the impacts of the very large numbers of non-native gamebirds on sites of high nature conservation importance. For Pheasants and Red-legged Partridges to have an impact on the ecology of a site then, for most impacts, they must be present on the site, although for some impacts being found nearby would be enough (eg through affecting the densities of generalist predators which may use the sites in questions for foraging). Birdwatchers often collect data on the presence or absence of birds in identifiable geographical locations. By collating the publicly available data from such birdwatchers’ observations and comparing those records with the boundaries of sites of conservation importance we examined how many sites of high conservation importance (Natura 2000 sites) had Pheasants, or Red-legged Partridges, or both, inside, probably inside, or at least very close to the Natura 2000 sites.  This analysis shows that only two out of 313 terrestrial Natura 2000 sites in England lack records of Pheasants and Red-legged Partridges within or very close to their borders.  Given that this method is almost certainly very conservative in identifying such sites, we have established that non-native gamebirds are present on the vast majority of English terrestrial Natura 2000 sites and therefore the scale of the task that DEFRA must undertake to assess any ecological impacts.

    Technical Summary Terrestrial Natura 2000 sites in England were intersected with an irregular grid of post-2000 records of Common Pheasant and Red-legged Partridge, each cell scaled according to the spatial precision of the record(s) within it (maximum cell size = 2×2 km). Of the 313 Natura 2000 sites in England that have a terrestrial component, 33.5% entirely contained one or more cells with confirmed presence of Pheasant, 71.9% contained the central points of one or more cells with confirmed presence and 99.4% (all but two Natura sites) overlapped one or more cells with confirmed presence of Pheasant. The equivalent values for Red-legged Partridge were 18.2%, 53.4% and 85.6%, respectively. The average percentage of the land area of terrestrial Natura 2000 sites in England that fell within grid cells occupied by Pheasant was 93.0% (45.6% for Red-legged Partridge), and for a dissolved layer total land area of all SPAs and SACs combined, taking out the overlap between sites, it was 72.1% (31.9% for Red-legged Partridge). Pheasants are therefore present within, or immediately outside, practically all the terrestrial Natura 2000 sites in England, and Red-legged Partridges are present within, or immediately outside, a majority.


    Site boundary data

    Polygon shapefile of all the UK’s Natura 2000 (N2K) sites downloaded from:

    Bird location data

    Location data for Common Pheasant and Red-legged Partridge were downloaded from NBN Atlas: These comprised mostly BTO data (up to 2015) but also included a small proportion of additional locations from other sources. To these were added eBird data filtered to a location accuracy of 100 m. Most NBN Atlas data come as point locations indicating the centre of a square grid cell within which the sighting was made; they do not usually indicate the precise location of the sighting itself. The associated accuracy codes indicate the size of the grid cell to which each sighting was assigned. Note that location accuracy in NBN is rather illogically coded such that a location accuracy of 1km refers to a point in a 1-km square

    1. Records without a location accuracy were deleted
    2. All records with a location accuracy of over 2 km were deleted (these were mostly or entirely from 10-km atlases)
    3. All records prior to 2000 were deleted
    4. Duplicate locations were deleted (e.g. BBS squares were the two species were recorded in multiple years) to leave only unique locations
    5. All records were buffered by a radius of half their location accuracy and squares were created that entirely inscribed the buffered circles (using the “Feature envelope to polygon” tool in ArcGIS), thus re-creating the original square grid cells. These cells were of different sizes and overlapped according to the source data (Fig. 1). A dissolved layer of these cells was also produced for analyses by area (see below).

    Fig. 1. Reconstructed grid cells, showing the different classes of precision of confirmed presence of Common Pheasant (larger blue squares 2-km, medium blue squares 1-km, small blue squares <100m) overlaying part of a Natura 2000 site (Breckland, in red). The white areas are those with no records of Pheasant in the dataset used. In this example, none of the 2-km cells falls entirely within the Natura site polygon, but one of the 1-km cells (“A”) and several of the smallest cells (circled in white) fall entirely within it. Note that due to the very high precision of mapping of Natura sites, with sites broken into multiple small polygons and even roads and individual fields excised from the site, cells such as that labelled “B” and the 2-km cell immediately below it, which fall entirely within the outermost boundary of the site, do not entirely fall within the site’s polygon because of the tiny proportion of their area falling on roads; even two of the highest-resolution cells (in yellow triangles) are not entirely included in the site’s polygon for the same reason.

    Data analysis

    To estimate the occurrence of Pheasant and Red-legged Partridge in each Natura 2000 site with different levels of confidence, intersections were undertaken for each species using spatial joins in ArcGIS Pro to calculate three variables for each Natura 2000 site:

    1. The number of occupied cells falling entirely within the Natura 2000 site
    2. The number of occupied cells whose centres fall within the Natura 2000 site
    3. The number of occupied cells at least partly intersecting the Natura 2000 site

    These are logically nested such that cells captured by intersection 1 are a subset of those captured by intersection 2, etc.. The first intersection, when applied to the example in Figure 1, would yield a count of six (cell “A” and the five much smaller cells circled in white). The second intersection would include these six, plus others whose centres fall in the site polygon (e.g. cell “B”, the 2-km cell immediately below it and the two much smaller cells contained within yellow triangles, plus others). The third intersection would include all cells already captured by the previous intersections plus any other cells that intersect any part of the site’s polygon, even if only to a small extent (e.g. cell “C”, plus many others).

    In order to estimate the percentage of each Natura 2000 site’s area that falls within cells occupied by each species, the dissolved grid of occupied cells was intersected with the Natura 2000 layer using the “Tabulate intersection” tool in ArcMap. In the example shown in Fig. 1, this would calculate the percentage of the site that falls within blue cells (i.e. everything except the bright red portions of the site).

    Once these intersections were complete, N2K sites that were terrestrial and fell entirely within England were extracted using the coding in the spreadsheet accessed here and selecting sites coded Country  = “E” and Zone = “Terrestrial”. Sites listed in this document as being 100% marine were deleted. Some partly terrestrial sites have a marine or inshore component, e.g. some estuaries; for analyses of the percentage area of sites falling within grid cells occupied by each species, the marine component of such sites was excluded.


    Filtering sites as described above returned a total of 313 Natura 2000 sites falling wholly within England that have a terrestrial component.

    The filtered data contained 73,091 cell records of Pheasant (82.2% from BTO data via NBN Atlas, 14.2% from other sources via NBN Atlas, and 3.6% from eBird) and 26,123 cell records of Red-legged Partridge (with a similar breakdown of sources), spread across the UK. Of these, 9.9% were accurate to within less than 100 m, 36.2% were accurate to within around 500 m (i.e. they represented records presented at a 1×1-km cell level and 53.9% were accurate to within around 1 km (i.e. a 2×2-km cell level accuracy).

    Fig. 2. Percentage of all terrestrial Natura 2000 sites in England (n = 313), and of SPAs (n = 79) and SACs (n = 234) separately, that completely contained one or more cells occupied by one or other species (black bars), that contained the centre(s) of one or more cells occupied by one or other species (mid-grey bars), and that intersected one or more cells occupied by one or other species (pale grey bars).

    Figure 2 shows the percentage of terrestrial Natura 2000 sites in England that entirely contained at least one occupied cell, that contained the centre of at least one occupied cell and that overlapped at least one occupied cell, for each species separately and for both species combined (i.e. either Pheasant or Red-legged Partridge). Because the distribution of Red-legged Partridge records fell almost entirely within the distribution of Pheasant records, the combined plot for both species is almost identical to the plot for Pheasant. The percentage of SPAs wholly enclosing one or more occupied cells or containing the centres of occupied cells was higher for SPAs than for SACs, probably due at least in part to the larger area of the former (mean 94.8 km2 vs 36.2 km2).

    The only two terrestrial N2K sites in England that did not intersect any cells occupied by either Pheasant or Red-legged Partridge were the Farne Islands, which presumably lie outside the dispersal range of mainland birds, and Fen Bog, a tiny site in the North Yorks Moors that falls 450 m from a cell with recorded presence of Red-legged Partridge and 1.2 km from a cell occupied by Pheasant. 

    The average percentage of the land area of terrestrial Natura 2000 sites in England that fell within grid cells occupied by Pheasant was 93.0% (45.6% for Red-legged Partridge). These figures do not take account of the fact that SPAs and SACs can overlap one another, and hence that a single record of Pheasant or Red-legged Partridge can fall within more than one Natura 2000 site. When the SPAs and SACs are dissolved into a non-overlapping layer of land under one or both designations, 72.1% of its area falls within cells occupied by Pheasant and 31.9% within cells occupied by Red-legged Partridge. The difference between these figures and the much higher site averages is due largely to the absence of Pheasants (or at least to a lack of records) from large parts of a small number of very large upland moorland Natura 2000 sites.

    DISCUSSION (written by Wild Justice and approved by our scientific collaborators)

    This report uses freely available bird observation data collected mainly by volunteer birdwatchers and made available through the application eBird or through Birdtrack or through more formal data collection exercises such as national surveys of distribution or numbers of birds, mainly organised by the British Trust for Ornithology. The fact that we could analyse these data is a testament to those many thousands of volunteers who collected the data and those who made the data publicly and freely available.

    It is well known that Pheasants in particular, but Red-legged Partridges too, are widely distributed across most of England in practically all habitats (eg farmland of a variety of types, open moors and heaths, woodlands of all types) but the occurrence of these two non-native bird species in relation to sites of high conservation value have not before been examined to our knowledge. Our analysis, which shows, essentially, that these two non-native gamebirds, released for shooting for pleasure, are found on practically all Natura 2000 sites does not come as a surprise but is a novel result.

    Might these data, or this analysis of them, overestimate the incidence of these birds on Natura 2000 sites? We feel it is unlikely. Pheasants and Red-legged Partridges are moderately large birds and can easily be identified, by sight or call, by many members of the public let alone the keen birdwatchers who mostly contribute to the datasets we have used.  Therefore we feel that there is little chance of false positives in terms of misidentifications. We cannot think that the methods of analysis used would overestimate the presence of these birds on these sites.

    In fact, these results are probably highly conservative in their findings given that they depend on visits to sometimes remote locations in England. If no-one has visited a site then there will be no records for us to examine. However, it is certainly the case that if there were more visits then there would be higher incidences of presence recorded in this dataset. There may be another small factor which leads to conservatism, some birdwatchers do not regard these two species as ‘real’ birds given that they are non-native and their numbers are hugely influenced by annual releases of captive-bred individuals and so may not think them worthy of recording.

    These data only give clues to numbers of the two species present on Natura 2000 sites (as opposed to presence in unknown numbers) but the high incidence of presence suggests that numbers are appreciable at many sites (a conjecture born out by personal observation). Some of the datasets analysed by us could be used to explore this issue further and we have carried out some small-scale analyses for selected sites. Birdtrack data, allocated to well-known sites such as nature reserves (where they are contained, as they quite often are) within Natura 2000 sites, could be analysed to examine what proportion of visits where complete lists of birds seen were recorded, contain the relevant species. One could then identify for any Natura 2000 sites what proportion of visits to the sites recorded either Pheasants, Red-legged Partridges or both. It might then be possible to construct a league table of Natura 2000 sites ranked by the likelihood of non-native gamebird observations. Wild Justice has done some simple analyses with data which were to hand, to show that this is feasible and we recommend this approach to DEFRA. Perhaps DEFRA is already carrying out such an analysis but if they are then we are unaware of it.

    These findings show that Natura 2000 sites in England have non-native gamebirds recorded within their boundaries, probably within their boundaries or near their boundaries with a very high incidence. This has implications for DEFRA’s review of impacts of these the non-native species of gamebird on the integrity of Natura 2000 sites.

    Comments on this post: we will allow comments on this post, normally we do not allow comments. We will moderate (ie read and check before publishing or rejecting) any comments submitted. All comments should have a name (rather than a pseudonym) attached to them (although we won’t know whether it actually is your real name) and a valid email address. We are allowing comments so that any scientific points can be made about this scientific analysis – and we welcome those. An alternative to leaving a comment here is to email us at

    For GDPR purposes: we will know your name, email address and ip address if you submit a comment. If we reject your comment then your details will not be retained. If we publish your comment then we will have access to your name (real or not), email address and your ip address. We will not give or sell this information to anyone and we will only use it to contact you about your comment and because it is required information for the commenting software to operate.

  81. Why is NRW allowing casual killing of Jackdaws?

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    Jackdaw. Photo: Tim Melling

    Natural Resources Wales authorises the uncapped, unchecked, unregulated killing of Jackdaws all over Wales through its General Licence GL004. This is supposed to be a conservation licence. It’s outrageous – totally outrageous.

    We know of no conservation organisation that culls Jackdaws on its land and yet NRW is allowing this killing for alleged conservation purposes – conservation of what, exactly? NRW lists the species for which killing of the four corvid species on GL004 is authorised, but without telling us whether it is the Jay that is predating Gannet chicks or Jackdaws. Most of the species listed on Annex 1 are simply ridiculous – after all, a lot of them never nest in Wales!

    Although NRW have had evidence that Jackdaws are not a conservation problem they appear to have ignored it. We won’t go into all the details, but the more you do, the more alarming the NRW General Licences appear. Take for example the NRW General Licence Review report.

    Have a look at Table 2 on page 12, and look at Jackdaw under licence GL004. You will see that Jackdaw scores 2 in one column (showing that there is some quite good science done on the subject) and 1 in the other column which purports to be the strength of the evidence. Clearly the evidence is fairly weak because Jackdaw doesn’t score 2. What does a score of 1 mean?

    We’ve discussed this before on this blog – see here. The score of 1 comes from a BTO report to SNH where, for some reason, we can’t think what reason, and we certainly can’t think of a good reason, if there is one study that suggests that Jackdaws are important predators of other species and millions of studies which suggest they have no impact at all, then the BTO report to SNH scored that species as having an effect. This the opposite of giving a species the benefit of the doubt and it flies against the precautionary principle. What the flawed BTO report does, and what NRW has repeated without thought it seems, is remove the benefit of any doubt and paved the way for widespread culling of Jackdaws for alleged but unexplained conservation purposes across the whole of Wales in unlimited numbers. Scandalous!

    Look at the BTO report and what it says about Jackdaws on pages 33 and 34 – click here. Is that the evidence that would move you to put Jackdaw on a general licence which authorises unlimited killing of a species across Wales?

    Let’s go back to the NRW report and look at page 32. It says about Jackdaw;

    Low expert opinion and no anecdotal evidence to suggest jackdaw will have an impact on wild bird prey populations.

    And yet, on this basis, Jackdaw is regarded by NRW, but not by any conservation organisation that we know, as a widespread conservation problem. Its ridiculous.

    Wild Justice is challenging this general licence – here is our crowdfunder.

  82. The strange case of NRW and the missing eggs

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    This post is about our legal challenge of the general licences issued by the public body, Natural Resources Wales, on 1 January 2020. To take a legal challenge against the decision of a government body requires a good knowledge of the law, and none of the three Wild Justice co-founders, Mark Avery, Chris Packham and Ruth Tingay, would claim to know much about the law, but we do know a bit about nature conservation (and luckily we have a great legal team).

    The Welsh General Licence GL004 purports to be a licence for the purpose of conserving birds by taking lethal control measures against four corvid species (birds of the crow family, Corvidae). The four corvids are Jackdaw, Jay, Magpie and Carrion Crow, and we’ll come back to them in later blogs, but let’s for a moment consider the purported beneficiaries of this licence – a list of 143 bird species listed at Annex 1 of GL004.

    Having a list of species such as that long list of species at Annex 1 of GL004 is a good thing – it’s actually attempting to be more specific about what the conservation purposes of the licence are – not to conserve every bird species in Wales but to conserve these particular species. That’s a small step forward compared with the general licences in Scotland or England.

    The NRW licence goes one small step further in stating very clearly that it is only to protect the eggs and chicks of the 143 species, not the adult birds. That seems quite sensible too.

    But, of course, for the licence to have any scientific credibility the list of 143 species has to be a sensible list. Now, we could, and probably will in later posts, get into whether species A of the four corvids (eg Jay) has a population level impact on Species B from the Annex 1 list (eg Gannet). What do you think? Are Jays an important predator of Gannet eggs? Nah, nor do we! But for now we don’t have to get into even that very easy discussion.

    Do you recognise the egg at the top of this post? You might guess it’s a duck egg but we’d guess that few would have identified it as a Velvet Scoter egg. Hats off to you if you did, though.

    Here is an adult male Velvet Scoter;

    Velvet Scoter Melanitta fusca

    …and a female;

    Velvet scoter, Melanitta fusca, single bird swimming on water, winter, Lancashire, UK

    …they’re quite cute ducks aren’t they? They are normally seen in Wales offshore, bobbing up and down in the waves in the winter months. Have you guessed where we are going with this?

    Velvet Scoter is one of the 143 species whose eggs and/or chicks you can protect, thanks to NRW’s General Licence GL004, through killing Jackdaws, Jays, Magpies or Carrion Crows. The only trouble is that Velvet Scoters do not nest in Wales, come to that they do not nest in the UK – probably never have, probably never will.

    NRW might just as well have added Emperor Penguin to Annex 1 for all the sense it would make.

    And yes, we are taking the mickey out of NRW staff and their illustrious and knowledgable Board, because by our reckoning there are loads of species in Annex 1 which don’t, never have or hardly ever do nest in Wales. So who is taking the mickey really? Annex 1 is listed alphabetically and in the As and Bs we find: Arctic Skua, Balaeric Shearwater, Bar-tailed Godwit, Bewick’s Swan and Brambling – if they all nest in Wales in 2020 it will be quite a year!

    By our reckoning there are c30 of the 143 species on Annex 1 which are not Welsh breeding species and yet you are authorised to kill an unlimited number of Jackdaws anywhere in Wales to protect the eggs and chicks of these non-breeding species.

    This is not by any means the only thing bizarre, unscientific and wrong about these general licences. But it’s a pretty big fail at a pretty fundamental level.

    Please help us to take our legal challenge against NRW General Licence GL004 through donating to Wild Justice’s crowdfunder – click here – or through donating directly to Wild Justice – click here.

    Thank you to all our supporters so far – we are a third of the way to our target after just three full days.

  83. BASC blow a gasket

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    We’re pretty accustomed to abuse from the shooting community – often from individuals but increasingly from their representative body BASC. The vituperative BASC are apoplectic with Wild Justice because of our legal challenge of the Welsh general licences – see here for what BASC say and see here for details of our challenge..

    Apparently the three of us, Chris, Mark and Ruth, are bringing down the whole of farming, the whole of the countryside and the health of Wales by using legal approaches, available to all in a democracy, to challenge government action.

    What is abundantly clear is that BASC is mightily rattled by the changes that are inevitable to the way that bird killing is licensed. We can’t be sure that we will win this case, but we are confident that we have an excellent chance, but we can be sure that change is on the way. BASC knows that it cannot bully Wild Justice and it cannot bully the law – so it just goes completely over the top with abuse. It is a strange way for a representative body to behave, have you ever heard the RSPB, the Wildlife Trusts or the National Trust using language like BASC uses against a few individuals with whom they disagree? And this approach will go down very badly with public bodies who will not want to be seen to be too closely associated with an organisation that spews out such nastiness. As is so often the case, shooting organisations are shooting’s worst enemies.

    And lest there be any doubt about it, the timing of our legal challenge is not of our choosing, it is determined by the timing of the issuing of the general licences under challenge, the passage of exchange of letters between us and NRW and indeed the fact that NRW appears to want to fight this case. NRW knew full well that they would probably face a legal challenge if they issued their flawed general licences and yet they did. Bring on the legal battle!

    And the excellent progress of our crowdfunder will have rattled BASC too – yesterday its total passed £1,000, £2,000, £3,000, £4,000, £5,000, £6,000, £7,000, £8,000, £9,000, £10,000 and £11,000 in a single day. thank you to all our supporters.

    If you would like to support our challenge of the casual killing of birds in Wales then visit our crowdfunder here please. And thank you!

  84. Our latest legal challenge – general licences in Wales

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    Jackdaw. Photo: Tim Melling

    Yesterday Wild Justice’s lawyers filed our application for a judicial review of Natural Resources Wales’s (NRW’s) issuing of general licences on 1 January 2020.  We’ve launched a crowdfunder and we’re seeking to raise £42,500 to pay the legal costs we have already incurred and to take this case through the courts. Please give generously to enable us to mount this challenge.

    This is the latest in our challenges of the legality of the general licences which allow the casual killing of millions of birds across the UK. We have already seen some minor changes to the licences and the species listed in England, Scotland and Wales but there is much more to do. This challenge, of the Welsh licences, will have implications right across the UK. We need to see the licences tightened up considerably to comply with the law and to reflect the scientific evidence.

    Our legal grounds of challenge

    All wild birds are protected by law and the exceptions to this full legal protection are well-defined and quite specific. 

    Although NRW identify the purposes of their general licences (eg nature conservation, protecting crops from serious damage, human health etc) they do not identify the circumstances under which there is no non-lethal alternative to using lethal control. This, we argue, is unlawful and amounts to allowing casual killing of otherwise protected birds.

    Our three legal grounds are:

    • Unlawful failure to specify circumstances
    • Unlawful failure in relation to satisfactory alternatives
    • Unlawful approach to derogations

    The science is lacking

    Our main concern with NRW’s licences is with General Licence GL004 which purports to be a nature conservation licence.  Although licences GL001 and GL002 have the same legal flaws we might not have challenged them if they weren’t associated with the awful GL004.

    GL004 allows the killing of Jackdaw, Jay, Magpie and Carrion Crow to protect the eggs and chicks of a list of 143 bird species in Wales. At first glance, it looks like a decent job has been done by NRW, but the more we looked the more we realised how poor a job they had done.

    First, many of the 143 species listed have never, and will never, nest in Wales! Species like Sanderling and Velvet Scoter are winter visitors and corvid predation on their eggs in Wales is simply out of the question.  Yet NRW list them as species whose eggs and chicks can be protected by lethal killing of corvids!

    Second, there is no strong evidence, and precious little weak evidence, that, for example Jackdaw has any impact on species of conservation concern in Wales (or anywhere else). In one of the most important studies looking for evidence of impacts of predation on prey species the authors didn’t even consider Jackdaw as worth examination because it simply isn’t a predator of nests and chicks. Also, the literature review on which NRW relies actually states that there is a ‘Low [level of] expert opinion and no anecdotal evidence to suggest Jackdaw will have an impact on wild bird populations’ and yet Jackdaw is on the list as a species that can be killed for nature conservation purposes.This is turning the precautionary principle on its head.

    We believe that Jackdaw, Jay and Magpie must be removed from GL004 and that the licence would then only cover Carrion Crow, but that the circumstances where Carrion Crows can be killed for nature conservation purposes must be greatly limited.

    The Wild Justice witness statement runs to about 25 pages so you can see that there is much more we could say but we seek to get these issues settled in court according to the law.

    Our requested remedy

    We are asking for permission for judicial review of the 2020 Welsh general licences where we will ask the court to declare the licences unlawful. This will give NRW the opportunity to carry out a proper review of these licences in time for lawful alternatives to be issued in 2021.

    Please help us by contributing to our crowdfunder – click here. Thank you!

  85. Wild Justice misrepresented by Daily Telegraph, again

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    Scaremongering and hysteria is the response we’ve come to expect from many within the game-shooting world whenever Wild Justice launches a new legal challenge, and that’s exactly what the Daily Telegraph published yesterday in an article headlined as, ‘Dog walkers could be banned from swathes of countryside under Chris Packham plans, it is feared’.

    According to Telegraph journalist Hayley Dixon, Wild Justice’s current legal action against DEFRA concerning the Government’s failure to undertake environmental impact assessments on the release of millions of non-native gamebirds near Natura 2000 sites, ‘could have a knock on effect on other activities’ such as ‘dog-walking, horse riding and farming’. Her article includes quotes from BASC, Countryside Alliance, Game Farmers’ Association and the National Gamekeepers Organisation so it’s not difficult to see what prompted the melodrama.

    Wild Justice co-director Dr Mark Avery said the suggestion that dog-walking would be affected was “nonsense”, adding, “Our case is about the real issue of biodiversity concerns”.

    Solicitor Tessa Gregory from law firm Leigh Day, representing Wild Justice, did provide a quote to the journalist but only part of it was published. Here it is in full:

    The suggestion that Wild Justice’s legal claim could result in the need to assess the environmental impact of dog-walking in the countryside is wrong and shows a fundamental misunderstanding of the law. Assessment is required under the law where, based on objective evidence, it is not possible to exclude likely significant effects of a plan or project on protected sites (known as Natura 2000 sites).

    It is the scale, organisation and regularity of the mass release of gamebirds that mean such releases are capable of being a plan or project for the purposes of the law. Where these mass releases are on or near protected sites, it will in some instances (as accepted by Defra), not be possible to exclude negative impacts. It is in those circumstances that Wild Justice are asking the Government to comply with the law and carry out an assessment of the environmental impact of gamebird releases. Of course, there is nothing to fear from an assessment if a particular activity does not harm a protected site”.

    Oh, and by the way, Daily Telegraph, none of the three Wild Justice Directors (Chris Packham CBE, Dr Mark Avery, Dr Ruth Tingay) are ‘animal rights activists’ as you’ve wrongly asserted. We’ve been here with you many times before (e.g. see here) and if you continue to misrepresent us we will consider legal action.

  86. Banning driven grouse shooting to be debated in Westminster parliament

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    The Wild Justice e-petition which reached 100,000 signatures on Day 20 of its existence back in early September will be debated by backbench MPs in Westminster Hall soon – we imagine that it will be late March or early April.

    Do not think that such a debate will rapidly lead to the banning of driven grouse shooting but it will be interesting to see what MPs say about the issue three and a half years after it was first debated. Since that time we have seen more floods, more calls for burning to cease on all peatlands and considerably more evidence of the scale of wildlife crime against protected birds of prey. In Scotland we have seen the publication of the Werritty report which calls for licensing of grouse shooting.

    This debate will provide an opportunity for a DEFRA minister to say something on the issue. Heather burning is a hot topic now and this debate will give DEFRA the opportunity to lay out their plans on that subject. If they don’t, questions will be asked.

    Wild Justice and other environmental organisations will be briefing MPs on the issues.

    Once we know full details then we will post them here and put them in our next newsletter. The newsletter will also include information on what you can do to help this debate go well. Sign up for our newsletter – click here.

  87. Putting UK gamebird numbers in context

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    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate

    Here is another paragraph from the Wild Justice witness statement supporting our legal challenge;

    The scale of gamebird releases is a particularly UK issue. When measured in spring (standard practice for bird populations) the breeding populations of Pheasant in the UK (ie those birds which have survived the shooting season, and the winter to breed in the spring before further massive releases in the summer) comprise about a half of the whole European population. Other countries have Pheasant shooting but they do not release such vast numbers of farmed birds into the countryside a few weeks before the shooting season as we do in the UK. The Netherlands banned almost all gamebird and game shooting in 2002 on a mixture of animal welfare and conservation grounds.

    Or to put that a different way, the UK has 50% of the European population of this non-native bird whilst occupying only 2% of the land area of the continent.

    And to put it yet another way, if the UK had the same density of Pheasants as the rest of the Europe then our population would be 1/50th of the current level.

    DEFRA has ignored the ecological threat to UK wildlife for far too long and now needs to take urgent steps to assess the impacts on our wildlife.

  88. Non-native gamebirds challenge – what they say

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    Seven week old pheasant poults, after just being released into a gamekeeper’s release pen on an English shooting estate

    The Guardian covered our legal challenge – very accurately – click here.

    One of us, Mark, was on talkRADIO this afternoon – that was fun.

    Amongst many messages of support we’ve received was this email:

    I’ve just heard Mark Avery on talkRADIO and thought he was absolutely amazing, a brilliant spokesperson.  What is staggering is that he said this could go either way in the courts and I dont understand why.  Anyway if there is a campaign I can sign I would love to.  It disgusts me and upsets me how these birds are treated in the name of “sport”.    I do everything I can to look after the birds in my little garden they are all fed all year round.  What is it with some humans who just want to kill and destroy defenceless animals

    Well done for your great work in highlighting such a huge issue to the public. 

    DEFRA need to pull their finger out. 

    We agree – this is what we say about our case – click here.

  89. Wild Justice seeks judicial review of gamebird releases

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    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate

    On Monday afternoon our lawyers lodged court papers calling for a ban of releases of Pheasants and Red-legged Partridges into the English countryside this year except where DEFRA has ruled out any impacts on the ecology of Natura 2000 sites.  This is the latest stage in a legal challenge which began in November 2018.  DEFRA admitted last year that it was required to assess the impacts of the vast numbers of non-native gamebirds on Special Protection Areas for birds and Special Areas of Conservation for wildlife and yet has recently admitted that its progress is so slow that nothing will be in place to limit releases this year. DEFRA has therefore not taken the necessary steps quickly enough to avoid further unlawfulness and we are seeking an expedited hearing for judicial review of their decision.

    Each year gamebirds reared in captivity are released into the countryside in late summer ahead of the shooting season. Both the species in question, Pheasant and Red-legged Partridges, are non-native species and are released in vast numbers. Industry estimates are that 47 million Pheasants and 10 million Red-legged Partridges are released for shooting.

    Here is an extract from our Statement of Facts and Grounds where the Claimant is Wild Justice and the Defendant is George Eustice, Secretary of State for Environment, Food and Rural Affairs:

    The Claimant seeks permission for a judicial review to be considered on an expedited (so as to allow for determination of the claim well before July 2020 at which point releases of gamebirds will begin) basis.

    At the substantive (or rolled up) hearing, the Claimant will ask the court to declare that:

    • As set out above, the UK has unlawfully failed to implement the Habitats Directive.

    • The Defendant has unlawfully failed to take such steps as would be required (or indeed any steps) to ensure compliance with the Directive as set out above in relation to the release of game birds for sport shooting in the summer of 2020.

    • Given that the Defendant has failed to ensure that Appropriate Assessments will be undertaken (and releases will only be in accordance with their conclusions), the releases of game birds in 2020 will be unlawful other than in those particular cases where it is possible to exclude from the outset adverse impacts on Natura 2000 sites.

    The Claimant also asks for an order that the Defendant should exercise his powers to issue SNs (Stop Notices) to prevent such releases.

    Here is an extract from our witness statement:

    Imagine that there were no Pheasants or Red-legged Partridges living in the UK at the moment and somebody suggested releasing nearly 60 million of them for the first time this summer! There is no possibility that such a situation would be nodded through by any competent government department. And yet the scale of non-native gamebird releases has been allowed to increase steadily and inexorably over recent decades with government and its agencies failing to regulate or even study these impacts in any adequate manner. That must end now because common sense requires it but so does the law as far as it pertains to Natura 2000 sites.

    Yesterday we heard that the Hon Mr Justice Mostyn did not grant our request that the period for the Defendant to file its acknowledgement of service and summary grounds of defence should be shortened, but did order that on filing of the acknowledgement of service and summary grounds of defence the papers are to be placed as soon as possible before a judge to decide if permission should be granted and, if so, who the interested parties should be and whether the claim should be expedited to be heard before the end of the Trinity term 2020.

    The three co-founders of Wild Justice said;

    Chris Packham CBE: DEFRA has been dragging its feet on this issue since we first raised it. It is time to sort this out and Wild Justice is fully prepared for a court battle on behalf of UK wildlife.  Our challenge relates to Natura 2000 sites in England but the impacts will be felt right across the UK countryside.

    Dr Ruth Tingay: The lack of monitoring and regulation of gamebird releases is staggering. The Government doesn’t seem to know or care how many are released each year and even the figure of 60 million gamebirds may well be an underestimate.  Incredibly, there is nothing to stop the shooting industry releasing twice as many gamebirds next year. This has to stop and proper regulation brought in.

    Dr Mark Avery:  These non-native gamebirds go around gobbling up insects,  other invertebrates and even snakes and lizards, they peck at vegetation, their droppings fertilise sensitive habitats which no farmer would be allowed to fertilise and they provide prey and carrion that swell the populations of predators that then go on to prey on other threatened species. And the biomass of Pheasants and Red-legged Partridges exceeds that of all native UK birds put together. This is a very serious ecological assault on the countryside which government is failing to assess and regulate.

    Wild Justice is represented by Tessa Gregory and Carol Day, solicitors at Leigh Day.

    Carol Day: Wild Justice quite rightly held off issuing legal proceedings last year on the basis that the Government said it would review arrangements to consider the impact of the gamebirds’ release in future. It is now clear that the review has only just started and that no action will be taken that could affect the shooting season in 2020.

    If Wild Justice waited until September to challenge the legality of the gamebird releases it would be too late. The Pheasants and Partridges would have left their breeding pens, and the damage could then be done. And so – responsibly and properly – the Claimant is acting now, at a time when it is still possible to head off the alleged illegality.

  90. Small successful event in London

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    Ruth Tingay of Wild Justice (centre) with a bunch of leagal eagles

    On Thursday evening, Wild Justice held a small event in London with friends, colleagues, donors, potential donors, journalists and others. We weren’t going to mention it here but Charlie Moores wrote a lovely blog about it which you might like to read – click here.

    We can tell you that our guests were very generous and we’ve had donations of over £5,000 since then.

    On a less positive note, when Chris Packham got home after midnight, after a very busy day, he found a dead Badger tied to his gate.

  91. Game Fair, fair game 2020

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    Last year Wild Justice directors Chris Packham and Mark Avery were invited to the annual Game Fair to face a barrage of difficult questions about our thoughts and opinions on a variety of matters. We are pretty much always up for talking to people and so accepted the invitation as much out of a sense of duty as real enthusiasm.

    And, you may remember, a few days, very few, before the actual event we were uninvited by the Game Fair organisers (actually only Chris was univited Mark read it on the BASC website – how classy are they?).

    We notice that the Game Fair is in Warwickshire this summer and at the moment we might be free (all three of us not just the two blokes) so we’d just like to offer some advice to BASC, GWCT, the Daily Telegraph, Moorland Association, Countryside Alliance and others: if you’d like us to attend this year then ask us soon and get yourselves sorted out so that you can try to avoid the public relations disaster you caused yourselves last year. Just saying…

    Here are some links to last year’s events (here, here, here, here)

  92. Superb raptor watch at Wicken Fen

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    We were very lucky. Considering the wind was blowing and it was raining when we arrived, it was unexpected that the weather would improve so much in the next hour. About 10 of us had chanced the weather and went on a raptor walk at Wicken Fen yesterday afternoon, and our main hope was to see, to glimpse, Hen Harriers coming in to roost.

    We were very lucky. Five steps out of the warmth and shelter of the National Trust visitor centre we had seen a very distant Barn Owl and two quite distant ringtail Hen Harriers as well as Marsh Harriers. Wow! It was worth coming after all.

    We were very, very lucky because later we had superb views of male and ringtail Hen Harriers. Multiple views, long-lasting views and close views. Some of the best harrier-watching I’ve had and the best so far for many of the rest of the group.

    Ringtail Hen Harrier. Photo: Gordon Yates
    Male Hen Harrier. Photo: Gordon Yates.

    The harriers, Marsh and Hen, were coming in to roost after a day of feeding out on the Fens and on the nature reserve at Wicken Fen itself. The Hen Harriers are winter visitors here, and nest, if these birds nest in the UK which is quite likely, mostly on moorland areas of Wales, Scotland and northern England. Their numbers are greatly reduced by illegal persecution on grouse moors because Hen Harriers eat Red Grouse that people want to shoot.

    The Hen Harriers we saw weren’t eating Red Grouse, there aren’t any within 100 miles of Wicken Fen, instead they are eating small mammals such a voles and small passerine birds such as finches, buntings, sparrow, pipits and larks.

    This was the third raptor watch that Wild Justice directors, Ruth Tingay and Mark Avery, have attended and we’ve seen Hen Harriers (and obviously lots of other birds) at every one ( Wicken Fen, RSPB Wallasea Island and RSPB Titchwell). We chickened out of travelling to The Wirral last weekend because of the foul weather and we have failed to set up an event in Kent this year, despite trying. But we’ll consider doing similar walks next year if people are interested.

    Thank you to the RSPB and National Trust for hosting and facilitating these walks. Each was great fun. But yesterday at Wicken Fen was just superb. We were very lucky.

  93. DEFRA roll out of general licences

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    Common Jay Photo: Andy Rouse

    DEFRA has rolled out the existing scientifically flawed and, we believe, unlawful general licences for several more months. This is yet another sign that DEFRA pays little attention to its environmental responsibilities or, perhaps yet another sign that DEFRA just cannot function properly these days. It’s difficult to tell which.

    It’s certainly a very clear sign that DEFRA has no urgent interest in properly regulating the casual shooting of millions of birds but then DEFRA has been slow to act to reduce illegal killing of protected wildlife and quick to sanction killing of tens of thousands of protected Badgers so this does not act like a government department with the interests of wildlife at its heart. That’s a reason why Wild Justice needs to take battles on behalf of wildlife.

    The issuing of these licences was, last year, a job which Natural England carried out. Many will remember that Natural England completely botched their response to Wild Justice’s legal challenge and revoked the then-existing licences with a matter of a few hours notice to all involved (despite having had legal advice weeks earlier that their licences were unlawful). Natural England then began what looked as though it might be a somewhat lengthy process of issuing a much larger number of more specific general licences (more on that approach later) until Michael Gove took the licensing role away from Natural England in what looked like a fit of impatience, telling all and sundry that DEFRA would sort it out much better and much more quickly. DEFRA has sorted out nothing under either Michael Gove or Theresa Villiers and DEFRA now plan that the discredited general licences will run for another five months until, we are promised, new licences will be issued.

    It’s just another DEFRA shambles.

    Wild Justice was invited to a meeting with DEFRA officials yesterday (we were invited on Wednesday evening for a meeting on Thursday afternoon). It was a private meeting and we were frank with DEFRA. As you can imagine (because we have made them often before) we made the following points;

    • Wild Justice is unimpressed by a further roll out of scientifically flawed and unlawful general licences. We do not believe that DEFRA is doing its job properly.
    • a 5-month extension of the existing discredited licences is in many ways an extension by a further calendar year because most of the casual killing of birds that these licences ‘authorise’ will take place in spring.
    • Wild Justice’s most pressing concerns are over the so-called conservation licence which does not specify what it is aiming to conserve, where it is aiming to conserve it and at what period of the year any such measures would be most effective. This licence, in particular, should not have been rolled over in anything like its current form. DEFRA has been negligent in encouraging further casual killing under a licence which purports to have a nature conservation function.
    • in particular, DEFRA has had ample time to consider the species listed under the so-called conservation licence and it should by now realise that there is no justification for having Jackdaw, Jay, Rook or Magpie on such a list. It does not take this long to review the science and in rolling over this licence for another breeding season DEFRA has simply rolled over to the shrill and unscientific cries of the likes of BASC. By not addressing this issue whatsoever and introducing any change for over a year then DEFRA has ignored the evidence that it has received from true nature conservation organisations and further reduced any claim it might have for science-led policy making. It doesn’t take this long to cross some species off a list.
    • further, the inclusion of released gamebirds on the livestock/crops licence is bizarre and another example of how the shooting industry appear to hold sway over DEFRA. Yes, Pheasants and Red-legged Partridges when in captivity in breeding facilities are livestock but DEFRA has bent the definition of livestock out of any semblance to reality when saying that free-living gamebirds are still livestock when they are at large in the countryside because they might come back and visit their release pens now and again. No civil servant worth their salt would ever draft such nonsense so surely this must have been dictated word for word by shooting interests? Who owns each individual gamebird with this status? How do they know who is the owner since gamebirds are not individually recognisable or close-ringed? Can I seek compensation from gamebird releasers if their livestock are in my garden eating my vegetables? Can I sue the owner of these livestock if they cause a road traffic accident? Can I shoot livestock? Can my gamebird-releasing neighbour claim that I am shooting his livestock if he thinks his livestock have crossed the boundary and been driven on one of my shoot days? And yet DEFRA has rolled over this nonsense after months of review.

    Wild Justice made some other points too, but that’ll do as a summary.

    DEFRA officials assured Wild Justice that the review they were carrying out was detailed and thorough, and we do not doubt that. Although, of course, we have no clear evidence about it and can only see the complete unwillingness of DEFRA to make any changes at this crucial time of year and instead DEFRA has done what the shooting industry in particular has demanded and kept everything in its discredited form for more months.

    DEFRA asked Wild Justice whether we were against general licences in principle. We reiterated that we were not, but that we reckoned that DEFRA was finding that it was very difficult to write general licences that are detailed enough to be lawful. We can imagine that DEFRA may eventually reach the position that Natural England had reached when Michael Gove strode manfully into the debate, saying ‘Let me deal with this’, and realise that they need to have much more detailed and specific general licences, and more of them, to deal with different circumstances, than the incredibly vague ones that exist now. But that is up to DEFRA to decide – they should have decided by now.

    Let us imagine that DEFRA officials come up with proposals for a new licensing system, as a result of careful and detailed consideration, that are far better than the ones we are living with today – this must be possible. DEFRA needs to consult Natural England on the new licences and then they must be signed off by ministers. There is nothing certain about the outcome of this process. The outcome is not certain and the timing is not certain.

    DEFRA officials were quite keen to know Wild Justice’s intentions on the legal challenge. That’s a matter for Wild Justice and its lawyers to consider and we are. As you can see from the above, DEFRA has done nothing to reduce the chance of legal challenge to their licences as they have changed nothing, promised nothing and merely kicked the tatty and damaged can down the road for another five months.

    Wild Justice can, of course, test some of the legal issues by legal action against Natural Resources Wales general licences, or potentially Scottish Natural Heritage general licences as well as the DEFRA general licences. These are possibilities under active consideration.

    Also, we had a quick chat about gamebird releases where DEFRA has already told us that they need several months more to decide what they are doing. Wild Justice pointed out to DEFRA that having admitted that the law requires them to assess the impact of gamebird releases on sites of high nature conservation importance then they may be acting illegally if they do not limit such releases this year. That was just a reminder, we’ve said it before.

  94. It’s our birthday!

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    We launched Wild Justice a year ago today.

    We’re just getting into our stride and looking forward to Year 2.

    Thank you to all our supporters.

  95. Gamebird releases – update

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    Here are the most pertinent parts of a letter sent to DEFRA yesterday;

    and then;

    We trust that is clear…

  96. A busy week

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    Monday – receive response from DEFRA on gamebird releases – we are waiting for our lawyers to advise us on options

    Tuesday – publicise our new legal challenge to the Welsh general licences and spend three hours on Twitter responding to questions and taking insults from people who almost all self-identify as shooters.

    Wednesday – a phone conference with our legal team and some experts – watch this space or to be sure to be kept in touch then sign up to our newsletter – click here.

    Thursday – one of us does have an interesting meeting on this day.

    Friday – we expect a response from DEFRA on general licences but since these things tend to arrive at the close of play (if at all) two of us, Ruth and Mark, may well be watching Marsh Harriers going in to roost at Titchwell RSPB nature reserve in Norfolk at the time.

    Sunday – Mark and Ruth will be at Parkgate on The Wirral with lots of other birders looking for harriers, Marsh and Hen, out on the saltmarsh and there will be lots of other birds too.

    And dispersed throughout this there will be lots of emails to read and send, and sending thank you cards and emails to donors who send cheques to us through the post.

    Wild Justice is just three people, Ruth Tingay, Chris Packham and Mark Avery, none of whom is full time and none of whom is paid any salary. We are building up a Fighting Fund so that we can investigate a large number of legal challenges and pick those that stand the best chance of success coupled with making the biggest impact on wildlife. If you’d like to contribute to our Fighting Fund then that would be very kind of you – the options are through PayPal, bank transfer or cheques through the post – click here for details. Thank you.

  97. NRW – your general licences are unlawful

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    Jackdaw. Photo: Tim Melling

    Yesterday we sent this letter to Natural Resources Wales.

    It won’t have come as a shock to them as we have corresponded with them on this matter.

    Unless NRW agrees with our legal interpretation then we intend to apply for permission for judicial review of their issuing of general licences. If we do this then we will need to raise funds for such a legal case.

    As always, Wild Justice’s main interest is in the general licence which applies to lethal control of birds for so-called conservation purposes but since the legal flaws we have identified with that general licence apply to all the general licences issued by NRW then there is little point in trying to differentiate between them. The farming industry should reflect on that.

  98. When will this e-petition get debated?

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    Wild Justice is looking forward to the day when our successful e-petition to ban driven grouse shooting will be debated by backbenchers in Westminster Hall. Ours was one of very few e-petitions to have reached 100,000 signatures before the general election – in less than 20 full days in our case.

    Everything was put on hold for weeks in the run-up to, during, and after the general election. Only last week was the Chair of Petitions Committee elected by MPs. The new chair is Catherine McKinnell MP, Newcastle upon Tyne, North (Labour).

    Although Westminster Hall debates do not end in a vote, or a change in government policy, they do require a response from a minister (from DEFRA in this case) and allow the Shadow Minister to make points and backbenchers of all parties to air their views. It is an opportunity for an issue to be raised and put on the parliamentary record for ever.

    Here is the link to the e-petition text. Thank you to 111,965 of us who signed it.

  99. Parkgate – Sunday 9 February

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    Hen Harrier. Photo: Gordon Yates

    On Sunday 9 February Ruth Tingay and Mark Avery from Wild Justice will join lots of other birders and raptor enthusiasts on the Dee Estuary to look for waders, egrets, Marsh Harriers, Peregrines, Short-eared Owls and, we hope, a sighting or two of Hen Harriers hunting over the saltmarsh.

    Here are details if you’d like to join the throng.

  100. In the post…

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    This seems an appropriate day for this card and its message and enclosure to arrive in the post.

    Wildlife knows no political boundaries, and neither should wildlife’s friends.

    Thank you!

  101. A recent email

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    We received this on Thursday afternoon but didn’t actually read it until Thursday evening (which is quicker than we get to some emails!).

    Dear Wild Justice

    Personally I am heavily involved in the hunting, shooting and fishing community so must remain annonymous for obvious reasons.

    Something has come to light that may be of interest to you. It will not shut down shooting, which I know you are fans of doing, but it will be of significant interest and providing that you know how to press for conviction would well lead to one.. Obviously my annonymity is important for me, but also my desire to see family financially cared for is important.

    If there is an arrangement available whereby I can provide information on the basis of an annonymous source, such as a private investigator, that would result in financial reward in exchange for information about a significant a pest control supply company, that would be of great interest to myself and equally to yourselves I am sure. If this is something that you would be possible please let me know how arrangements can be made. Kind regards

    received by email on Thursday afternoon

    Two of us had a quick chat about this email but before we responded we got another one from the same email address as follows:

    Time’s up. This is going straight to the police and BASC will get the glory instead.

    received by email Friday morning

    Well that saved us having to reply saying ‘If you have any genuine information then you should take it to the police. We are not interested in your deal, thank you.’.

  102. Titchwell – Friday 7 February

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    A week today, Friday 7 February, Wild Justice co-founders Mark Avery and Ruth Tingay are visiting the RSPB Titchwell nature reserve to look for lots of (we hope!) Marsh Harriers and perhaps (we hope!) the occasional Hen Harrier coming in to roost.

    We planned to visit the reserve and watch from the footpath to the beach but when we contacted the RSPB they said ‘Come on one of our regular walks’ so we will.

    To be on the same walk you need to book and you need to pay the RSPB (but you get tea and cake as well as harriers). We’re talking about 3pm-5pm at the RSPB Titchwell nature reserve in north Norfolk and to register and pay, and for all details click here.

    Last weekend we visited RSPB Wallasea Island – for an account of the visit click here – we saw several Marsh Harriers, a ringtail Hen Harrier and lots of waders and ducks.

  103. Badgers and biscuits

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    On Tuesday Wild Justice had a long and detailed meeting with our legal team and a group of experts on badgers and bovine TB.

    There are many aspects of the badger-culling programme that concern us but that doesn’t necessarily mean that there is a legal case to pursue. We are still looking with great interest at this subject.

    Where, for example, is the evidence that the government’s actions have set us anyway down the road towards what is claimed to be the desired endpoint of eradication of bovine TB in cattle?

    Why has DEFRA not responded to the Godfray report? This report was commissioned in February 2018, published in November 2018 (yes, 2018!) and has not yet received a government response in January 2020. DEFRA hardly behaves like a government department these days, it behaves like a shambolic home for deranged countryside myths.

    The scale of death and suffering licensed by Natural England is quite incredible and yet they seem perfectly content with their role in this utter mess.

    Angry as we are, we’re still looking hard at the issues with the aid of some nice people and nice biscuits.

    This is the type of work for which we need a Fighting Fund – if we do not find legal grounds to take a case on behalf of Badgers then we’ll have spent thousands of pounds getting to that position. We won’t take frivolous cases but that means we need to investigate a range of options and subjects and consider them carefully. If you feel able to contribute to our Fighting Fund then please click here for details of how to donate by PayPal, bank tranfer or by popping a cheque in the post. Thank you.

  104. Letter to DEFRA on general licences

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    Yesterday Wild Justice’s lawyers sent this letter to DEFRA. Paragraphs 16, 17 and 18 sum it all up pretty well. The choice is DEFRA’s – and with the choice comes the responsibility for the consequences.

    Essentially, Wild Justice has got what we asked for almost a year ago – an admission of unlawfulness from Natural England over their general licences and a period of review and consideration. That period is now coming to an end, and if it hasn’t been successfully concluded then that is DEFRA’s fault and DEFRA’s problem. We can settle the issue in court if needs be.

    Wild Justice’s main interest is in the licence which foolishly and wrongly authorises killing of a long list of species for the purposes of nature conservation – we will not stand idly by and allow the casual killing of wildlife, falsely in the name of conservation, to continue unchallenged. How long does it take to cross off some species from a list?

  105. General licences – DEFRA heads for a new debacle.

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    Jay. Photo: Andy Rouse

    Media speculation that DEFRA is woefully unprepared to issue new, lawful, sensible general licences is probably correct.  The response of the shooting community has been to press DEFRA to extend the current unlawful (we contend), ridiculously flawed general licences and face legal challenge from Wild Justice all over again.  This is hardly the advice of a wise friend.

    Wild Justice proposes an alternative approach – issue no general licences for 2020 and make all who wish to be licensed to kill the relevant bird species apply for individual licences to do so.  Wild Justice made this suggestion to DEFRA at a stakeholder meeting last week.

    This would probably remove any chance of an immediate legal challenge by Wild Justice, a challenge that we are confident that we would win, and which we are fully prepared to take, given that DEFRA has failed to make any progress in the last year. These were also points that we made to DEFRA last week. Our main interest is over licences which allege to permit killing for conservation purposes rather than to prevent serious damage to crops of livestock.

    DEFRA has made more of a mess of this subject than did Natural England. Natural England was edging towards a solution when DEFRA intervened – we need not feel sorry for DEFRA all these months later if they have failed to find a way through these issues. Farmers and others who wish to rely on a licence to kill certain species need to reflect on how abject has been DEFRA’s lack of action.

    Wild Justice does not seek to prevent lawful lethal control of birds, it is about stopping the casual and unlawful killing of millions of birds. It’s government’s job to have a licensing system that works for users and is compliant with the legislation. General licenses are the chosen route of this and other governments to attempt to license these activities but they are not the only way to do it and DEFRA is realising rather slowly that there are inherent difficulties in framing general licences so that they meet the requirements of existing legislation.

    Let us reflect on how we got here:

    • 13 February 2019 Wild Justice issued a Pre-Action Protocol letter to Natural England challenging the legality of general licences on specific grounds
    • 23 April 2019 Natural England withdraws all general licences (despite this not being what Wild Justice had requested)
    • 25 April 2019 Natural England starts issuing individual licences covering individual species and conditions – the shooting and farming community go wild, and Michael Gove decides that he can do a better job
    • 5 May 2019 DEFRA issue a 4-day consultation on general licences
    • 14 June 2019 DEFRA issues temporary general licences which are essentially unchanged
    • 24 July 2019 Michael Gove replaced by Theresa Villiers as SoS for DEFRA
    • 29 October 2019 Wild Justice and its lawyers meet DEFRA and its legal representatives to talk through issues
    • 5 December 2019 DEFRA second consultation on general licences closes
    • Today – after nearly 12 months, DEFRA, having grabbed the issue out of NE’s hands, appears unable to come forward with a new licensing system and is being encouraged by the shooting community to stick with a discredited and unlawful licensing system.

    The budget cuts to DEFRA and NE are one reason why this is such a shambles, but DEFRA simply appears unable to think through the issues these days. 

    To summarise: if, after a year, DEFRA cannot issue good general licences then they should not issue bad general licences.

  106. Wallasea raptor watch

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    Ruth Tingay and Mark Avery from Wild Justice went raptor watching yesterday afternoon at a rather chilly Wallasea Island RSPB nature reserve in Essex.

    We see that we aren’t the only ones to have visited Wallasea recently and it’s a great place for birdwatching; there were large numbers of waders on show (mostly Oystercatcher, Golden Plover, Lapwing, Knot, Curlew, Redshank and Dunlin) with ducks, geese and swans and Grey Herons, Little Egrets and Great Egrets.

    This newly created wetland was formerly a very large wheat field but now it is a nature reserve. It’s a good place to see birds of prey and we saw lots of Kestrels hovering along the sea wall, Buzzard, a very distant Peregrine, several Marsh Harriers and a ringtail (adult female or young male (probably the former, we thought)) Hen Harrier.

    Hen Harriers breed in the uplands of the UK, very rarely in the lowlands, and the ringtail we saw yesterday, if it was a British bird and not a visitor from the continent, will have been hatched or attempted to nest itself in upland areas such as the Yorkshire Dales, North Wales, or the Highlands of Scotland. Hen Harriers are highly persecuted birds, because in summer they eat a wide variety of small birds and voles but their diet includes Red Grouse, and people will pay a lot of money to shoot Red Grouse whereas Hen Harriers don’t pay anything. So Hen Harriers are illegally killed by shooting interests on far too many grouse moors. Illegal raptor persecution is just one of the reasons why Wild Justice launched an e-petition last summer calling for a ban on driven grouse shooting. That e-petition received over 100,000 signatures and should be debated in the Westminster parliament in the coming weeks. Moorland management for grouse shooting was also criticised by the Committee on Climate Change last week – they called for a ban, starting this year, on the burning of peatland habitats for grouse shooting.

    So, the Hen Harrier we saw on a newly created coastal wetland in the south of England yesterday is a survivor of wildlife crime in the uplands and is a poster girl for more sustainable upland management. Let’s hope she enjoys being an Essex girl for a while and then chooses a safe place in the uplands to try to nest. We wish her safe travels and a safe nesting season.

    We’ll be raptor watching at other sites over the next month or so (we are waiting for news from Kent!) and we’ll update the details (click here) soon. Our next visit will be to Titchwell RSPB nature reserve where we understand we’ll be on a guided walk looking at harriers coming in to roost.

    Wild Justice is fundraising in the run-up to the first birthday of its launch – click here for details of how to donate. Thank you for all your support so far.

  107. BASC go ballistic

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    Seven week old pheasant chicks in a gamekeeper’s release pen on an English shooting estate

    Maybe it was optimistic to think that the shooting industry would be eager to see the issue of the conservation impact of the unregulated release of tens of millions of gamebirds into the countryside heading for resolution.

    We renewed our legal challenge to DEFRA on this matter this week because we have seen no move from DEFRA over the last four months. Having admitted in September the need for conservation assessment DEFRA needs to move very quickly on this matter if the 2020 gamebird releases near designated sites can be considered lawful.

    BASC issued this pugilistic statement – click here.

    Our challenge to DEFRA on their failure to implement the nature conservation legislation properly is apparently an ‘attack on shooting’. DEFRA does sometimes give the impression of being in the pockets of the shooting industry for sure, but this is a legal challenge on conservation law. That ‘C’ in BASC doesn’t stand for much, does it?

    BASC then says that our challenge is ‘vexatious’ and that Wild Justice is attempting to ‘rush’ the government into a decision on the legality of gamebird releases. In fact, Wild Justice could only be criticised for being too patient with DEFRA: our challenge started on 10 July 2019 and DEFRA took two months before conceding the correctness of our challenge. They have now taken four months without informing us or the world that anything is happening and we are getting ever closer to the July 2020 season for releasing gamebirds into our countryside. That’s not vexatious and it’s not a rush. After 6 months, the government ought to tell us what it plans to do to address and correct its admitted unlawful implementation of environmental legislation.

    BASC say that their members should not be panicked by Wild Justice’s ‘cynical’ action. Well, our action is hardly cynical in pressing government to get itself and the shooting industry into compliance with environmental legislation. It’s up to BASC to advise its members on whether to panic or not but our reminder to DEFRA that they need to act is a serious one which may have consequences for gamebird releases this coming summer. We are aware that game shooters may well now be ordering in advance millions of gamebird eggs and poults for delivery in spring and summer – it would be a good idea if they were aware of this legal action.

    The 2019/20 Pheasant shooting season ends 1 February. Wild Justice intends to help DEFRA ensure that the 2020/21 season is regulated in compliance with environmental legislation.

    And just to be perfectly clear, Wild Justice expects a response from DEFRA by 4pm Monday 3 February, failing which we reserve the right to issue judicial review proceedings without further reference to DEFRA (and certainly not to BASC).

    And because we successfully crowdfunded for action on this subject last year, and because DEFRA conceded our case, then we have most of the funds that we assembled then still at our disposal. At this stage we are not asking for further funding from the public and our supporters for this challenge (although that might change in future depending on how things go). We’re not asking you for money because you’ve already provided the funding for such a challenge – thank you again.

    However, we are always open to more donations so that we can build up a fighting fund to investigate and then take on more cases – click here for details of how to donate to our work via PayPal, bank transfer or cheques through the post.

  108. Wild Justice Fighting Fund

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    We launched our fundraising drive for the Wild Justice Fighting Fund less than a week ago but it has already been very successful. Over £10,000 has come in over that period from hundreds of donors. We are very grateful to all who have been able to spare some money to help us fight for wildlife – thank you very much!

    We will continue fundraising through to the first anniversary of our launch on 13 February and we hope, perhaps, to reach £20,000 by then (but that might be rather a stretch – we’ll see).

    A very big thank you to all who have donated so far. Here is the link which explains how donations by PayPal, bank transfer and cheques in the post can be made – click here.

  109. Gamebird releases – renewed challenge

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    Seven week old pheasant chicks in a gamekeeper’s release pen on an English shooting estate

    Today, indeed this very afternoon, our lawyers have sent the following Pre-Action Protocol letter to the Secretary of State for DEFRA, and to Natural England and Welsh ministers as interested parties.

    You will see that this is a follow-up to our earlier challenge (which was submitted in July 2019 see here and to which DEFRA responded in September 2019 see here) where DEFRA admitted that gamebird releases needed to be assessed properly and they promised to do so. We have seen no progress on this and so we are giving them a nudge. We are sure that this will be welcomed by the Pheasant-shooting and Red-legged Partridge-shooting community so that this matter is dealt with before such non-native gamebirds might be released next summer (usually from July onwards). It’s in everybody’s interest for this to be sorted out sooner rather than later.

    The most easily understood (perhaps) and highly pertinent passages for the layperson are paragraphs 11 and 12 as follows;

    11. The simple point is that, the problem having been recognised by Defra in September 2019, it would be unlawful for those releases to take place in 2020 unless the possibility of them having detrimental impacts on the sites in question had been properly considered and specifically ruled out ahead of time. And so the Secretary of State needs to initiate those processes now (in parallel with any continuing review if so wished).


    12. To hold off doing that would lead to illegality later and so be unlawful now (unless the Secretary of State were to commit to using the SN and equivalent powers ahead of the 2020 releases as a longstop).

    But here is the PAP letter in full, followed by a quote from Wild Justice’s Mark Avery.

    Mark Avery from Wild Justice said:

    We started this legal challenge last July, DEFRA took two months to respond (mid September) and now we are past mid January and only six months from the time when gamebird releasing might start again. DEFRA needs to get moving. This legal letter is designed to give them a very firm shove.

    And because we successfully crowdfunded for action on this subject last year, and because DEFRA conceded our case, then we have most of the funds that we assembled then still at our disposal. At this stage we are not asking for further funding from the public and our supporters for this challenge (although that might change in future depending on how things go). We’re not asking you for money because you’ve already provided the funding for such a challenge – thank you again.

    However, we are always open to more donations so that we can build up a fighting fund to investigate and then take on more cases – click here for details of how to donate to our work via PayPal, bank transfer or cheques through the post.

  110. Thank you!

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    We’ve been getting payments through PayPal, transfers to our bank account and cheques in the post. All are very, very welcome – thank you! We’ll give you some idea of how generous people have been tomorrow.

    The thing about cheques is that they tend to come in envelopes written by hand and with notes attached. It’s fun to read the messages, here are some examples;

    No need to send me any ‘thank yous’. It’s thanks enough to see someone speaking up for wildlife + the environment now has the financial clout to take on people who are meant to protect our countryside.

    Dear Warriors (!)

    Thanks for all you are doing. Here’s a small donation.

    Thank goodness for Wild Justice…

    As someone who has spent the last 30 years writing letters to governments, ministers and NGOs in an attempt to dissuade them from the relentless onslaught against our natural world, I thank goodness for Wild Justice.

    Just a few examples out of many – and they are all thanking us for the small part that Wild Justice is playing at standing up for threatened wildlife. But it is we who need to thank all our supporters. We can’t do anything without your support.

    But, not to put too fine a point on it, we can do more if we have more resources which is why we are asking for donations to form a Wild Justice Fighting Fund so that we can explore more cases and take more action. Here is information on how you can donate if you feel you want to support us some more – click here (and thank you!).

  111. Raptor watching this winter

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    There are lots of nature reserves around the UK where you might see birds of prey this winter, including, if you are very lucky, the endangered Hen Harrier.

    Ruth Tingay and Mark Avery from Wild Justice will be looking for raptors at the following locations on the following evenings just before and around dusk. If you are out looking for raptors too, then say hello!

    These are not Wild Justice ‘events’, they take place on land open to the public, mostly nature reserves, and entry or parking charges may apply.

    Here is where we intend to be:

    At all sites there is a very good chance of seeing Marsh Harriers, and a chance of seeing the much rarer Hen Harrier. Bird sightings can never be promised and are weather-dependent.

    The best time to look is from 90 minutes before sunset at Wallasea, Titchwell and Wicken Fen as the birds assemble at favoured sites to roost. Parkgate is dependent on high tides filling the saltmarsh and many birds of prey, herons, owls and corvids feed on the displaced rodents.

    Birdwatching in winter can be a cold pastime – wear warm and waterproof clothes. In heavy rain observations are impossible and not much fun so consult a weather forecast before travelling to check whether your journey might be fruitless. A pair of binoculars will enable you to see distant birds in much more detail.

    Wild Justice is fundraising in the run-up to the first birthday of its launch – click here for details of how to donate. Thank you for all your support so far. We’ll be providing an update on Tuesday.

  112. We are raising money

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    Wild Justice launched 11 months ago and in the month running up to our birthday we are asking you for your money, please.

    Traditionally this is the worst time of year to fundraise – but then, we aren’t traditional. Yes, we know it’s just after Christmas and those credit card bills are heading your way but we’re hoping that you will find a little money that you might be able to spare for us. Please!

    We’ll say a little more about our plans in our next newsletter which will be sent out tomorrow – if you aren’t signed up already then you can do so by clicking here and filling in your contact details.

    But if you are already convinced, then we accept donations through PayPal or bank transfer – click here or by cheques through the post to Wild Justice, 9 Lawson Street, Raunds, Northants NN9 6NG.

  113. Wild Justice and 25 others on moorland burning

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    As a member of Wildlife and Countryside Link, Wild Justice signed a recent letter to Theresa Villiers asking for an immediate end to burning of England’s upland bogs.

    Walshaw Moor Estate. Photo: Sarah Hanson

    Dear Secretary of State, 

    The 1st October marked the start of the heather and grass-burning season, and this week Parliament debated nature-based solutions to climate change for the first time in its history. In light of this we are writing to ask you to bring an immediate end to the practice of burning England’s upland bogs, including our internationally important blanket bog. This would make a significant and immediate contribution to our fight against climate change and increase the resilience of these habitats and the benefits they provide for people and wildlife. It would also be a prime example of global leadership in the run up the UK’s Presidency of a nature-based solutions themed COP26.  

    England’s upland blanket bogs are a stunningly valuable public good – they are internationally important for nature and are also vital in the fight against climate change. The UK’s peatlands store an estimated 3 billion tonnes of carbon, with England’s peatlands storing an estimated 500 Mt carbon. 

    However, this public good is being destroyed for private gain. Much of our blanket bog is now severely degraded. Historic atmospheric pollution has combined with intensive management practices including drainage, grazing and burning to devastate large areas of protected habitat. These intensive management practices are intended to make the bogs more productive for farming and grouse shooting, but the private benefits they produce are greatly exceeded by the environmental damage they entail in the destruction of public goods. 

    The scientific evidence is conclusive in showing that burning has a profound impact on the functioning of our blanket bogs, with large areas of bog now devoid of peat-forming bog mosses and vegetation, and the underlying peat soil dried out as a result. In many places, the vegetation has been entirely replaced by a monoculture of heather which further contributes to drying the peat. These habitat changes have significant detrimental impacts on bog structure, peatland invertebrates and internationally important species such as the dunlin and golden plover, which prefer to live on wet bogs.  

    Due to this poor management, whilst England’s blanket bogs should be a net carbon sink, they are instead releasing 350,000 tonnes of CO2 to the atmosphere each year, with 75% of these emissions a direct result of burning. This is the equivalent emissions of 140,000 cars per year.  

    Allowing burning to continue will substantially undermine the UK’s ability to achieve the Government’s target of net zero emissions by 2050. Rather than continuing to allow upland bogs to be burnt, we need a concerted programme to re-wet blanket bog across England to make them more resilient to future worsening climate change and the associated increase in fire risk. A recent study of European peatlands found that climate change and human impacts (including burning) are causing peatlands to change from being a carbon sink to a source of emissions. Healthy blanket bog needs water, not fire.  

    Burning also has more immediate effects on the ecosystem services provided by our moors and bogs. Healthy bogs help slow the flow of water across the bog surface, reducing the risk of flooding for communities downstream, as well as impacting water quality. By contrast, degraded blanket bogs are less able to withstand the worsening and more frequent heatwaves making them vulnerable to an increased risk of wildfires, with the resulting smoke pollution having a major negative impact on the air quality of nearby population centres. 

    We welcome your personal commitment to tackling the climate and nature crisis and that Parliament has declared a climate emergency, as well as the Queens Speech highlighting the importance of restoring natural habitats. However, if the Government is serious about showing global leadership in the run up to COP26, you should introduce an immediate and outright ban on burning on all upland blanket bogs. This would be a powerful and proportionate demonstration of practical action to show that the Government is determined to tackle climate change and improve our natural environment.  

    We would be very grateful for the opportunity to discuss this issue further and would be delighted to organise a site visit for you if that would be helpful.   

    Signed by: A Rocha, British Mountaineering Council, Butterfly Conservation, the Climate Coalition, CPRE, Council for British Archaeology, Earthwatch Institute, Friends of the Earth, Greenpeace, Green Alliance, the League Against Cruel Sports, National Trust, OF&G Organic, Plantlife, Conservation Farming Trust, People’s trust for endangered species, Real Farming Trust, Rewilding Britain, The RSPB, Wildlife and Countryside Link, Sustain, Sustainable Soils Alliance, Wild Justice, the Wildlife Trusts, WWF, ZSL.

  114. It’s our birthday!

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    Today is our birthday! On 26 October last year we registered Wild Justice as a not for profit company.  It wasn’t until 13 February that we launched our website and our first legal challenge so we’re going to count that as a birthday too, but here’s a quick run through Wild Justice’s activities so far.

    October 2018 – February 2019: set up website, register domain names, get an accountant, get a logo, open a bank account, set up a Twitter account, open a PayPal account, set up email addresses,  explore a range of legal challenges.

    13 February 2019:  we launched Wild Justice and disclosed that we had sent a Pre-Action Protocol letter to a government agency as the precursor of potential legal action.

    General Licence challenge: our challenge to Natural England over the legality of their general licences was successful. Our action has triggered a debate over the species included on the general licences across the UK and the terms under which they can be relied upon. Already Wales has changed its general licences reducing the species covered and more reviews are planned. Scotland is looking at the options for change too. In England the unlawful general licences were revoked, a small number of new licences were issued by Natural England and then DEFRA took over the process, issued some general licences which are similar to the former ones but, importantly, are now consulting on new general licences for next year. Wild Justice is involved with discussions with DEFRA over the legal and scientific basis for any new licences. We remain willing and able to take further legal challenges.

    Wild Justice has started a process of review and change which we believe will lead to major and long-lasting changes to licensing of lethal control of birds by land managers. It will probably take at least a couple of years for the full impacts of our successful challenge to be seen.

    Hen Harrier Day: Wild Justice organised the largest ever Hen Harrier Day event with over 1500 attendees and a great line-up of speakers.

    Ban driven grouse shooting e-petition: Wild Justice launched an e-petition to the UK parliament calling for a ban on driven grouse shooting. This passed 10,000 signatures within a few hours (which generated an inadequate government response) and 100,000 signatures on Day 20 (which should lead to a Westminster Hall debate in due course).  The petition currently has over 111,000 signatures and will close to new signatures when the expected general election campaign begins.

    Non-native gamebird releases: Wild Justice’s second major legal challenge has forced DEFRA to agree to review the impacts of the release of tens of millions of Pheasants and Red-legged Partridges on native wildlife. We are waiting to see the shape of this consultation.


    • Wild Justice is an active member of Wildlife and Countryside Link and has worked with other wildlife and environmental organisations on a number of campaigns.
    • We have had meetings with a range of organisations and individuals from Natural England to the National Farmers Union and from senior police officers to politicians.
    • We have investigated a wide range of issues for future legal challenges including; pesticide use, fish farming, felling of trees in the breeding season, licences to cull Beavers, licences to cull Buzzards, the Badger cull and several others. These and other subjects are still areas where we may become more publicly active in future.
    • Wild Justice has promoted the work of others through our social media actions – we know that our direct contribution can only be small but we are keen to help others too.
    • We have accepted interviews and presented talks on our work to a variety of audiences. We were banned from the British Game Fair because our views were considered to be ‘extremist’ and the organisers were concerned for our safety.
    • We have successfully crowdfunded £80,000 for our legal challenges (much of which is available for future work).

    We think we have made a pretty good start – we hope you agree.  There’s a lot more work to be done.

    Thank you to all our supporters and donors for enabling us to do what we have done so far, and thank you to a wide range of people who have helped us get established, in particular, and in alphabetical order:  Andy, Angie, Anita, Bill, Carol, Christian, Craig, David, Diane, Erica, Gerry, Henry, Lewis, Michelle, Patrick, Paul, Rosemary, Tessa, Tim, Tina, Tom, Wayne.

    Ruth, Mark and Chris

  115. Open letter to Natural England

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    Dear Tony

    Open letter to Natural England Chair, Board and staff

    It was good to meet you and Marian two weeks ago and discuss policy issues. We didn’t agree about everything (and we note the news of another missing brood-meddled Hen Harrier since then) but those are differences of opinion that are part and parcel of debate. This letter is not about those.

    We write to you about Natural England’s conduct to Wild Justice, and in particular Lord Blencathra’s remarks, as a Board member of NE, to the EFRA Select Committee on 21 May.  And quite specifically Lord Blencathra’s remark  ‘It is disingenuous for Wild Justice to say “We did not want Natural England to pull the licences immediately. We are quite happy to let them to continue to next year” ‘.

    It is possible to find a range of synonyms for ‘disingenuous’ but in any list you will find these: dishonest, deceitful, underhand, underhanded, duplicitous, double-dealing, two-faced, dissembling, insincere, false, lying, untruthful, mendacious. To use this term of a Natural England stakeholder organisation in public evidence to a Parliamentary Select Committee is a serious matter, going as it does, to their reputation and character. We cannot recollect Natural England having used such words about, say, the Moorland Association, the NFU or the RSPB and we object to you labelling us in this way, and refusing to correct this calumny.

    We have been called worse, all of us, many times, and we are not sobbing into our handkerchiefs in despair at Natural England’s rudeness, but we object to this rudeness from a Board member of a public body. We are asking for an apology from Natural England; ideally from Lord Blencathra himself, but we would be content with an apology from yourself as Chair of Natural England on the organisation’s behalf.

    It was not the least bit disingenuous for Wild Justice to state that we were happy for Natural England to let the General Licences continue to next year as this was the remedy that we sought in our Pre-Action Protocol letter which was written on the best legal advice available to us. Indeed, before sending that letter we discussed, with our legal team, whether we should ask for immediate withdrawal of the licences or not, and we chose ‘not’ on the basis that revocation of these licences would cause considerable inconvenience to a large number of people.  To have chosen this course of action, on the basis of legal advice, cannot possibly be disingenuous and we ask Natural England to withdraw this baseless accusation and apologise.

    You will have noted that NRW and SNH are revising their general licence schedules under somewhat (not entirely) similar circumstances to those in England but have at no stage abruptly revoked the licences as did Natural England.  They have, essentially, followed the process that we asked Natural England to follow.

    Just to recap, we have very little interest in Lord Blencathra’s personal views about us as Wild Justice, or as individuals, but he was not speaking as a private individual; this is a matter of how a public body behaves.

    You, Tony and Natural England, have two courses of action. Either you apologise in writing and we publish that apology on the Wild Justice blog, and that will be an end of the matter, or you do not apologise and we will take it that Natural England as a public body regards all three of us as deceitful. The latter choice by Natural England is a serious matter.

    We look forward to receiving an apology from Natural England in a speedy fashion.  Failing that, our next step will be to take this complaint to the Parliamentary and Health Service Ombudsman having exhausted the Natural England complaint procedure.

    We attach a few other factual matters as Annex 1.

    Yours sincerely

    Wild Justice

    Dr Mark Avery, Chris Packham CBE and Dr Ruth Tingay

    Annex 1

    1. Natural England evidence to EFRA Committee

    Natural England’s evidence to the committee contained many errors which we have documented and pointed out and

    2. Natural England complaint process

    We have pursued this matter through Natural England’s complaints process receiving an email from Natural England on 9 September (reference Complaint 7418).

    That response was seriously inadequate;

    • Although the sender of the email said that he had reviewed the transcript of Lord Blencathra’s remarks in fact he misquoted those remarks (and in a way that would have made them seem less seriously pointed at Wild justice).  This was careless of Natural England and suggests that the complaint was not reviewed thoroughly.
    • Natural England’s response mostly defends Natural England’s decision to revoke the licences rather than the remarks by Lord Blencathra about which we specifically complained. Our complaint was not about what Natural England did (foolish though we feel that it was) but about what Lord Blencathra said about us.
    •  Our email to Marian Spain on 20 August included this passage ‘Our main complaint about NE’s conduct is that Lord Blencathra referred to Wild Justice, in public evidence to a Parliamentary Select Committee, as disingenuous. There were other errors in NE’s evidence to that committee which we have corrected but only Natural England can correct the slur against our integrity made by your Board member. We regard this as a serious matter and you can be assured that we will publicly and robustly seek an apology. ‘. That is what we are still doing and the Natural England response of 9 September did not address the use of the word ‘disingenuous’.
    • Natural England’s response to us of 9 September stated ‘We have also shared this information with our Chair, Tony Juniper, who agrees that an apology is not appropriate in this case.’ But when we met you recently, you, Tony, did not appear to have looked at all carefully at this matter so we are drawing it quite firmly to your attention now.
    • We do not believe that the Natural England complaint process addressed our main concern and appeared to us not to have taken this matter the least bit seriously.
  116. Well done Wales!

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    Natural Resources Wales (the equivalent of Natural England, the Environment Agency and Forestry England rolled into one) has issued its new General Licences which are valid until the end of December 2019.

    They are a big step forward and Wild Justice supports the moves that have been made to make these licences fitter for purpose. The new licences are not perfect but they are certainly better. Our view is very similar to that of the RSPB as set out in this blog post.

    We are promised further review of these licences in 2020.

    The new GL004 limits lethal control to Carrion Crow, Jackdaw, Magpie and Jay and only for the purposes of protecting the eggs and chicks of a list of species of conservation importance in Wales and only (without seeking further permission) outside of designated sites. This is a considerable clamping down on the licensed casual killing of birds in Wales. It limits the species (not enough), the location and, it appears, the time of year under which the licences can be used. We write ‘appears’ because we are sure that some shooters will say that they are shooting a Carrion Crow in November in order to protect Curlew eggs in May and we will want clarification on this matter from NRW. But it’s a good start (could be even better) and we know that it has been made in the face of strong opposition from angry men with guns.

    The Annex 1 list, of species of conservation concern, is a bit ham-fisted, we would argue, given that it includes many species that never have and never will nest in Wales (so the protection of their eggs or young is rather moot). It also includes quite a few common widespread species, eg Song Thrush, which may allow those wanting to kill Magpies to do so with no earthly conservation benefit being possible since the science shows that Magpies do not have an impact on those species’ numbers.

    There is also the issue of Shrodinger’s Pheasant. The Pheasant is not a species listed on Annex 1 (quite rightly – it’s a non-native species for heaven’s sake) but you will find in popping up on GL001 which sets out the rules for protecting livestock. Pheasants are livestock when they are being captive bred or are in release pens (even, it appears, when those release pens have no roof and those Pheasants can fly in and out of them). But NRW have followed NE in claiming that Pheasants are livestock when they are ‘kept’ and that any Pheasant that has been released into the wild but nips back now and again to have a peck of grain is still livestock. And the consequence of this is that, in theory, one could kill corvids to ‘protect’ Pheasants that were released months ago but occasionally revisit release pens. Livestock have owners. Therefore this opens up the possibility of taking legal action against the owners of free-roaming Pheasants who damage your vegetables or cause road traffic accidents – perhaps. This unsatisfactory situation needs looking into and it’s on Wild Justice’s list of issues.

    We will be looking at these new licences in more detail with our lawyers.

    However, Wales now has a better set of General Licences than does England or Scotland. Well done Wales! But let’s see more progress soon, please.

  117. Chris Packham wins another award

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    Huge congratulations to Wild Justice co-director Chris Packham, who received the Outstanding Contribution Award at the Mirror Animal Hero Awards 2019 last night.

    His citation read:

    Television presenter, campaigner, author and environmentalist who has inspired the nation to celebrate and care for British wildlife.

    Read more about why Chris was honoured here and read an exclusive interview with Chris in the Mirror here

    Well done, Chris, you’ll be needing to extend that mantelpiece at this rate! We’re very proud of your achievements and it means you have to buy the first round when we next get together.

  118. Wild Justice seeks answers from Defra over Badger cull

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    We have received many requests, pleas and some communications akin to demands, that we take legal action against Defra over its outrageous, cruel and unscientific Badger cull programme and against Natural England over its licensing of these culls.

    This may be a useful juncture at which to make clear that just because we and others dislike and oppose any particular government action it does not mean that there is a strong legal case to be taken on that subject; our and your opposition to government action does not make it illegal! Others have taken legal cases on the Badger cull and we have wished them luck and hoped that they might influence events but, to date, they have made valid points which have been taken on board but have not landed a killer blow to this cull.

    Wild Justice has been following this issue with concerned interest and yesterday we sent the letter below to Defra and copied it to Natural England. The letter is not the start of formal legal action by Wild Justice against Defra on this subject but may be the precusor to such action as the letter makes clear;

    This is not a formal letter under the Pre-Action Protocol, but your responses may inform such a letter. Given that it is foreseen that culling will take place in Autumn 2019, a response within the normal 20 working days under the Environmental Information Regulations 2004 is inappropriate. We therefore request an urgent response to this letter within 10 working days, i.e. by 4pm on Friday 11 October 2019, or earlier if culling is to commence before then.

    Wild Justice will be making contact with experts on Badgers in the Badger Trust, academia and wildlife NGOs – some of them are already close contacts of ours.

    At this stage we have not launched a crowdfunder and we are not asking for financial support (although sending a letter of the sort below clearly entails both work from Wild Justice and our legal team and some expense) although if we take this matter further we will ask for your support.

  119. General licences – Scotland

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    Common Jay. Photo: Andy Rouse

    Everyone is looking at general licences following our successful legal challenge of the system, and in the knowledge that further legal challenges are possible from Wild Justice and from other interest groups. This unprecedented scrutiny is getting statutory agencies and governments to sharpen up their acts.

    In Scotland, SNH has commissioned a report from the BTO which is now published – see here.

    It’s not a bad report as far as the review of the science is concerned and it does go as far as to exonerate Rook completely from the General Licence 1 (with regard to impacts on nature conservation) as follows:

    In relation to General Licence 1, which is issued to reduce impacts on wild bird conservation, there was no evidence that rooks are an important nest predator, or that they are likely to impact otherwise on the conservation of wild birds to support its inclusion on GL1.

    For other corvid species the review says:

    Magpie: “Analyses of large-scale and extensive national monitoring data provide little evidence for national-scale impacts of magpies on avian prey populations but most studies do not assess the impact of magpies alone”

    Carrion/Hooded Crow: “There is evidence that carrion and hooded crows can reduce the local productivity and abundance of prey species where carrion or hooded crow occur at high density, particularly of waders and gamebirds.” However: “Analyses of large-scale and extensive national monitoring data provide little evidence for national-scale impacts of carrion / hooded crows on songbird populations.”

    Jackdaw: The worst that is said of this species is that “Jackdaws have the potential to out-compete red squirrels for artificial nest boxes where provided”

    Jay: “An opportunistic species, for which the eggs and young of wild birds form part of a mixed diet. Nest predation is perhaps likely to be greatest for open-nesting birds in scrub or woodland habitats”

    Given that general licences allow anyone, any time, anywhere to kill unlimited numbers of the listed species (in theory, after the person relying on the licence has tried or evaluated properly non-lethal methods first) these levels of scientific evidence are not remotely adequate to keep Magpie, Jay and Jackdaw on the general licences in Scotland or anywhere else in the UK. It is arguable whether Carrion Crow and Hooded Crow should be listed too, although we in Wild Justice will not be pressing that argument at this time.

    Although the BTO reviews of the scientific studies are adequate there is a flaw in the way they summarise the findings of different studies, of different qualities in different parts of the world which is potentially problematic and certainly should be ignored by decision makers who need to look at the detail not just the summary (in Table 6).

    The flaw in presentation and summary is as follows, let’s illustrate it with the Rook. The Rook gets top-billing exoneration in this report (perfectly correctly) because there are no studies that are rated (perfectly correctly) by BTO as being in what they call Category 2 (Clear effects in at least some situations) and no studies that are rated (perfectly correctly) as being in what they call Category 1 (Potential effects in at least some situations) and so all of the studies are actually in what they call Category 0 (No demonstrated effect). This works out well for the Rook and results in BTO saying there is no evidence for an impact and therefore no reason for the Rook to be included on General Licence 1 in future (and by extension, to have been included in the past decades). This makes sense. But the Rook was lucky, in our view, because if there had been hundreds of studies showing no impact and a single study (even if conducted in a different continent) suggesting an impact then the BTO would have popped it in Category 2 overall as they only, in the body of the report, report the highest category the studies of a species occupy.

    This is the equivalent of convicting someone in the dock if there is one shred of evidence against them but loads of evidence that point to innocence. It’s a poor way to summarise what is, by necessity a complex picture of many studies conducted in different places in different times and to different degrees of rigour, sample size etc.

    It is undoubtedly a poor way to summarise the complexity of the range of scientific studies on a subject. An alternative method (which we don’t propose, but we use to illustrate the point) would be to categorise any species that has a single study in Category 0 as a Category 0 species overall because there is evidence for no impact despite their being evidence of impact too – or giving the species the benefit of the doubt. We are not suggesting this as a method, but it is as daft as the one that the BTO actually used because it is essentially a mirror image of that method.

    Let’s look at the Jackdaw too. The Jackdaw is popped into Category 1 (Potential effects in at least some situations) because there is at least one study in that category and no studies in Category 2. In fact there are nine studies of Jackdaw which the BTO evaluate as being four in Category 0 and five in Category 1 – an equal split really. It’s not as though all the studies are in Category 1, and Category 1 studies only show a ‘potential impact in at least some circumstance‘. Even if all the studies were allocated to Category 1 Wild Justice would argue that when decision makers come to evaluate them they should drop Jackdaw out of General Licence 1 in Scotland and say that anyone wanting to kill Jackdaws for the purposes of conserving wildlife should apply for a specific licence, giving their evidence of need and with evidence of non-lethal methods that they have tried and which have failed. A pile of Category 1 studies is hardly enough to put a species on a general licence which allows widespread and unlimited killing. But the Jackdaw has an almost equal number of studies in Category 0 as it does in Category 1 and therefore there is not a case to be made for keeping it on General Licence 1. And note, that the only two studies from the UK are both in Category 0 and so there is no UK evidence that lifts the Jackdaw into Category 1 at all. It is pretty clear that the Jackdaw should not be on Scottish General Licence 1 for a moment longer and that it has been traduced for years.

    Similar arguments can be made for Jay and Magpie once you look at the individual studies and the numbers in each category and so get behind the BTO’s flawed Table 6 summary of the evidence. It would even be possible to make a decent case for excluding Carrion Crow and Hooded Crow from Scottish General Licence 1 on this assessment. SNH should certainly think hard about whether they really can issue a general licence if the impacts of Carrion Crow and Hooded Crow on wildlife are restricted to impacts on some species (such as Curlew) which live in some places and which would not benefit at all from exercise of the general licence to kill corvids in other places. SNH should look at the approach of NRW in Wales.

    The BTO analysis of the individual studies looks OK to us – it is actually quite similar to that which formed the basis for our evidence to Defra months ago – but the report is let down by a flawed method of summarising the complex mix of studies.

    When you look at the range of findings of the studies made on various species one finds that there is no justification for continuing to allow widespread unlimited killing of Rook, Jackdaw, Jay or Magpie and that even for Carrion Crow and Hooded Crow there are good reasons for limiting the circumstances and locations under which they can be killed for conservation purposes.

  120. Impacts of non-native gamebird releases need to be assessed – another success for Wild Justice

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    Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate

    Yesterday, after nearly three months of cogitation, Defra agreed that the law requires them to assess the ecological impacts of the unregulated release of tens of millions of non-native gamebirds. This is another very significant success for Wild Justice, our wonderful legal team and our equally wonderful supporters. Be in no doubt that despite this being required by law, it would not be happening without the Wild Justice challenge.

    Which law? Our challenge depended on the EU Habitats Directive (a piece of legislation drafted by former Conservative MEP, former civil servant in the environment department, and father of the current UK Prime Minister, one Stanley Johnson). This legislation was of UK origin, in that it started as an idea in Stanley Johnson’s head, but applies across all EU member states. It is an important source of protection for the environment from the eastern Polish border to the west of Ireland, and from the north of Finland to the southernmost tip of Spain, and it is what requires an assessment of the impact of gamebird releases in the UK.

    Why and how? The Directive requires the assessment of plans or projects that may affect the status of sites of high conservation importance, Special Areas of Conservation and Special Protection Areas. A plan or project might be something as obvious as a plan to build a housing estate in the middle of such a site (where it is likely to be turned down) but also includes a plan to build a housing estate abutting such a site or close enough to such a site that it might be affected. Our challenge said that releases of non-native gamebirds needed to be assessed in a similar way for their impacts and Defra has had to agree. We suspect, on the basis of the government’s conservation record over nearly a decade, that they were reluctant to concede this point but after long thought they have conceded it. It’s a good decision and an important one.

    What happens now? Nothing for a while! But Defra have said that they will consult on the issues and the legislative framework. Wild Justice will be keen to play a part in this consultation and we will encourage our supporters to do so too. The issues that are raised for the conservation status of SACs and SPAs will apply more widely than just those sites and so this should open the door to more scrutiny of the impacts of vast releases of gamebirds on the ecology of the countryside as a whole, and the consultation that applies to England will have implications for practice in Wales, Northern Ireland and Scotland too – we’re all in the EU and all covered by the Directives at the moment.

    Wild Justice said ‘We’re delighted to have prompted a government change of policy that will open the door to a review of the ecological impacts of non-native gamebirds on our native flora and fauna. The currently unregulated release of gamebirds for shooting has, the science shows, large potential impacts on the ecological health of our countryside. It is time that these releases are properly assessed and come under proper regulation. We will scrutinise the plans that Defra brings forward in order to assess their ecological value and their compliance with the Directives. If Defra’s plans do not comply fully with the Directive then we stand able to take further legal action, and we will not shrink from doing so if that is necessary. We are grateful to our wonderful legal team at Leigh Day and Matrix Chambers and to our supporters who funded our challenge.‘.

  121. General licences in Wales

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    Common Jay Garrulus glandarius. Photo: Andy Rouse

    Natural Resources Wales (NRW) ordered a review of licencing arrangements following a legal challenge in England by campaign group Wild Justice, headed by TV naturalist Chris Packham and fellow conservationists Mark Avery and Ruth Tingay.

    Seven rural groups with little knowledge of nature conservation are ‘up in arms’ over unpublished proposals by Natural Resouces Wales (NRW, the rough equivalent of Natural England in Wales). The groups (Game and Wildlife Conservation Trust, Countryside Alliance, National Gamekeepers Organisation, Farmers Union of Wales, Countryside Land and Business Association, British Association for Shooting and Conservation and National Farmers Union Cymru) have ‘jumped the gun’ (according to NRW, rather wittily) in criticising the proposals which are as yet unpublished. No criticism has come from actual nature conservation organisations.

    Wild Justice understands that the proposals will see a removal of several species from the general licence lists that will apply in Wales, following a scientific review of the evidence, and a tightening up of the circumstances under which the provisions of the general licence can be relied upon.

    We understand that rather than the current approach to issuing licences for the purpose of nature conservation, which has applied across the UK, and which could be grossly oversimplified as ‘any corvid, anywhere, any time’, NRW is moving towards ‘some corvids (but only those where there is evidence of impact) and only to protect particular species of conservation concern’. This was one of the outcomes that Wild Justice sought by taking its legal action – a reexamination of the relevant science and a more focussed approach which would allow necessary lethal control as a last resort but would cut down on the casual killing of birds out of sheer prejudice.

    Wild Justice said:

    NRW is moving in exactly the right direction in its thinking. We welcome these moves and look forward to seeing them published and commenting on them in detail. We hope that NRW will not be bullied into watering down their proposals by landowning organisations whose interests are in game management and not nature conservation. Wales is leading the way it seems.

    Wild Justice also said:

    Defra promised a consultation on this matter this summer and we have yet to see anything from them. The nights are drawing in, the blackberries are ripening in the hedgerows, migrant birds are heading towards their African wintering grounds, and the leaves are beginning to turn on trees, and unless Defra pulls their finger out they will be overtaken by a period of purdah ahead of a general election. Wild Justice remains ready and willing to take legal action against Defra if it issues flawed general licences to apply in England next year. We suggest that Defra looks hard at the approach taken in Wales.

  122. Gamebirds legal challenge

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    We sent the following letter to the Defra legal team yesterday. As you can see, they are either in some disarray or are simply mucking us about. Either way, they’d better get on with things…

    Dear Mr ***********,
    Thank you for your email, received at 17.32pm on 29 August. Our client finds your position perplexing and wholly unsatisfactory.
    Our client’s Pre-Action Protocol letter was sent on 10th July and generously offered an extended period of 21 days for reply. You replied on 30th July (the day before your response was due) and requested a further 4 weeks (until 28th August). At the end of that seven week period you asked for a further day and at the end of that day you requested a further extension until 11th September. This will represent a period of some nine weeks simply to respond to our PAP letter.  
    In the event that we do not receive your substantive response to our PAP letter, or a satisfactory explanation for the reasons for this extended delay (and acceptable reasons would not, in our view, include the usual holiday period and/or simply being busy) by 11th September, our client reserves the right to issue proceedings without further notice to you.
    Yours sincerely,

    (Leigh Day)

  123. 100,000 signatures in 20 days – thank you!

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    We are thrilled by the support that our e-petition has received – thank you to all our supporters.

    This matter should receive a response from Defra in due course and should be debated in a Westminster Hall debate in the Westminster Parliament eventually. But rather more importantly, the number of signatures, and the speed with which they were amassed (at 5,000 signtures a day), will be noted by politicians in parliaments across the UK.

    Although we understand that our e-petition will be closed when parliament is suspended – probably in a week’s time – it is still open for signing until then.

    Please sign our petition calling for a ban of driven grouse shooting.

  124. #HHDay2019 (4)

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    Fraser reads his poem. Photo: Guy Shorrock/RSPB

    To somewhat use the words of one of my favourite Bob Dylan songs, at Hen Harrier Day at Carsington the only persons on the scene, missing, were the 600 gamekeepers. Eh?

    In setting up Hen Harrier Day there were lots of things to worry about, or at least to consider. Things like power supplies, promoting the event with an ever-changing list of speakers, whether Chris Packham’s travel plans would get him to the event and as we neared the actual day, the weather. It’s all part and parcel of a pop-up event at a new venue run by amateurs!

    But when your event is a celebration of Hen Harriers, a species which everyone claims universally to love, one has to put up with nastiness from members of the game shooting industry too. We are used to this (see here and here for recent examples), it is part of being environmental campaigners who touch the issues that affect game shooting.

    And so as soon as we announced the venue and the date we found social media comments about coach loads of gamekeepers arriving to disrupt our event from across the country. Various shooters, possibly in their cups, promised direct action against the event. Severn Trent Water, who were fantastic, and who run Carsington Water, had phone calls objecting to the mere existence of an event which praises the Hen Harrier (that illegally persecuted bird that everyone loves!). And the rumour was circulated that 600 gamekeepers would arrive with megaphones and chants.

    They would have been very welcome and it would have been interesting to see them storming the stage, and filming them, as 9 year old Fraser was reading out his poem or when Superintendent Nick Lyall was, in uniform, spelling out that raptor persecution is a crime, or when the Derbyshire Police and Crime Commissioner was saying that in his county, and in his mind, fighting wildlife crime is a police priority.

    But the messages, some of which certainly came from current and former gamekeepers, amount to another example of nastiness and attempted intimidation. We consulted the police and, of course had many police officers on site since Hen Harrier Day is largely about upholding the law, and were advised to take certain precautions but that the threats were not credible. A bit like what much of the grouse shooting industry says.

    And so the only people on the scene, missing, were the 600 gamekeepers. But we did have the pleasure of Amanda Anderson from the Moorland Association keeping an eye on us, and she was very welcome.

    And by the way, our e-petition calling for a ban on driven grouse shooting passed 70,000 signatures last night after just over a week – only 29,900 to go!

    Please sign this e-petition to ban driven grouse shooting – click here.

  125. Government urged to drop post-Brexit prohibition on environmental disclosure

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    Wild Justice is playing its small part in working on general environmental issues with the wider conservation community. We were very happy to be a signatory of the letter reproduced below.

    We notice that Wild Justice’s name sits alongside many prestigious organisations from a variety of perspectives but that some organisations which we might have expected to be present (most notably the Wildlife Trusts and National Trust) are absent. Interesting.

    The Rt Hon Theresa Villiers

    Secretary of State for Environment, Food & Rural Affairs

    Seacole Building

    2 Marsham Street

    London SW1P 4DF

    8 August 2019

    Dear Secretary of State,

    We are writing to express our concern at the proposed prohibition on disclosure of information in the draft Environmental (Principles and Governance) Bill, published in December 2018.[1]

    The draft Bill is partly intended to replicate the scrutiny functions of the European Commission and European Environment Agency after Brexit. However, some of the new arrangements would be subject to more severe restrictions on the public’s right to information than currently apply under both UK and EU law. [2]

    The bill would establish the Office of Environmental Protection (OEP) whose functions would include investigating complaints of serious failure by public authorities to comply with environmental law.[3]

    The OEP would normally have to make public the fact that it is investigating a public authority or has concluded that it has failed to comply with environmental law.[4] However, the disclosure of large classes of related information would be restricted:

    •             The OEP would be prohibited from disclosing information obtained from a public authority under investigation unless the authority consented[5]

    •             The public authority being investigated would be prohibited from disclosing correspondence or formal notices from the OEP unless the OEP consented[6]

    •             The OEP would be required to copy its correspondence with a public authority to the relevant minister but could not disclose the minister’s reply without the minister’s consent.[7]

    Although the OEP would be free to publish such information if it wanted to,[8] it could not be required to release it. The restrictions would continue after an investigation was over and any enforcement action concluded. The approach is wholly at odds with the public’s right to information under the Environmental Information Regulations (EIR).

    If the purpose is to protect the OEP’s ability to carry out investigations, the prohibition is not necessary. Regulation 12(5)(b) of the EIR provides that ‘a public authority may refuse to disclose information to the extent that its disclosure would adversely affect…the course of justice, the ability of a person to receive a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature’. 

    This exception is not absolute.  The EIR require that: (a) disclosure must be shown to have an ‘adverse effect’ on the authority’s ability to conduct an enquiry (b) the exception must be interpreted in a ‘restrictive way’,[9] (c) a ‘presumption in favour of disclosure must be applied’[10] and (d) the public interest in maintaining the exception must outweigh ‘the public interest in disclosing the information’.[11]

    None of these important conditions would apply under the draft Bill. If the OEP, public authority or minister (as the case may be) did not wish the information to be released, it would be withheld. There would be no need to show that disclosure would be harmful. The public interest in the information would be irrelevant.  This would reverse decades of progress in opening up environmental information. 

    It provision would impose a degree of secrecy which does not apply to any other UK environmental regulator. The restriction would be even more onerous than that under Europe’s access regime. The right of access to European Commission documents excepts information about investigations unless there is an overriding public interest in disclosure.[12]  Moreover, the point of the restriction is to ensure that member states comply with their European treaty obligations, a consideration which will not apply to the UK after Brexit.

    The prohibition raises a wider concern. Regulation 5(6) of the EIR provides that the right of access to environmental information cannot be restricted by any other law. [13] If this remained in place the proposed prohibition could have no effect. The government must therefore intend to amend or repeal regulation 5(6). This would not just affect the OEP. It would mean that any legal restriction on disclosure would override the EIR right of access, regardless of which public authority held the information.  This would be a fundamental limitation the EIR.

    Clause 28 of the bill envisages a damaging and unjustified restriction on the public’s right to environmental information. We call on the government to omit it from the proposals.

    Signed by:

    Amnesty International UK Section

    ARTICLE 19

    Bat Conservation Trust



    Bumblebee Conservation Trust

    Butterfly Conservation

    Campaign for Freedom of Information

    Campaign for National Parks

    Campaign for the Protection of Rural Wales

    Campaign to Protect Rural England

    Clean Air in London


    Compassion in World Farming

    Friends of the Earth

    Global Justice Now

    Global Witness

    Good Law Project


    Guy Linley-Adams Solicitor

    Law Centres Network

    My Society

    National Union of Journalists

    News Media Association

    No 3rd Runway Coalition

    Open Rights Group

    Renewable Energy Foundation

    Royal Society for the Protection of Birds

    Salmon and Trout Conservation

    UK Sustain

    The Brexit Civil Society Alliance

    The Ecologist

    The Ramblers

    Transparency International UK

    Trees for Cities

    Unlock Democracy

    Whale and Dolphin Conservation

    Wild Justice



    [2] See:

    [3] Draft Environment (Principles and Governance) Bill (hereafter ‘Draft Bill), clause 19(1)

    [4] Draft Bill, clause 29(1)

    [5] Draft Bill, clauses 28(1) and 28(2)(a)

    [6] Draft Bill, clauses 28(3) and 28(4)(a)

    [7] Draft Bill, clauses 24(1),  28(1)(b) and 28(2)(a)

    [8] Draft Bill, clause 19(6)

    [9] This requirement is found Article 4(2) of the Aarhus Convention on Access To Information, Public Participation In Decision-Making And Access To Justice In Environmental Matters, which will continue to apply to the UK after Brexit,

    [10] EIR Regulation 12(2)

    [11] EIR Regulation 12(1)(b)

    [12]  A public right of access to documents held by the European Commission, Council and Parliament exists under EC Regulation 1049/2001. One of the exceptions is found in the third indent of Article 4(2) which states: ‘The institutions shall refuse access to a document where disclosure would undermine the protection of…the purpose of inspections, investigations and audits.  Although the General Court of the Court of Justice of the European Union has held that in relation to this exception a general presumption of confidentiality applies, the provision nevertheless allows access where ‘there is an overriding public interest in disclosure’. The Court of First Instance has held that for this exception to apply it must be ‘reasonably foreseeable’ ­­that the protected interest would be undermined.  Moreover, the protected interest ‘is not to protect the investigations as such, but…to induce the Member State concerned to comply with Community law’. Case T-36/04, Association de la presse international ASBL (API) v Commission of the European Communities.

    [13] Regulation 5(6) states ‘Any enactment or rule of law that would prevent the disclosure of information in accordance with these Regulations shall not apply’

  126. Bird Fair bits

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    Bird Fair Saturday lunchtime. Photo: Guy Shorrock/RSPB

    Wild Justice was quite busy at the Bird Fair over the Friday-Sunday.

    Friday morning started at 09:30 with a talk from Ruth Tingay. This is not a much sought-after slot on the Bird Fair programme – first talk on the first day?! But it was standing room only – people were turned away.

    Then on Saturday lunchtime, on the main events stage in front of 600+ people, the whole Wild Justice team was interviewed for 30 minutes by Charlie Jacoby of the Fieldsportschannel. Remember that Chris Packham and Mark Avery were banned from the Game Fair at the last minute after having been invited to face questions from Charlie Jacoby. The Bird Fair was kind enough to give Charlie and Wild Justice the chance to meet and ask and answer questions in front of a much bigger audience and you can watch the recording here;

    We’d say that it was more knock-about fun than piercing interrogation but all credit to Charlie for turning up and all shame to the Game Fair for not letting two such interviews go ahead as they had planned.

    After Charlie left the stage Chris was joined by three of the young people whose writing about Hen Harriers had been featured at Hen Harrier Day, six days earlier;

    First was Jack:

    Photo: Guy Shorrock/RSPB

    Then came Fraser;

    And then came Meri;

    Their essays and poems, and those of other young people are in a booklet which is available from the Derbyshire Wildlife Trust – it’s a very good, and very moving, read.

    And on Sunday morning Mark Avery gave a talk similar to Ruth’s to another packed marquee.

    It was a very busy Bird Fair for all of us, incredibly busy (as always) for Chris, but we’d like to thank all the attendees, all the organisers and volunteers, and all the people who came and shook our hands or heard our talks, for their help and support, and for making it a really special Bird Fair.

    Oh yes, and we were promoting the e-petition all the time and that now stands at an amazing 66,900 signatures.

    Please sign the Wild Justice e-petition to ban driven grouse shooting – click here.

  127. If you are at the Bird Fair today

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    If you are at the Bird Fair today then please take a postcard away with you.

    This postcard:

    It’s obviously, on one side, a gorgeous eagle (without a trap attached to its foot).

    On the other side it has the information about how to find your way to the e-petition to ban driven grouse shooting.

    You can get a copy of this postcard by coming to the Events main stage for Chris Packham’s midday session where Wild Justice directors Mark Avery, Ruth Tingay and Chris will be answering questions from Charlie Jacoby of the fieldsportstv channel (because Chris and Mark were banned from answering questions at the Game Fair), three young people will be reading their poetry and prose about Hen Harriers and more. On leaving that event please take a postcard which you can use to publicise this e-petition calling for a ban on driven grouse shooting.

    More postcards will be available to the general public later next week. Today (and if stocks last, tomorrow) please just take one card.

  128. Please support Wild Justice’s petition to ban driven grouse shooting.

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    The three directors of Wild Justice have a 5-year track record of calling for a ban of intensive Red Grouse shooting. Yesterday, late afternoon, this latest UK-wide e-petition calling for a ban on driven grouse shooting appeared, and by bed time it had already passed the 10,000 signatures which will trigger a response from the Westminster government (they’ll say ‘no’).

    But the first 10,000 signatures are the easiest 10,000 – although these came very, very quickly. We need to get to 100,000 signatures in order to trigger a debate in the Westminster parliament – open to backbench MPs from all parts of the UK – and that is a mountain to climb.

    It’s a mountain to climb and we’ll have to run up the slope as time is short. Such petitions run for 6 months (and, completely by chance, this one closes on the first birthday of Wild Justice’s launch (is that a sign of some sort?)) but they can be curtailed by the announcement of a general election. That is very likely long before the end of the 6-month period. So time is short, maybe very short.

    We’ll be blogging about why we’d like you to give this e-petition your support over the hours and days and weeks ahead, but, for now, please support this e-petition calling for a ban of driven grouse shooting if you trust Wild Justice to have thought about it, weighed up the pros and cons, and so, basically, if you trust us.


  129. #HHDay2019 (3)

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    What wonderful speakers there were at Hen Harrier Day! We don’t have images of them all, but here are some. If you have images of any of the missing ones (!) we’d love to be able to use them and credit them to you.

    Iolo Williams opens Hen Harrier Day 2019. Photo: Guy Shorrock/RSPB.

    Thanks Iolo for coming over from Wales – and we know you’ve got a very busy life (and car problems to cope with). You are a star and we really appreciated you being with us all.

    Hardyal Dhindsa, the Derbyshire Police and Crime Commissioner. Photo: Guy Shorrock/RSPB

    Hardyal Dhindsa – the Police and Crime Commissioner for Derbyshire – the only man in a suit and tie and another person with a busy life. Thank you Hardyal for coming, and thank you for making wildlife crime a priority for the police in Derbyshire. And it is worth saying that it was great to have the Derbyshire Police Rural Crime Unit with us, talking to the public, all through the event.

    Gill Lewis – with wings! Photo: Guy Shorrock/RSPB

    Gill travelled a long way to be at Hen Harrier Day 2019 – her first HHDay! Gill’s books Sky Dancer and Eagle Warrior are doing a lot to spread the word about raptor persecution to younger people. She’s a great supporter.

    Tim Birch of Derbyshire Wildlife Trust. Photo: Guy Shorrock/RSPB.

    Tim is a great campaigner and conservationist. He’s only missed one Hen Harrier Day and that was because he was recovering from heart surgery – which is a pretty convincing reason. Great, as always, to have Tim’s passion on stage (and we’ve already thanked the Derbyshire Wildlife Trust for their support in many ways).

    Ruth Tingay of Wild Justice. Photo: Guy Shorrock/RSPB.

    Ruth opened the second session of talks and, after making sure that her mum could have a selfie with Chris Packham, she talked about the wilful blindness of politicians in Westminster and Holyrood over the subject of wildlife crime. Politicians – the #slightlysoggy1500+ expect you to do more.

    Dan Rouse. Photo: Guy Shorrock/RSPB

    Dan Rouse from Wales was a new face to many attendees – a Welsh language TV presenter and conservationist, it was great to have both her and Iolo’s accents and knowledge on stage.

    Cathleen Thomas. Photo: Guy Shorrock/RSPB

    Cathleen Thomas from the RSPB Hen Harrier Life project has been immersed in this subject for several years. She spoke with great authority as well as passion about her work with Hen Harriers and how they must have a better future in our uplands.

    Ian Thomson. Photo: Guy Shorrock/RSPB

    Ian Thomson brought a Scottish accent and decades of experience from investigating wildlife crime in Scotland to the stage. He was the token man in this session but he did OK! Thanks Ian – you are a star!

    Superintendent Nick Lyall. Photo: Guy Shorrock/RSPB.

    Superintendent Nick Lyall is the chair of the Raptor Persecution Priority Delivery Group and is a breath of fresh air to the scene. His presence, and his words, showed that the future of the uplands and the part that wildlife crime plays in their present, are not just subjects for raptor enthusiasts, or even for environmentalists, but for senior and serious police officers. Killing Hen Harriers or other protected wildlife is a crime – it’s a crime that is common – it must end, and if the shooting industry can’t end it themselves then it is a job for law enforcement agencies. Nick showed that he was very determined to end wildlife crime.

    Tessa Gregory, lawyer from Leigh Day. Photo: Guy Shorrock/RSPB.

    Tessa Gregory‘s name would not have been familiar to many in the 1500+ crowd of attendees and so they weren’t prepared for such a brilliant speech. Wild Justice has worked with Tessa since before we were Wild Justice so we know what a star she is – and now a lot more people do. She talked very clearly about how how difficult the approach which Wild Justice is taking in legal cases really is – we can’t expect to win that many of them because we are shining a light on the murky areas of law in order to clarify and change what is happening. And Tessa made it quite clear why Mark Avery had had legal advice that brood-meddling of Hen Harriers was unlawful and why the team still believes that, and is seeking to appeal that case. And the presence of Tessa, Hardyal and Nick made it abundantly clear that what the Hen Harrier is facing is a crime wave on the grouse moors. The absence of Hen Harriers from much of our uplands isn’t an accident – it is due to serious, organised crime and the killing must stop!

    Dominic Dyer. Photo: Guy Shorrock/RSPB.

    We had been promised thunder and lightning on the day but they arrived in the form of Dominic Dyer whose voice reverberated across the grass. I noticed a couple of people step back from the speakers! Lots of passion about Hen Harriers, a bit about badgers and a lot about the need for change. Thanks Dom!

    Natalie Bennett, Green Party. Photo: Guy Shorrock/RSPB.

    Natalie Bennett has become a regular speaker at Hen Harrier Day events and it’s not that easy to find a politician that cares – but we’d be hard-pressed to find one better than Natalie anyway. Although, it is worth recording that the Westminster Hen Harrier Champion, Angela Smith MP, from nearby Penistone and Stocksbridge had been hoping to attend but was, in the end, unable – but we know that she would have said ‘The killing has to stop’ because she always does and it really, really should stop. But Natalie speaks to the issues that concern most HHDay attendees as well as the issue of wildlife crime – carbon emissions, flood risk, water quality – the wider unsustainability of grouse moor management. We need more politicians like Natalie and perhaps we are seeing more emerge.

    Chris Packham. Photo: Guy Shorrock/RSPB.

    Chris Packham arrived back in the country on Sunday morning without much sleep, with a bad back and feeling ill – but no-one can do it better than he. He produced a great finale to the event and sent people home with hope in their hearts and determination in their heads.

    We’ll be posting links to moving images on this blog later this week. If you want to use any images from this blog post (all by Guy Shorrock/RSPB) then please email us and we will put you in touch with Guy about any fees and details of crediting them.

    But here are a few more images for now. We’ll be posting a few more blogs on #HHDay2019 today and tomorrow.

    Photo: Guy Shorrock/RSPB.
    Photo: Guy Shorrock/RSPB.
    Photo: Guy Shorrock/RSPB.
    Mark Avery trying to make it look as though the day was going to plan all the time! Photo: Guy Shorrock/RSPB.

  130. #HHDay2019 (2)

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    The Derbyshire Wildlife Trust were wonderful partners at yesterday’s Hen Harrier Day event at Carsington Water. Not only was Tim Birch an inspiring speaker, and not only did Derbyshire Wildlife Trust members turn out in large numbers, but they also produced a fantastic book of writing about Hen Harriers (pictured above being waved around by Chris Packham).

    Diane Gould getting a deserved round of applause at Hen Harrier Day. Photo: Guy Shorrock/RSPB

    Diane Gould brought this collection together and four of the children who contributed read out their marvellous words on stage.

    It looks like a small thing, but the 12 pages are packed with moving and beautiful words about Hen Harriers.

    Photo: Guy Shorrock/RSPB

    Thank you to the Derbyshire Wildlife Trust and thank you to:

    Maxwell and Zahra (aged 7)

    Fraser, Holly and Rosie (aged 9)

    Sarah, Hamish, Hattie, Poppy, Kaya, Lucy and Charlotte (aged 10)

    Emily (aged 11)

    Lucy, Jack and Kitty (aged 12)

    Meri (aged 13)

    We may well feature some of their work on this blog in future.

  131. #HHDay2019 (1)

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    Yesterday’s Hen Harrier Day event was a great success. Here are just a few images of the day (all by Guy Shorrock).

    A small part of the 1500+ crowd. Photo: Guy Shorrock
    A part of the same crowd later in the day. Photo: Guy Shorrock
    The three Wild Justice directors. Photo: Guy Shorrock

    Hen Harrier Day 2019 was a very special event – it was the first one organised by Wild Justice and the biggest ever. And it was a pile of fun.

    More blogs on this during the day but first, some thanks:

    • HUGE THANKS to Severn Trent Water for letting us, and helping us, have this event on their site. Severn Trent were brilliant to work with and very helpful throughout. And they also shrugged off some nastiness from anonymous phone callers who self-identified as being from the shooting community (more on this later).
    • MASSIVE THANKS to all the speakers who gave up their time, expertise and passion freely (more on this later).
    • 1500++ thanks to attendeees – for many of whom this was their first Hen Harrier Day attendance. There could easily have been 3000+ attendees over the whole day as, obviously, people were coming and going all the time. It was a fine turnout on a day when the weather forecast was not wholly for fine weather and so…
    • …thank you to the heavens for not opening up on us and the few showers that happened early on in the day were balanced out by the fine weather and sunshine later.

    More thanks, and more news later today.

  132. Hen Harrier Day event – Sunday 11 August

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    The weather forecast is good for Sunday – light showers and a breeze!

    12 midday – 5pm, 11th August
    Carsington Water Visitor Centre
    Ashbourne, Derbyshire

    Click here to find it on Google maps

    Join Wild Justice (Chris Packham, Ruth Tingay and Mark Avery) on the UK’s 6th Hen Harrier Day. Learn more about our Hen Harriers, discover the TRUTH behind their disappearance in the UK and find out what you can do to help.

    Hen Harrier Day was established in 2014 and events have been held at locations from Northern Ireland to inside the M25 and from the south coast of England to the highlands of Scotland. It is now a recognised part of the ornithological and conservation scene and continues to raise awareness of the persistent illegal persecution by the grouse shooting industry of this beautiful, important and iconic bird.

    On Stage

    The speakers will be grouped in three blocks spread through the afternoon (programme subject to change):

    Early speakers: Iolo Williams Conservationist and broadcaster), Hardyal Dhindsa (Derbyshire Police and Crime Commissioner), Gill Lewis (author), Tim Birch (Derbyshire Wildlife Trust).

    Mid-afternoon speakers: Ruth Tingay (Wild Justice and Raptor Persecution UK), Cathleen Thomas (RSPB Hen Harrier Life project), Dan Rouse (conservationist, Wales), Ian Thomson (RSPB Investigations, Scotland)

    Late afternoon speakers: Nick Lyall (Police Superintendent, chair Raptor Persecution Priority Delivery Group), Tessa Gregory (lawyer, Leigh Day), Dom Dyer (conservationist), Natalie Bennett (Green Party), Chris Packham CBE (Wild Justice, broadcaster etc).

    Derbyshire Police Rural Crime Team will have a stand and be delighted to talk to you about wildlife crime issues. Other standholders: RSPB, West Midlands Bird Club, League Against Cruel Sports, Extinction Rebellion and others.

    Derbyshire Wildlife Trust have produced an amazing small book of children’s writing on Hen Harriers – on sale on the day.

    This is an outdoor event adjacent to the Carsington Water Visitor Centre which has a cafe, toilets, shops. Large pay and display car park. Unfortunately, no buses run to the site on a Sunday. If you would like a lift or can offer one please add your details here. Phone reception is poor and live-streaming has proved too expensive to contemplate. We will be filming the event and edited highlights will be available next week.

    Chris Packham, Gill Lewis and Mark Avery will be signing books in the RSPB shop after the event (530pm).

    All welcome. We thank Severn Trent for their support and enthusiasm in letting, and helping, us stage this event. Derbyshire Wildlife Trust and RSPB each have a daily presence at this site and have been enthusiastic supporters of Hen Harrier Day 2019.

    Hen Harriers

    Their stunning beauty and the ugly truth.

    The Hen Harrier is also called the ‘Skydancer’ because of its acrobatic displays in the breeding season.

    RSPB video

    Illegal persecution on driven grouse moors has long been recognised as the main factor preventing recovery of the Hen Harrier population.

    Male Hen Harrier found on a Scottish grouse moor caught in an illegally set spring trap this year. Despite efforts by a local vet this bird had to be euthanised. Photo: Ruth Tingay

    A gamekeeper who was caught on camera shooting a Hen Harrier on a grouse moor in Scotland escaped prosecution because this video footage was deemed inadmissible.

    Despite overwhelming evidence to the contrary, representatives from the grouse shooting industry claim that the illegal killing of Hen Harriers is an “historical controversy”.

    by Paul Thomas

    Scientists calculate there is habitat to support c2600 pairs of Hen Harriers in the UK – in the last national survey (2016) there were only 545 territorial pairs.

    Photo: Gordon Yates

    The latest scientific research says there should be c500 pairs of Hen Harriers nesting on grouse moors in the UK – in recent years there have been fewer than 20 pairs.

    There should be 300+ pairs of Hen Harriers nesting in England – last year there were only 14 nests. Ludicrously, this was hailed as being ‘successful’ because there were more nests last year than in the previous decade.

    Hen Harrier. Photo: Gordon Yates.

    Losing over a quarter of the Hen Harrier population in just 12 years is a matter of serious conservation concern in Scotland.

    Hen Harrier Annie was shot in an area of grouse moors in Scotlandin 2015 – her body was only found because she was satellite tagged.

    A recent Government-commissioned study has shown that 72% of satellite-tagged Hen Harriers are likely to have been illegally killed on or next to grouse moors.

    Hen Harriers are ten times more likely to die or disappear in suspicious circumstances on or near to a grouse moor than in any other habitat.

    Heather is regularly burned on grouse moors across the UK – burning damages blanket bog habitats, increases carbon emissions, reduces water quality and increases flood risk (as well as all that persecution of Hen Harriers)

    The Hen Harrier is one of the most persecuted birds of prey in the UK. It is relentlessly shot & trapped on many grouse moors because it eats Red Grouse as well as Meadow Pipits, voles and many other species.

    But it’s not only Hen Harriers – here is RSPB video footage of a male Peregrine Falcon being caught in an illegally set trap, at a nest, on a grouse moor, in Bowland in Lancashire in 2016. The caught case collapsed because this evidence was deemed inadmissable. As well as footage of a trap being set thee is sound and video evidence of the female leaving the nest followed by the sound of shots.

    Hen Harriers are not even safe inside some of our National Parks. Grouse moors in the Yorkshire Dales, the Peak District & the North York Moors National Parks are notoriously dangerous for Hen Harriers.

    The Hen Harrier is the logo of the Forest of Bowland AONB. This year 5 pairs of Hen Harrier nested successfully in one small part of the AONB managed by United Utilities plc – none is thought to have nested succcessfully on the large areas of grouse moor in the AONB since 2003. Bowland is another wildlife crime hotspot.

    The Nidderdale Area of Outstanding Natural Beauty (AONB) is another notoriously dangerous place for Hen Harriers, and for other birds of prey such as Red Kites. They are poisoned, trapped and shot on grouse moors in this so-called protected area.

    Map of Nidderdale AONB (yellow outline) with confirmed illegally killed Red Kites (red dots), disappeared Hen Harriers (orange stars), where Bowland Betty was recovered (red star) and an approximate location of River’s last resting place (red triangle, which we now know should be much closer to the red star denoting Bowland Betty)

    A gamekeeper who was caught on camera setting illegal traps on a grouse moor escaped prosecution and just received a police caution instead. The police later admitted they’d made a mistake & should have charged him. Chris Packham talks in 2016 about illegal pole traps set on a Yorkshire grouse moor.

    The main prey of Hen Harriers are small birds and mammals such as Field Voles and Meadow Pipits, but they also eat Red Grouse which is why they are illegally persecuted by the grouse shooting industry.

    c600,000 Red Grouse are shot each year in the UK for ‘sport’. It will cost paying ‘guns’ an average of £75/bird to shoot Red Grouse. The record ‘bag’ for a day’s grouse shooting was set a long time ago – 2929 dead birds on the Abbeystead Estate in Lancashire on 12 August 1915. Photo: Tim Melling

    Female Hen Harriers incubate the eggs and chicks – the males bring food which they pass to the female in mid-air close to the nest.

    Hen Harrier food pass (male (above) pases food to the female in mid air. Photo: Gordon Yates

    Some Hen Harriers travel to France and Spain in winter before returning to the hills of the UK to nest.

    Hen Harrier, Photo: Geoff Harries.

    In winter some Hen Harriers remain in the hills but many are found in coastal habitats far from the moorlands where they were hatched.

    The normal Hen Harrier clutch size is 4 or 5 eggs which are incubated for 34 days. They nest on the ground in moorland areas.

    Hen Harrier chicks. Photo: Mark Hamblin

    Hen Harriers are one of three harrier species which nest in the UK – the other species are Marsh Harrier and Montagu’s Harrier.

    Hen Harriers normally first breed at two years of age.

    Hen Harrier female and chicks at the nest. Photo: Peter Cairns

    A satellite-tagged Hen Harrier hatched in Lancashire travelled to the north of Scotland and roamed widely in northern England before being shot in a grouse shooting area of Yorkshire.

    Those who illegally kill Hen Harriers on grouse moors are getting away with their crimes because the Westminster & Scottish Governments have consistently failed to address the problem, largely due to vested interests.

    Listen to A Distant Call by The Artisans – downloadable on Monday.

    Read Mark Avery’s book, Inglorious, on why we should ban driven grouse shooting.

  133. Getting very close to fully funded

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    Our crowdfunder is £4000 short of being fully funded – that’s amazing. Thank you to all who have contributed.

    This will allow us to take our legal action all the way through the courts and use the legal system to make Defra review the impacts of unregulated gamebird releases on our wildlife.

    Thank you again.

  134. Defra cannot give us a proper response yet

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    Our challenge to Defra over the impact of the release of 50+million non-native gamebirds is clearly giving them some difficulty.

    They have been in receipt of our Pre Action Protocol letter (which sets out the details of our claim against them) for three weeks. We were generous – they should reply in two weeks but we gave them three weeks – after all Michael Gove was trying to be Prime Minister and we were approaching the holiday period.

    There is a protocol set out for this type of thing – you can read it here. Wild Justice always intends to stick to the protocol and so far we have, but public bodies such as Natural England and Defra often don’t.

    Not meeting deadlines is sometimes due to inefficiency, sometimes because the other side is struggling to come up with a cogent answer and sometimes is because they are mucking you about. But the rules are clear:

    Defra should have replied to us on Tuesday this week after we had given them three weeks, rather than two weeks, to come back to us with their response and they did respond, but they asked for another four weeks on top of the three weeks they had already had. This is not the action of a government department which is certain of its case. Where the proposed defendant is confident they often slap back a response quickly just to show that they aren’t the least bit bothered by the proposed legal action. But that’s not what Defra has done.

    Now, it might be that a new ministerial team, with Theresa Villiers, who has some background in animal welfare issues so may be interested in this case simply because it is about captive-bred birds destined for shooting, and Zac Goldsmith, who is more of an environmentalist than most Defra ministers of the last decade, is engaging with this action. Or it might be that the government legal department has nipped off to the south of France for a month.

    Once we can let you know what is happening then we will.

  135. Telegraph publishes letter correcting their coverage of Wild Justice

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    The Daily Telegraph published a story about the absence of Chris Packham and Mark Avery from the Game Fair on their website last Friday evening.

    We wrote to the Daily Telegraph as follows on Saturday:

    Sir, Your report of our banning from the Game Fair (25 July) is wildly inaccurate – perhaps because you didn’t speak to us. We had both been invited to the Game Fair to be interviewed by a presenter of a pro-shooting news channel. Your report did not mention this and falsely gave the impression that we were planning to gate-crash the gathering. Having been invited weeks ago, we were ‘uninvited’ a couple of days before the event. The organisers of the Game Fair were nervous about an audience hearing our very reasonable views about how game shooting needs to reform to survive. Wild Justice is not an animal rights campaigning group.  No Wild Justice directors are involved in a Panorama programme on grouse shooting. We have invited Charlie Jacoby of the Fieldsports Channel to the annual Bird Fair at Rutland Water on Saturday 17 August to ask us the questions that the Game Fair wouldn’t allow to be asked. We hope he can attend.  

    Chris Packham CBE and Dr Mark Avery

    Wild Justice

    What the paper has published:

    SIR – We had both been invited to the Game Fair (report, July 25) to be interviewed by a presenter of a pro-shooting news channel. Having been invited weeks ago, we were “uninvited” a couple of days before the event. The organisers of the Game Fair were nervous about an audience hearing our very reasonable views about how game shooting needs to reform to survive.Wild Justice is not an animal rights campaigning group. No Wild Justice directors are involved in a Panorama programme on grouse shooting.We have invited Charlie Jacoby of the Fieldsports Channel to the annual Bird Fair at Rutland Water to ask us the questions that the Game Fair wouldn’t allow to be asked.

    Chris Packham
    Dr Mark Avery

    London W1

  136. Natural England conduct – unacceptable

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    On Friday, our lawyers sent the following letter to Natural England regarding their evidence to the Efra Committtee and their conduct towards Wild Justice.

    This is a follow-up to our earlier letter. Clearly there was a response from Natural England in between but that is up to Natural England to publish if they wish – we’d be happy with that.

    Wild Justice is going to meet Natural England in August to discuss a range of issues.

  137. Wild Justice parks legal action on general licences – but the engine is still running and the car is ready to go!

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    On Friday, Wild Justice’s lawyers wrote to Defra and Natural England about general licences. The beginning and end of the lengthy letter are reproduced below – please read these extracts, but the summary is as follows. Because of the passage of time, and the time-limited nature of the general licences, and the apparent fact that a consultation will be issued on these matters ‘soon’, and the speed with which the legal system operates, Wild Justice does not have time to mount a sensible challenge of the legality of the general licences this time around. But we will mount such a challenge next year if any new licences issued by Defra and/or Natural England fail to address the legal points that we have made.

    So if our legal challenge is a car, we haven’t scrapped it. In fact it is almost fully fuelled (the crowdfunder), the driver is sitting at the wheel and the engine is revving. We are ready to set off again at a moment’s notice.

    Anyone wanting to rely on general licences in 2020 please take notice that Wild Justice will take legal action if Defra/NE do not heed our legal case. Be aware that any revocation, removal, delay of licences next year will depend on Defra’s/NE’s appropriate response to the legal points that we have made.

    Dear Sir/Madam

    Re: General Licence WML – GL26: To kill or take Carrion Crows to prevent serious damage to livestock including poultry and reared gamebirds

    We write in response to Natural England’s (NE) letter of 5 July 2019 and the Secretary of State’s (SS) letter of 11 July 2019.

    Those letters do not in any way change our view that Wild Justice would have a strong basis for a challenge to GL26 as issued by NE on 26 April 2019, on the basis explained in our letter of 4 June 2019. As for the points made in your letters, in outline only:

    We’ll not reveal the detail of our legal case here. But the summary of the letter is important.

    13.       Accordingly, as above, we remain of the view that Wild Justice’s claim here would be a strong one.
    14.       However, we are mindful of the fact that an application for judicial review made now would be unlikely to be considered and determined by the court much before the end of 2019 and quite possibly later. Certainly, there would be little if any of the life of these particular licences left at that point. We also note that you (SS/NE) are currently reviewing all such licences with a view to fresh and different licences in 2020. If that is right, then even if the court were to agree with Wild Justice on the points in issue here, that would have little if any continuing impact when it came to the 2020 licences and beyond.
    15.       On that basis, and that basis only (namely without any implication that its claim would not be strong in law) Wild Justice is proposing not to proceed with a judicial review challenge to the 26 April 2019 GL26 licence, or the others produced at the same time which rely on the same flawed approach. However, to be clear, by doing that Wild Justice is not in any way to be taken as compromising or prejudicing its ability to challenge the legality of other licences, including any licences produced following the review for 2020. Indeed, Wild Justice will scrutinise all such licences carefully and if any repeat the errors we have identified here, then Wild Justice will take all necessary legal action at that point.
    16.       In the meantime, Wild Justice looks forward to the consultation process(es) which will presumably form part of that review including consultation on proposed new licences. It will enthusiastically take part in those processes. Meanwhile, we trust that, while presumably outwardly maintaining your stance on the points above for the moment, you will nonetheless take them into account within the review and when considering any further licences (in a similar way to the approach you took to Wild Justice’s previous judicial review, namely outwardly maintaining that Wild Justice was wrong, long after you had accepted privately that Wild Justice was entirely correct).
    17.       To that end, our client would be willing to meet with Natural England and/or DEFRA to discuss any of the above.

    Yours faithfully
    Leigh Day

  138. Wild Justice, Fieldsports Channel and the Bird Fair

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    Wild Justice directors Chris Packham and Mark Avery were supposed to be having a grilling from the Jeremy Paxman of shooting, Charlie Jacoby, this morning at the Game Fair, and they were quite looking forward to it, but a couple of days ago the invitation was peremptorily withdrawn, apparently on the instruction of the Countryside Alliance, BASC and GWCT.

    Today, Chris Packham, on behalf of Wild Justice and with the agreement of the Bird Fair invited Charlie Jacoby to come and ask his questions in front of a much larger Bird Fair audience on Saturday 17 August.

    Here is what Chris said:

  139. Do not read if you are easily offended

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    Three weeks ago Chris Packham posted this image – it’s the three Wild Justice co-directors, Mark Avery, Chris Packham and Ruth Tingay – giving our support to Henry Morris and friends who were running across grouse moors in northern England to highlight the plight of Hen Harriers and to raise money for Wild Justice. By the way, their crowdfunder has raised over £12,000 already and has just a few more days to run.

    Our photograph was then posted on Facebook by Andy Richardson who describes himself as an ‘ex-headkeeper come conservationist’.

    There then followed a stream of abusive comments from a variety of people, most of whom self-identify as members of the shooting and/or fishing community. We post these comments here just to illustrate the type of abuse that the three of us get routinely – the examples posted below are the tip of a very large iceberg and no doubt will be written off by others as being just a few bad apples.

    This type of abuse is made on open access social media and can be read by anyone. That means that the authors of the following comments are quite happy, in theory, that their girlfriends, wives, mothers, grandmothers children, workmates, friends and anyone else in the world should read them.

    It also means that the friends, relatives, workmates and children of Wild Justice co-directors can read them.

    If you read them, then prepare to be shocked at the nastiness, the misogyny, the aggression and the rudeness of what follows. But the authors are clearly happy for attention to be directed to their words as they have written them in a public place. Imagine walking down the street and having these vile comments being directed at you.

    Here is some information about some of the authors of these comments:

    Steve Evans – lives in Sunderland, is proprietor of Owl Tree Works and seems to have a son who plays football.

    Shaun Freke – quite keen on shooting by the looks of it, and manages a Blues band in which he sings.

    Peter Onslow – a MD/CEO of a small company and seems to like horses

    John Edwards – an artist that produces models of fish.

    Richard Neville – pigeon shooter from Tring, Herts

    Sandy Ferguson – farmer from Fife

    David Mayoh – retired, seems keen on fishing

    John Cameron Dunn – Man Utd and shooting

    Andy Hilton – from Ruthin, North Wales, might well be a gamekeeper?

    Ben Tarvie – very interested in birds’ eggs

    Chris Walker – man in tweed who looks like a gamekeeper

    All these people may have perfectly normal and productive lives but when they get onto social media they use language that they probably (but we don’t know them) wouldn’t use in polite society. We wonder how many of them will gather together at the Game Fair tomorow, Saturday and Sunday?

    If you would like to support the work of Wild Justice despite these abusive comments, or maybe because of them, then you can donate to our work here.

    And by the way, the comments immediately below illustrate why we don’t permit comments on this blog.

  140. Wild Justice directors uninvited from Game Fair

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    Wild Justice’s Mark Avery and Chris Packham had both been invited to Friday’s Game Fair in Hertfordshire to present our views in front of an audience of hunting, shooting and fishing supporters (to a large extent). At almost the very last minute, they were both ‘uninvited’.

    Here is what Chris Packham said in response.

    Both Mark and Chris had been perfectly happy to face what was expected to be a sceptical, even hostile, audience but it seems that the shooting organisations ran scared from debate.

  141. Crowdfunder approaches end of Week1

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    The Wild Justice crowdfunder to raise funding for a legal challenge of Defra (until yesterday actually of Michael Gove but now of Theresa Villiers) will complete its first week at 10am this morning. We are aiming to force Defra to carry out an ecological assessment under the Habitats Directive of the impacts of releasing 50 million non-native gamebirds, Pheasants and Red-legged Partridges, into the countryside every year.

    These two species of non-native bird make up half the biomass of birds in the countryside. If this completely unregulated situation had not crept up on us over the years, and from scratch someone suggested that we release these birds into the countryside, then surely government would have said ‘Hang on a second, that’s bound to have a fundamental impact on the ecology of the countryside. We ought to check this out.’. Our legal challenge is to get this checked out.

    Thank you for amazing support from over 1100 individuals. In 23% of the time allowed, we have raised 66% of the funds needed. We have 23 days to raise the remaining £14,974 to reach our £44,500 target.

    Please consider donating to our crowdfunder – click here – thank you.

  142. Crowdfunder update – over half way

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    On Thursday morning, at 10am, Wild Justice launched its current crowdfunder to raise the massive sum of £44,500 in order to fund a legal challenge to force Defra’s Michael Gove to assess the ecological impact of the annual release into the countryside of 50+ million Pheasant and Red-legged Partridges.

    After c70 hours (ie we’re still in Day 3 of this appeal) the amount of money we still need to raise doesn’t begin with a 4, or a 3 or a 2 but is £19,930. That’s still a lot of money, but we are well over half way there. Thank you to 1000 supporters for getting us so far, so quickly.

    The three Wild Justice directors, Chirs Packham, Ruth Tingay and Mark Avery spend a ridiculous amount of time checking on progress of the crowdfunder – it becomes quite addictive. So to keep putting smiles on our faces, if you’ve been meaning to donate but haven’t quite got around to it yet, then please have a look at our crowdfunding page on the Crowdjustice site.

    Here are some of the messages that we have been sent by supporters:

    I’ve just been reading The Times (Chris Packham starts legal challenge over release of 35m pheasants and partridges) and I think what Wild Justice are all doing is great. You don’t have to be vegan or even particularly tuned-in to realise something’s going horribly wrong on so many fronts. And, as many campaigners have shown before, the law can be a very powerful tool if it’s brought to the defence of those who cannot defend themselves.

    Excellent news, thank you for tackling this on our behalf and on behalf of wildlife. I work in the countryside and whilst there is some good conservation work and local employment done in the course of managing shoots I think the degree to which the countryside is altered to support game shooting is unjustifiable and unsustainable. Huge swathes of land are just pheasant and partridge farms and shooting ranges.’

    I like many shooters in the UK who have no interest in killing wildlife
    either for food or reprehensibly for fun, but are railroaded into BASC
    membership to get insurance cover for our target (as in paper target)
    shooting hobby, but are getting sick and tired of the BASC’s continued
    bollox about ‘shooting under threat’ in the UK as their standard response
    to good people like yourselves standing up for our wildlife.

    As a 20 year vegan who happens to enjoy the relaxing yet challenging
    hobby of target shooting – the BASC’s vocal assertion of speaking for
    all shooters in that ‘all for one and one for all ‘ diatribe of theirs
    has just gone too far and I will be canceling my membership and looking
    for an alternative forthwith.

  143. Wild Justice crowdfunder enters Day 3

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    Wild Justice is crowdfunding so that we can take our legal challenge of Defra all the way through the courts. We are trying to force Michael Gove to assess the impact on UK wildlife of the release of 50 million non-native gamebirds (Pheasants and Red-legged Partridges) by the shooting industry.

    Wild Justice says that these vast releases of birds at this time of year must be assessed under the EU Habitats Directive legislation and that Defra has failed to do so.

    48 hours ago we launched a crowdfunder to raise the £44,500 we need to take on the big guns of Defra. The response has been amazing – thank you to the 850+ people who have generously donated to this appeal. We are almost half way to our target and, although there is a long way to go, it’s a great start.

    If you would like to learn more about Pheasants in particular, 43 million of which are released into our countryside every year for shooting, then email and put PHEASANTS as the subject of your email, and we’ll send you some information.

    If you would like to support our legal case using your credit/debit card then please have a look at the crowdfunder page – 50 million non-native gamebirds damaging UK wildlife – then please click here.

    Alternatively you can donate using PayPal, or by bank transfer, or even by sending us a cheque in the post and the details for those options are on the Wild Justice website – click here.

  144. GWCT stung into limp, unconvincing defence of their members.

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    GWCT is clearly rattled by the Wild Justice legal challenge – even though it is to Defra. Rarely do we hear the thoughts of GWCT Chief Exec Teresa Dent; we only usually get the spin of her right hand man, Mr Gilruth. So it must be something momentous to get Teresa to utter.

    This is what she said;

    We [GWCT] found that the releasing of lowland gamebirds can be done in a way that minimises or avoids negative effects on habitats and other wildlife, and maximises the potential of management practices associated with releasing to deliver broader biodiversity benefit.

    Well, was that really worth waiting for…?

    The critical word above is a small one – the word ‘can’.

    I ‘can’ live a life of perfection, in theory, but ‘do’ I?

    The GWCT ‘can’ speak without a forked tongue – but ‘does’ it?

    Natural England, of which Teresa is a Board member, ‘can’ use all its might and power to conserve the Hen Harrier, but ‘does’ it?

    So, yes, Pheasant releases, in another and wholly imaginary world, ‘can’ be done in a way that minimises or avoids negative effects (how wise to admit that negative effects exist) but are they?

    Elsewhere on the GWCT website you will find more concrete evidence for harm, from their own work – this is (as I said in my recent British Birds paper) a good summary of the situation:

    There are legitimate questions relating to the release of pheasants for shooting and impacts on habitats and wildlife. The Game & Wildlife Conservation Trust research in this area over the last decade or so has been substantial but has still tackled only some of the issues. It has highlighted so far a number of possible unwanted impacts, which are usually a result of the released birds themselves, and a number of positive effects, which are usually associated with habitat management work for game.

    The impact of pheasant releases: balancing the positive with the negative

    Unwanted impacts that are usually a result of the birds themselves – and the number of birds being released has increased dramatically, as best illustrated by this graph from the GWCT website;

    GWCT website

    How high is that graph in 2019? I’m pretty sure that it is higher than when this graph stops in 2010. How odd that GWCT haven’t updated it.

    There is plenty more one could say, but let us just point out that Teresa relies on shoots sticking to the Guidelines for Sustainable Gamebird Releasing. These are the GWCT’s guidelines – not government guidelines, and not enforced in any way. But maybe GWCT members (and everyone else flinging Pheasants into the countryside) is a paragon of virtue when it comes to sticking to the guidelines? How likely do you think that is?

    Well the GWCT themselves give us part of the answer here;

    The GWCT suggest that around 700 birds per hectare of release pen is an appropriate stocking level (Sage & Swan, 2003) but releases in the order of 8,000 birds per hectare of release pen, have been documented. The mean stocking density reported in Sage et al. (2005) is currently 1,800 birds per hectare of pen.

    The recommended stocking density is 700/ha but the average is more than twice as high as that (1800/ha) with an admitted example of more than ten times the recommendation (8000/ha). What a great example of self-regulation by Pheasant shooters. It’s a good job GWCT members aren’t ‘self-regulating’ on drink-driving isn’t it?

    The Wild Justice legal challenge asks Defra to comply with the Habitats Directive and assess the impacts of Pheasants – such examples will make any independent assessment take a closer look at everything else going on in the world of Pheasant shooting. And rightly so.

    And here is our crowdfunding page asking for your support, please, so that we can take this case through the courts.

  145. Wild Justice challenges gamebird releases

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    P28PYW Seven week old pheasant chicks, often known as poults, after just being released into a gamekeepers release pen on an English shooting estate

    Last week Wild Justice sent a Pre Action Protocol letter to Michael Gove at Defra requiring him to assess the impacts of the release of the vast and increasing numbers of non-native gamebirds into the countryside. This, we argue, is a legal requirement under the EU Habitats Directive.  Please support our crowdfunder.

    Every year 43 million captive-reared Pheasants (and 9 million Red-legged Partridges) are released into the countryside.  The numbers released have increased about 10-fold in the last 45 years and, like most of the rest of the shooting industry’s activities, are not regulated by government. More paperwork is needed to reintroduce native UK species into the countryside for conservation purposes than to release non-native omnivorous birds on a vast scale to fuel recreational shooting.

    Gamebird releases and associated shooting are of concern because:

    • Pheasants and Red-legged Partridges eat a wide variety of native plants, invertebrates, reptiles and even small birds and mammals.  These impacts must be properly assessed particularly since release numbers are unregulated and increasing.
    • One in three released gamebirds are shot for recreation but the rest die of disease, on the roads, from starvation or are killed by predators. This bonanza of prey and carrion feeds the numbers of a range of generalist predators and scavengers. High UK populations of Red Foxes and Carrion Crows may affect the numbers of some ground-nesting birds such as Curlew and Lapwing.
    • Gamebirds can carry diseases that affect native wildlife, commercial poultry stocks and people.  Pheasants often have high burdens of the ticks which transmit Lyme disease to humans.
    • Pheasants are shot with lead ammunition, the vast majority of which is discharged into the countryside and accumulates. Lead is a poison for wildlife and people.
    • The illegal persecution of birds of prey continues at a high level in the UK and over 60% of those convicted of offences are gamekeepers – most of whom will be employed by shooting estates which release Pheasants and Red-legged Partridges.
    • Pheasant numbers are increasing most rapidly in upland areas where their impacts on heathland wildlife through direct predation (eg of Adders and Common Lizards), through their droppings and browsing affecting sensitive plant communities and through altering predator numbers are of growing concern.
    • Gamebirds on country roads cause serious road traffic accidents each year.
    • Increasingly, shot gamebirds are being dumped or buried in the countryside because the market for food consumption is saturated but the market for recreational shooting is booming.
    • Although the shooting industry claims that management for gamebirds benefits other species there is increasing evidence that they are actually a problem for farmland birds because they compete with them for food resources in winter.
    • The density of released Pheasants in woodlands is often 10-times that recommended to safeguard invertebrate populations.
    • There are very real welfare concerns around the breeding, transport and release of gamebirds including in regard to their importation in their millions from European breeders.

    For all these reasons, and probably many others, we believe that gamebird releases ought to be regulated. The Habitats Directive requires the UK to assess ‘plans or projects’ which may affect protected sites of nature conservation importance.  There is no doubt in Wild Justice’s mind that the release of 50+ million non-native gamebirds into the countryside is a plan or project which has ecological impacts and which must be assessed.

    Please support our crowdfunder so that we can take this case through the courts and compel Defra to act.

    Chris Packham, a director of Wild Justice, said ‘The UK’s shooting industry is one of the least regulated in Europe with no centralised collection of any data. No one knows how many birds are released or shot, whether wild or captive bred. So how on earth can that shooting industry claim to be making informed decisions about sustainable harvesting, stocking or conservation? What is blindingly obvious to anyone with even a basic understanding of natural sciences is that dumping at least 50 million non-native birds into the UK countryside will have a profound effect on its ecology – it’s about time we measured what that effect is.‘.

    Ruth Tingay, a director of Wild Justice, said  ‘It’s worth noting that the 50+ million figure is only a guesstimate, made by the shooting industry six years ago. For all we know there could be 100 million Pheasants and Red-legged Partridges being let loose in the countryside every year. The fact that the Government doesn’t know or care how many are released, and its previous refusal to assess the extent of the environmental damage caused, will come as no surprise to conservationists who have watched this Government put vested interests ahead of wildlife conservation time and time and time again.‘.

    Mark Avery, a director of Wild Justice,  said ‘Let’s take a step back: if we had never seen a Pheasant or Red-legged Partridge in the countryside and someone suggested releasing over 50 million of these omnivorous non-native gamebirds annually would we just nod it through with no concerns? No! It’s only because this situation has crept up on us through lack of regulatory control that we are in this position. Government has been lax and now Michael Gove must act.‘.

    Carol Day, solicitor at Leigh Day, said ‘The aim of the law is to ensure that plans and projects that could have a significant adverse effect on important wildlife sites are properly evaluated before permission is given to carry them out. Our client is arguing that the scale of gamebird releases and the potential impact on the UK’s most important wildlife sites is such that a process for assessment must now be provided.’.

  146. Countryfile

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    Mark Avery, co-director of Wild Justice writes:

    It’s over a fortnight ago that I drove for three hours to Yorkshire to be interviewed by Countryfile about Wild Justice’s successful (and ongoing) legal challenge over the general licences.

    I spent several hot hours in the sun at Wheldrake Ings and talked to Charlotte Smith (right, above) and was filmed by the BBC film crew. There was lots of walking up and down, quite a lot of leaning on a gate, some time waiting for the local flying school planes to move on and some time seeing some birds and lots of Painted Lady butterflies.

    On the same day, the team interviewed my mate Tony Juniper, now Chair of Natural England, a local farmer and some time later they talked to Andrew Gilruth of GWCT. I knew all that was happening but not what had happened. So I was as interested as everyone else to see the programme when broadcast. Well, actually I’ve only just looked at it because the Cricket World Cup Final was much more interesting and then I had some work to do and some family phone calls to make and take, so I’ve only looked at it this morning.

    You can look at it now too on BBC iPlayer – it starts c14 minutes into the programme. It’s a pretty fair piece and I don’t have any complaints about the treatment of Wild Justice. When you do several takes of the same thing you tend to think ‘They’ve missed out some of the best bits I said’ but that’s life. And the piece has certainly gone down well with many, as Wild Justice has received many emails and donations directly linked to the Countryfile programme – thank you!

    Having said that of course, it isn’t the programme that Wild Justice would have made about the subject but that’s not really the point. We know that Countryfile has form in leaning towards the opinions, however ungrounded in facts, of farmers and shooters and we all have to take that as read.

    There is one passage that I would have liked to be included where I listed the things wrong with the general licences, not just their unlawfulness as pointed out by our challenge, but also the species on them (there is no excuse for Jackdaw, Rook, Jay or Magpie being listed for their impacts on wildlife), for the fact that they are not understood by the people that use them, the fact that bird identification sklills by users of the general licences are often very poor, the fact that there is no monitoring of the numbers of birds killed or of what species and no enforcement on the ground of the provisions of the licences. But there you go.

    The section with the farmer was interesting – I wonder whether he has been meeting the actual conditions of the general licences all these years? And of course he is killing birds to protect birds – that is the party line even though it is barely grounded in science at all. He may well believe what he says even though he has been misled on the science.

    Andrew Gilruth just made the outrageous suggestion that some unnamed species are ‘entirely reliant’ on people using the general licences – really? Which species are entirely reliant on Jays being killed, Andrew – and what is the evidence? And are even Curlew ‘entirely reliant’ on gamekeepers killing birds, Andrew? How about Foxes? The exaggeration slips so easily off the tongue of the GWCT spin doctor who I tend to think of as the ‘Grand Insinuator’ these days.

    There was a piece not used by Countryfile where Gilruth was banging on about his insinuation that Wild Justice had been offered a deal to go away by Natural England. I know they were planning to film this because they asked me questions about it which I answered on camera before they spoke to Andrew. Charlotte Smith asked me a question and I said something like ‘I don’t know what he’s on about. Do you? Where is this information which GWCT claims to have got through a Freedom of Information request but hasn’t published? Have you seen it because I haven’t’. When I was shown the smoking gun, which would have been pointing at Natural England not Wild Justice, I pointed out that was simply NE’s letter conceding the challenge and they had to say something but they certainly didn’t say what GWCT seemed to be suggesting. Natural England behaved badly enough in this case (see here) but to offer a ‘deal’ when they knew that the law was against them would have been a sacking offence. It’s hardly surprising this did not appear in the programme. By the way, the CEO of GWCT is Teresa Dent who is also a Board member of Natural England…

    And then there was Tony Juniper. Tony’s first day as Chair of Natural England coincided with the revocation of the general licences but he had played no part in the decision-making process leading up to that decision. I had to laugh when he said that it would be good if everbody sat down and talked about things – I’m sure that that’s what was said of Tony when he was laying about government and industry in his good old days at FoE! And we haven’t had a phone call from the Chair of Natural England to come round for a cup of tea yet but we’ll certainly answer the call if he makes it, and is serious. In fact there are some matters on our list which, after a bit more research, we may want a chat about. Watch this space.

    But Tony ended with the alarming news that NE can’t do its job properly because of lack of resources. That is probably true – lack of resources and lack of will have been two of the big handicaps that have held back NE in its work for many years. It is to be hoped that, together, Marian Spain (who has had a torrid time but is more of a nature conservationist than her predecessor) and Tony Juniper (who is certainly a nature conservationist) will be able to remedy the lack of nerve. Unless NE demonstrates some balls then no amount of money will help them deliver what they should do for the public. I am hopeful that things will change but the jury is still out – it’s obviously too soon to tell.

    Countryfile asked me, on camera, what I thought of Natural England, perhaps expecting a rude response but from memory I said something like this ‘I think they are wonderful. Obviously Tony Juniper, their new Chair is a mate, and I have many other friends who work in Natural England, so of course I think they are wonderful. But they are nowhere near as wonderful as they used to be. And they need government support and resources to be really wonderful once again.’. Something very close to that anyway. But Countryfile, for their own reasons didn’t broadcast that. If they had stuck that on the end, then the piece would have ended on a note of agreement. No criticism of Countryfile intended, but, as you can see, the editor is in a very powerful position to create a narrative with the pieces recorded in completely independent and unsighted interviews, and it’s what is left on the cuttting room floor which is as important as what is included. That’s why my preference is for live broadcasts – then you live with your mistakes and triumphs and nobody controls the message.

    So Tony, you’d have had that call for more resources from Wild Justice – but Countryfile cut it out.

  147. Hen Harrier Day update

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    Preparations for Hen Harrier Day are proceeding well – although setting up an event is always a bit nerve wracking.


    Location: Carsington Water, Big Lane, Ashbourne, Derbys DE6 1SE

    Date and time: Sunday 11 August, 12midday – 5pm

    Event: a family-friendly, open-air celebration of the threatened Hen Harrier

    Speakers: will include children’s author Gill Lewis, Wild Justice director Ruth Tingay, RSPB Hen Harrier Life Project’s Cathleen Thomas, Wales raptor enthusiast Dan Rouse, Hen Harrier Westminster Parliament species champion Angela Smith MP (tbc) and Green Party former leader Natalie Bennett [and a similar number of men].

    Weather: bring sun-screen and a raincoat – we don’t know!

    Advantages of location: Severn Trent have been very welcoming and they are used to hosting similar events; toilets, loads of parking (pay and display), shops and a cafe on site. Equally inconvenient to reach from many parts of England and Wales.

    Disadvantages of location: intermittent phone reception but Vodaphone is best. No bus service runs on a Sunday.

    Cost: to you it’s free, to us it’s an expense – but we are having fun setting it up.

    We are looking at setting up livestreaming of the event but it doesn’t look completely easy – but a team of techies is working on it.

    Stewart Abbott is attempting to set up a car-sharing service which is very kind of him.

    We are looking to set up a book-signing in the RSPB shop at the end of the event.

    The results of a childrens’ creative writing exercise will be read out from the stage.

    More details as the event gets closer.

  148. Thank you very much

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    From a sixth form college in the south of England – thank you very much indeed. We’re very grateful for this type of support. When we get a letter or a card in the post it’s often this type of lovely surprise.

    We won’t publicise the name of the sixth form college or individuals partly because, sad to say, we find that not only the three Wild Justice directors but also supporters of our work, are certain to be trolled on social media by people who almost always are clearly from the shooting ‘community’. More on that at a later date.

    It’s a crazy world with a mixture of good and bad people in it.

  149. Henry Morris raises awareness of wildlife crime and supports Wild Justice

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    On Wednesday morning at 8am in a remote part of the Forest of Bowland Area of Outstanding Natural Beauty in Lancashire, Henry Morris (second from right above) and his brother Ed, and friends Tim and John set off on a journey. Henry’s aim was to run 200km, in four days, across the grouse moors of northern England to publicise the illegal killing of Hen Harriers and to raise money for Wild Justice. Wild Justice director Mark Avery was there to wave the gang off and wish them well.

    A pair of Hen Harriers; the grey male is passing some food that he has caught to the brown female who will take it back to the chicks in the nest. And all this happens at speed in mid-air. Photo: Godon Yates.

    On Saturday at 2pm, in Nidderdale in Yorkshire, Wild Justice directors Ruth Tingay and Mark Avery, and a crowd of friends and family of Henry and the other runners, gathered to welcome them to the end of their journey.

    What an achievement! As Henry and his relay team ran through villages they were greeted by supporting honks from passing motorists, cheers from people along the route and some puzzled looks.

    Henry was carrying a satellite tag, a bit like the ones that are used to study birds and their movements, and so it had been possible to follow his progress across the remote uplands of Lancashire, Cumbria and Yorkshire. Henry had planned his route to visit the areas where Hen Harriers, also carrying satellite tags, had ‘disappeared’ in recent years. A recent analysis of the Hen Harrier data was entitled ‘Patterns of satellite tagged hen harrier disappearances suggest widespread illegal killing on British grouse moors.‘ and confirmed the open secret that Hen Harriers are gunned down, totally illegally, on grouse moors because Red Grouse form part of the birds’ diet. In other words, a protected and beautiful bird is killed illegally to protect Red Grouse stocks so that people can shoot the grouse for fun later in the year.

    Henry Morris and his satellite tag.

    Henry, like most normal people, was amazed and incensed by this rampant wildlife crime in the National Parks and Areas of Outstanding Natural Beauty in northern England and planned his run to ‘join the dots’ of locations of Hen Harrier disappearances.

    On Friday the runners visited the spot where a famous Hen Harrier, hatched and fledged in the Forest of Bowland where Henry’s run started, was illegally killed, shot, in Nidderdale near where the run ended. That Hen Harrier was named Bowland Betty by local school children and she travelled far and wide in her first two years of life, visiting moorland in the north of Scotland and many sites in the north of England before meeting her end in Nidderdale before she had the chance to rear any chicks herself. Bowland Betty’s story is a famous one, a typical one, but a sad one – and there’s even a book all about her short life and its untimely end.

    Henry Morris is amazing! A few months ago he had never seen a Hen Harrier and he knew little about wildlife crime affecting them and other birds of prey in the English uplands and now he is a Hen Harrier fan and a leading advocate for their proper protection. He has been inspired by this marvellous bird and the wildlife crimes that threaten its existence – but his marathon run inspires the rest of us to keep on campaigning for a better deal for wildlife. See his Hen Harrier website here.

    Henry has also been raising money for Wild Justice through his run and he is fast approaching £10,000. If you feel inspired by Henry’s marathon run then please contribute to his crowdfunding page which you can access here.

    We’ll be agreeing with Henry how we should spend the money raised. It is likely that some of it will go to the costs of setting up the Hen Harrier Day event in Derbyshire on 11 August, some may go to spreading the word about Hen Harriers to schools and some may be added to rewards for information to help the police catch wildlife criminals. It all depends how generous you are!

    By the way, Wild Justice will be sending out its next newsletter overnight so it should be in your inbox tomorrow morning – subscribe here.

  150. Marathon for the Missing Hen Harriers

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    Henry Morris is running through the grouse moors of the north of England this coming week to raise money for Wild Justice, to publicise the fate of Hen Harriers and because that’s what he does as an ultra-marathon runner. See his website for more details.

    He’ll be carrying a satellite tag, much like some Hen Harriers have done, and you’ll be able to see whether or not he disappears on the moors as have many, many Hen Harriers including the sad case of Hen Harrier Rannoch which emerged last week – slowly killed in an illegal trap on a Scottish grouse moor.

    Hen Harrier ‘Rannoch’ died on a Scottish grouse moor.

    Wild Justice has talked to Henry about how to spend the money that he is raising and options include: funding Hen Harrier Day events, donating books about Hen Harriers to public and school libraries and funding more satellite tags to study this endangered bird.

    Henry’s doing an amazing thing – please support his crowdfunder.

  151. Hen Harrier Day 11 August

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    The speakers confirmed so far are the three Wild Justice directors (Chris Packham, Ruth Tingay and Mark Avery) and Iolo Williams (TV presenter), Gill Lewis (author), Tim Birch (Derbyshire Wildlife Trust), Superintendent Nick Lyall (chair of Raptor Persecution Priority Delivery Group) and Cathleen Thomas (RSPB Skydancer project) – but there will be more.

    More details to follow over the coming weeks.

  152. Wild Justice statement on new general licences.

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    Wild Justice says:

    Odd isn’t it? Natural England consulted with Defra in April and revoked these licences and then Defra consulted with Natural England in June and reinstated them. We wonder whether they know what they are doing.

    Wild Justice is most interested in the licences which authorise killing protected birds for the purposes of nature conservation. On the science; the licences are flawed. On the law; our challenge to GL26 is lodged and we await Natural England’s response by 4pm on Friday next. We are also consulting our lawyers over the new licences issued today. And on the politics; Michael Gove probably won’t be Environment Secretary for much longer and he is leaving a mess for his successor to clear up.

    Wild Justice looks forward to the promised consultation on general licences but that seems a long way away. Defra should move much quicker.’

  153. Evidence base for GL26 is threadbare

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    This is the section in the Licence Determination document received from Natural England to justify the publication of General Licence GL26 to ‘authorise’ control of Carrion Crows to prevent serious damage to livestock including gamebirds (Pheasants and Red-legged Partridges).

    We’ll come back to this ‘evidence’ but once you read it carefully you will see that it is does not amount to much. That either means that there is no strong evidence which could amount to a justification for issuing a general licence of this type or that Natural England have done a poor job in finding it and summarising it here. For serious damage to sheep we suspect that it may be the latter – but what do you think? For gamebirds we think it is the former – what do you think? But in both cases the evidence presented by Natural England does not justify the widespread, unmonitored, unregulated killing of Carrion Crows under a general licence.

    Just one more thing – note that this Natural England document is dated ‘February’. See where this sits with respect to the timeline of Wild Justice’s legal challenge. When Natural England responded to Wild Justice’s legal challenge with an evasive and ambiguous letter, on 13 March, they were already preparing this replacement general licence…

  154. Farmers Weekly on our new legal challenge

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    As we wrote yesterday, Farmers Weekly has now published a news story about our new legal challenge on their website – here it is. It’s a fair enough account of things.

    Just to be a little picky, Wild Justice has not challenged the crow shooting laws – we like the laws that protect wild birds. We are challenging Natural England’s licensing of lethal control of crows and other species because, specifically because, we do not believe that they implement the laws that have existed for decades.

    That’s a technical but massive difference. Our success in our first legal challenge showed that the statutory agency, Natural England (and its predecessor bodies) had for decades, failed to implement the existing laws through a lawful licensing system. We haven’t changed the law, and we aren’t calling for the law to be changed. We want Defra and Natural England (and devolved adminstrations elsewhere in the UK) to give effect to the existing laws properly.

    If the licensing authority, the statutory regulator, isn’t implementing the law correctly then questions need to be asked of it. These questions have not yet been asked of Natural England and Defra.

    And another day has passed without Defra announcing its plans for lethal control of the species formerly listed on the General Licences GL04, GL05 and GL06. They are more than three weeks overdue and they have been ‘imminent’ for over a week.

  155. More on our latest legal challenge

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    Because the magazine/website Sporting Gun was unique among shooting magazines in actually asking us about what we were doing when Natural England revoked the General Licences GL04, GL05 and GL06, and because they asked some sensible questions and printed our answers faithfully, we have a bit of a soft spot for them. That doesn’t mean that we agree with them and it certainly doesn’t mean they agree with us, but they have certainly made an effort to be fair and we appreciate that.

    So we contacted them over the weekend to give them advance notice of our announcement of our second legal challenge. And that’s why they have this exclusive Q&A with us on their Facebook page and that’s why presumably the Q&A will eventually appear on their own website and perhaps in their magazine – and it’s why the likes of Shooting Times do not have this information.

    The comments on this Q&A from people who look as though they are mostly shooters show how difficult it is to reach out to this community. But there you go.

    We also contacted Farmers Weekly over the weekend because farmers are the other main group affected by changes to, and challenges to, the general licences. They’ve asked us some questions, they’ve ask for our comments, and they have taken them on board. They’ve treated us straight too. So you will soon see some reporting of our new legal challenge in Farmers Weekly too.

    We also contacted a national newspaper on this subject but they haven’t covered our legal challenge yet (as far as we’ve noticed). This is hardly surprising as, in the big scheme of things, this is rather complicated stuff and small beer in national news terms. But we tried. And guess what, the newspaper wasn’t the Daily Telegraph.

    In our first, and successful, legal challenge we did not name the public body (Natural England) whose decision we were challenging, nor the subject on which the challenge was based (General Licences GL04, GL05 and GL06) until over a month after launching it. We gave Natural England the time and space, unpressured, to consider their position. We believe that Natural England handled the matter badly and we will, when we get round to it, be writing to them and to the Efra Committee on that subject.

    You might have thought that a public body which had conceded a legal challenge to an entity might want to talk to that entity to check whether its new plans were going to be challenged again but we haven’t heard from Natural England. So, we didn’t feel any compunction about publicising this new legal challenge and publishing our Pre-action Protocol letter yesterday. We believe that the licences that Natural England published have a similar legal flaw in them as did the previous general licences. If Natural England thinks not, then we are prepared to take this case through the courts to have the legal arguments decided by a judge. If Natural England concedes again then the world will wonder what on earth they were doing issuing more legally flawed licences. We’ll have to see what happens.

    We’ll also have to see what happens with Defra’s much-delayed plans to issue new licences. We understand they had 4000+ responses to their rushed consultation but they will now also have had to scrutinise and think about Wild Justice’s new legal challenge. We are interested to learn their plans. When is the promised consultation going to happen? And when will a Defra minister appear in front of the Efra Committee? We keep hearing from others that Defra’s annoucement is ‘imminent’ – it’s been imminent for a while now.

    Last, but not least, many thanks to our friends at Birdwatch and Birdguides for promptly putting our news out to birders yesterday. Much appreciated!

  156. Our new legal challenge: General Licence GL26

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    On Friday morning Wild Justice launched a new legal challenge of general licences issued by Natural England.

    The formal legal letter is reproduced in full below.

    Wild Justice is challenging two aspects of GL26 (and only insofar as it relates to the killing of Carrion Crows to protect Pheasants), namely Natural England’s approach (1) to “alternatives” for the purposes of section 16(1A) Wildlife and Countryside Act (WCA 1981), and (2) to “kept” for the purposes of section 27(1) WCA 1981.

    Mark Avery of Wild Justice said;

    Licence GL26 is a shoddy document.  It is scientifically threadbare and, we contend, legally flawed. It does not form a sound basis to justify widespread, unmonitored, unlimited control of Carrion Crows to protect livestock. We are glad that Defra has promised a proper review of licensing of the killing of wild birds because, on the evidence of this licence, that killing often amounts to unjustified casual killing. We call upon Defra to announce the date and substance of that review as quickly as possible so that these matters can properly be examined before 2020’s licences are issued.  We also repeat our call to Defra not to issue any general licences to allow the lethal control of Jay, Jackdaw, Rook or Magpie for the purpose of protecting wild birds.  But now we are asking for the elements of GL26 which relate to protection of Pheasants and other gamebirds to be quashed and those elements which relate to other livestock to be thoroughly scrutinised in the review of general licences promised by Defra.

  157. A message from Defra

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    Received from Defra yesterday afternoon:

    Dear colleague,  

    We intend to announce shortly how we will proceed on general licensing, following an evidence-gathering exercise undertaken by Defra over the course of the last month. We received more than 4,000 responses to the call for evidence, and we have since been carefully considering all the evidence received in order to determine next steps, alongside additional evidence. As part of our evidence gathering we have sought the views of user groups on the useability of different potential licensing options.    

    We appreciate the urgency of getting a working licensing system in place as quickly as possible. A final decision has not yet been taken on the way forward, but we will be setting out next steps shortly.  

    Defra Stakeholders Team

  158. Hen Harrier Day 2019 #HHDay19

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    Male Hen Harrier. Photo: Gordon Yates

    It looks like there will only be one Hen Harrier Day event in the UK in 2019 – but everyone who cares about this bird and wants to see an end to its persecution is invited.

    Hen Harrier Day events started in 2014 and have been held at locations from Northern Ireland to inside the M25 and from the south coast of England to the highlands of Scotland. They are now a firm part of the ornithological and conservation scene.

    This year on the afternoon of Sunday 11 August, Wild Justice is organising a Hen Harrier Day event, with Severn Trent Water, at Carsington Water in Derbyshire. This is a large venue and can probably cope with what we hope and expect to be a sizeable crowd.

    Hen Harrier Day 2019 at Carsington Water will be a family-friendly event (bring your picnic if the weather turns out fine) with a host of great speakers. The event will celebrate this fantastic bird and highlight the ongoing illegal persecution that it faces on grouse moors.

    More details to follow.

  159. Nothing’s happening?

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    You may remember this handy visual aid published by BASC a while ago – it shows the scale of revocation of permission to use lethal means to kill particular bird species (listed down the side) for particular legitimate reasons (listed along the top). BASC basically called for all the red areas of the table to be coloured in green by Natural England and/or Defra so that life could be as it were before Wild Justice’s successful legal challenge of the General Licences GL04, GL05 and GL06. This seemed to ignore the unlawful nature of the previous licences. And we took the mickey, gently, out of BASC for calling for the reinstatement of Collared Dove killing for the purposes of preventing serious damage to fisheries.

    The cells in the table coloured green (Priority 1), yellow (Priority 2) and brown (Priority 3) were Natural England’s plans for issuing new licences in pretty quick time. Then Defra waded in and took over the process of issuing new licences with five working days consultation period starting on the Bank Holiday weekend at the beginning of May (Saturday 4 May). That consultation ended on 13 May and Defra said that Michael Gove would take a further week to review all the information and come to a decision – that would take us to the 20 May.

    Here’s a simple summary of what has, and more importantly what hasn’t, happened.

    Now we appreciate that ‘from 29 April’ includes all of the rest of time in the universe but five weeks later only three of the allegedly high priority 10 new licences have seen the light of day (and they aren’t very good – but we’ll come back to that later this week).

    Not surprisingly, the progress on the Priority 2 licences has been as follows:

    We’ve been waiting for three weeks to see any of these…

    And given the above, it is not surprising that progress on the Priority 3 licences has also been non-existent:

    None of this can be blamed on Natural England – the responsibility for this was wrested from them by Defra in early May. And Defra promised that Michael Gove would make his decisions by 20 May. That is now two weeks overdue:

    So, if BASC wanted to update their handy visual aid at the top of this post they could colour everything in red except the three general licences published by Natural England before Defra decisively stepped in and did … nothing so far.

  160. Statement on general licences by Wild Justice

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    Wild Justice was founded by Dr Mark Avery, Chris Packham CBE and Dr Ruth Tingay in October 2018. It exists to use the legal system on behalf of wildlife and to advocate for changes to laws to benefit wildlife. Our first legal case was a successful legal challenge of three long-standing general licences which ‘authorised’ lethal control of 16 bird species in England.

    On the day that Wild Justice was launched to the public, 13 February 2019, we sent a formal Pre-Action Protocol letter to Natural England challenging the validity of General Licences GL04, GL05 and GL06.

    We now learn that Natural England received legal advice, on 21 February,  that the Wild Justice challenge was correct. From that date Natural England knew that it must address the legal failings of its licensing regime. Whether two months of silence followed by a shock announcement of a sudden revocation of General Licences GL04, GL05 and GL06 will be regarded as a satisfactory response by a public body to finding that it was acting unlawfully is for others to judge. Three months after Natural England received its legal advice, the way ahead is still unclear and Defra has ‘taken control’ of the subject of licensed bird killing.

    In Scotland, following Wild Justice’s action in England, Scottish Natural Heritage is bringing forward a consultation on their very similar general licences and as yet no change to the licensing system has been introduced.

    Much of the outcry by certain shooting organisations and the media over Natural England’s actions has been ill-informed and ill-judged. Wild Justice does not think that the issue has been handled particularly well but we recognise that Natural England was unlikely to be praised by all however they dealt with revising an unlawful but long-standing licensing system.

    The transition period from an unlawful licensing regime to a lawful one which is fit for purpose started on 21 February but it is worth considering how a statutory regulator of wildlife law, Natural England, allowed an unlawful system to persist for so long. Species protection law is a fundamental cornerstone of nature conservation and Natural England’s job was to implement it properly. This is a failing of a public body that should be investigated. In Natural England’s recent evidence to the Efra Committee it was suggested that in 2014 Defra leant on Natural England to prevent changes to the bird-killing licensing regime. This goes to the heart of Natural England’s role and independence. We believe that this should be investigated. Owen Paterson and Liz Truss each occupied the role of Defra Secretary of State for parts of 2014.

    Wild Justice will be writing to Natural England asking them to clarify and correct certain aspects of their evidence to the Efra Committee and to explain their conduct to Wild Justice following the legal advice they received on 21 February. We will also write to the Efra Committee with information that they may find useful.

    But turning to the future. There is a gaping hole which the unlawful General Licences GL04, GL05 and GL06 used to fill. Now that Defra has taken responsibility for the licensing regime we await their proposals. Natural England had made a good start in issuing a timetable for the publication of a series of new general licences which would be both species-specific and issue-specific but this timetable is already in tatters thanks to Defra’s intervention. Three new general licences were issued by Natural England and have been criticised on a number of grounds by a variety of users of the licences. Without getting into the details, we can see that some criticisms of those new licences are valid and others are not. But having a series of licences that regulate the killing, only where necessary, of particular species is a difficult administrative task. Wild Justice will wait with interest to see what emerges from Defra’s cogitations and we have no fixed view at present, but it may be that general licences are a rather blunt instrument to deal with the complexities of this issue. We’ll have to see what Defra come up with.

    In any case, Wild Justice reiterates that there is no justification for new general licences which allow the lethal control of Jays, Jackdaws, Rooks or Magpies for the purpose of conserving fauna or flora. Killing those species for that reason is not scientifically justified.

    We envisage that there may be a long way to go before the issues identified as a result of our successful legal challenge are resolved satisfactorily. Wild Justice will play a constructive  part in the necessary discussions that must follow but reserves its right to take further legal challenges on this subject if necessary. Defra now has the opportunity to end the casual and unlawful killing of millions of birds and to restrict lethal control to those circumstances allowed by the law.

  161. Short statement by Wild Justice

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    Wild Justice noted with interest the Efra Committee meeting which took evidence yesterday from Natural England. 

    Wild Justice will make a fuller statement in the next few days. 

    Meanwhile, we learned with interest that Natural England had legal advice on 21 February that the General Licences GL04, GL05 and GL06 were unlawful. We note that this was not mentioned in NE’s response of 13 March to our formal Pre-Action Protocol letter of  13 February. We also note that NE announced the revocation of these licences on 23 April with effect from 25 April which was two months after they received that legal advice. 

  162. Questions for Natural England

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    Natural England’s Deputy Chair Lord Blencathra (who was Acting Chair at the time of the decision to revoke the General Licences GL04, GL05 and GL06), interim Chief Executive Marian Spain and new Chair, Tony Juniper, appear before the Environment, Food and Rural Affairs (EFRA) Committee on Tuesday 21 May 2019 (see here).

    Wild Justice contacted the EFRA Committee last week and offered any help that we could give, including that our lawyers were available to give evidence on the legal aspects of the case.

    We also suggested that the following questions would be germane to the Committee’s enquiry;

    • Had Natural England or Defra, before receipt of the legal challenge from Wild Justice on 13 February, ever had cause to be concerned about the lawfulness of General Licences GL04, GL05 and GL06? If so, what were the nature of those concerns and why weren’t they acted upon?
    • At what point after 13 February, when the Wild Justice Pre-Action Protocol letter was sent, did Natural England come to the view that the General Licences GL04, GL05 and GL06 were unlawful?
    • What communications occurred between Natural England and Defra over the legal challenge?
    • What legal advice did Defra give Natural England on the legal issues raised by Wild Justice between 13 February and 23 April?
    • What information was the Natural England Board given about the legal challenge at its meeting of 20 March?
    • What information was the Natural England Board given about the legal challenge at its meeting of 15 April?
    • When, and in what form, will the promised consultation on general licences take place and how will it differ from the rushed consultation by Defra which closed last Monday?

    We will watch with interest to see how this session goes.

  163. Thank you RSPB

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    Wild Justice is pleased, but not remotely surprised, to see that the RSPB has followed our lead on the general licence consultation and recommended that lethal killing of Jay, Jackdaw, Rook and Magpie should only be authorised by specific individual licences and not by new general licences.

    The science simply doesn’t exist which would justify widespread, open unmonitored lethal control of these four species.

    It’s hardly surprising that the RSPB opposes general licences for the lethal control of these four corvids as RSPB does not cull these species on its 150,000ha of UK nature reserves (the area of a smallish English county).

    Michael Gove is under considerable political pressure from shooting organisations, not as far as we have seen so far from farming organisations, to issue scientifically ill-founded general licences for lethal control of Jay, Jackdaw, Rook and Magpie but we trust he will stick with the science.

  164. Thank you GWCT

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    A few days ago we thanked BASC for their response to the Defra consultation on general licences because it clarified how ridiculous was their call for a reversion to the General Licences GL04, GL05 and GL06 which were revoked after Wild Justice’s successful legal challenge.

    Today we must thank the Game and Wildlife Conservation Trust (GWCT) for their submission which also appears to favour a reinstatement of the three discredited general licences although not in any way as positive or strident a way as that of BASC. In fact, it is somewhat difficult to find a recommendation for action in the GWCT response.

    Where GWCT say in their Summary ‘We highlight scientific evidence that predation control carried out under General Licences can lead to annual increases in breeding densities of a range of red-listed birds (e.g. grey partridges 35% increase per year, curlew 14% increase per year). We also highlight numerous case studies where farmland birds have responded positively to predation control.‘ they fail to disclose that the predation control to which they refer usually involved control of mammals as well as birds and rarely was able to distinguish between impacts of different bird species. The studies cited by GWCT, taken with other important studies which GWCT have neglected to cite, form no basis for any call to reintroduce a licensing regime for bird killing which allows the lethal control of Jay, Jackdaw, Rook or Magpie – the science for an impact of these corvid species on wild bird population levels is weak or non-existent.

    What follows is an evaluation of the GWCT argument, carried out by Wild Justice with the help of other scientists, and an assessment of the evidence against four corvid species.

    • An assessment and evaluation of the GWCT evidence:

    GWCT present a number of lines of evidence to propose that predator removal generally can improve breeding success and sometimes the population sizes of other species, but there is little evidence that deals with corvids explicitly and almost nothing on the impacts of individual species of corvid. Furthermore, GWCT give no consideration to other predator reduction methods. One of the conclusions of a recent major review of predation impacts (Roos et al. 2018), cited by GWCT, was that “Much more attention needs to be paid in future to landscape-scale measures to reduce predation impacts, such as changes in land-use configurations (e.g. removal of commercial forest plantations…), habitat management … and the re-establishment of populations of apex predators …, as well as a critical test of the environmental sustainability of intensive gamebird releasing that may cause trophic cascades…” [references replaced with ellipses]. A further general comment is that predator reduction or removal experiments of the kind that form the crux of GWCT’s evidence are often inherently biased by being undertaken largely in areas where it is supposed that there will be an impact; hence it is difficult to generalise their findings to other situations.

    We address GWCT’s arguments in turn here.

    1. GWCT cite as a “key reference” the study of Macdonald & Bolton (2008) [Predation on wader nests in Europe. Ibis 150: 54-73]. This exhaustive review of a large number of studies from across Europe documents around 3,000 nest predation events recorded by a variety of methods. The majority of predation events could not be assigned to individual predators, and were frequently recorded as nocturnal vs diurnal, or avian vs mammalian. Of those that could be assigned to individual species or species groups, corvids (specifically or generically) were implicated in just 38 (Magpie 1, “crow” 16, “corvid” 21). Of 200 nest predation events, predominantly in wet grassland, identified using nest cameras in which the identity of the predator could be established, 132 (66%) were by Foxes, 21 (10.5%) by Stoats, 15 (7.5%) by Crows, 12 (6%) by Badgers, 8 (4%) by Hedgehogs, and small numbers (2%) by other predators. The study concluded that “The use of temperature loggers initially, and nest cameras more recently, has shown that the widely held belief that birds (particularly corvids) are the major predators of wader nests is frequently not true.
    2. GWCT cite their Salisbury Plain and Otterburn predator removal experiments in defence of their stance on the issuing of General Licences, and showed that predator removal led to an increase in breeding success and populations of Grey Partridges (Salisbury Plain) and a number of upland breeding species (Otterburn). However, predator removal at both sites included mammals (Fox, Stoat, Weasel and Rat), as well as corvids (Carrion Crow, Magpie, Jackdaw and Rook). In both experiments, predator control significantly reduced densities of Foxes and Carrion Crows, but there was no assessment of the identity of nest predators before, during or after either experiment, so the impacts of corvid removal could not be assessed explicitly.
    3. Corvid removal studies are cited as evidence that “the ability to apply targeted corvid control at short notice can be beneficial, where breeding hedgerow nesting and probably other songbirds are exposed to breeding corvids”. They cite three lines of evidence:
      1. “In their recent comprehensive review Roos et al. (2018) state (in the abstract) that they found little evidence that predation limits populations of passerines but that they [sic] do limit waders. This, however, is not a full and balanced reflection of the results, and a key finding of the review, highly relevant to this call for evidence, is easily overlooked. Table 5 [actually Table 6], which refers specifically to experimental predator removal studies, shows songbirds increased in 40% of 20 studies following predator removal. For waders, it was similar, at 44% of 29 studies. The conclusion from this is that the science available prior to 2017 tells us that corvid removal can lead to an increase in songbird population size.” [our emphasis] We consider this conclusion to be an egregious misinterpretation of the data shown in Tables 5 and 6 of Roos et al., which relate to predator control/removal generally, and not corvid control/removal explicitly. Figure 4 of the same article indicates that the evidence that corvids alone can limit their prey numerically is no different from zero, and Table 7 shows that in only 13.6% of over 360 cases in which the effect of corvids on populations of their prey species have been assessed were the impacts found to be negative (and in 12% it was actually positive).
      1. The study of Sage & Aebischer 2017 is cited as evidence of a negative impact of corvids on nesting success of hedgerow passerines, although nesting success was measured only indirectly. This study, a rare example of a predator control/removal study that apparently controlled only corvids (though other predator control activities at the sites is not quantified), recorded very modest increases in apparent nesting success of 10-16% across all species with corvid control, but not for open nesters or hole nesters separately and with results that varied between sites – at some sites, nesting success was higher in the absence of corvid removal. The authors concluded that the impacts of this difference in nest productivity on overall population size of songbirds fell somewhere between unlikely and unquantifiable.
      1. The third piece of evidence is in the form of an unpublished PhD thesis, which we have not seen and therefore upon which we cannot comment, other than to note that one chapter appears to use artificial nests as a surrogate for real nests, a methodology that has come in for severe criticism (e.g. Moore & Robinson 2004, Ecology, 85: 1562-1567).
    4. GWCT cite their research at Loddington, Arundel and Royston, but this shares the same problems as the Salisbury Plain and Otterburn projects described above, in that predator control was general, including mammals as well as birds, that the identity of nest predators was not known, and that the impact of individual corvid species on populations of other species cannot be evaluated. White et al. (2008) concluded from their study of blackbird nesting success that “Although predator control appeared to have a positive influence on Blackbird breeding population size, the non-experimental set-up meant we could not eliminate other potential explanations”. There is a suggestion in White et al. (2014) (Loddington study) that the contribution of corvid control to the broader patterns noted was negligible: “Sporadic corvid reduction had a positive effect on nest survival only for common blackbird (at the nestling stage only) and a negative effect only for yellowhammer (across both stages)”.
    5. GWCT describe an unpublished study from the Avon Valley which suggests that unidentified daytime predators (presumed but not proved to be corvids) of Lapwing nests account for 41% of observed predation events or for 41% of all nests (the results are ambiguously presented). They describe a correlation between Lapwing nest survival and Carrion Crow density, but rightly point out earlier in their evidence that “statistically significant correlations do not indicate cause and effect and can be caused by unmeasured factors”. We have not seen this unpublished work so cannot comment further.
    6. GWCT describe an unpublished study from across the UK on breeding Curlews, finding that general predator control was associated with higher numbers and breeding success of Curlews. It is suggested that there is a negative correlation (the strength of which is not reported) between Curlew nesting success and Carrion Crow density. This evidence is used to “outline[s] the potential fate of one of the UK’s most threatened bird species if corvids are not legally controlled”, with the conclusion that “expanding predator management, particularly of corvids, currently done routinely on grouse moors, to peripheral unkeepered areas is a practical step that could quickly help stem the current rapid decline of curlew” [our emphasis]. It is not possible to assess from the data presented whether or not the presumption that crows are primarily responsible for the observed differences in numbers and breeding success is justified. However, the results appear to broadly support those of Douglas et al. (2014) [J. Appl. Ecol. 51: 194–203], who concluded that: “direct predator control may also be important to conserve ground-nesting birds in these landscapes, for example, where moorland management and forestry coexist as major land uses”.
    7. We cannot comment on the Member Responses as the claims made therein are not supported by empirical evidence.

    The GWCT consultation response does not cite a number of other relevant studies:

    Thomson et al. (1998) The widespread declines of songbirds in rural Britain do not correlate with the spread of their avian predators. Proc. R. Soc. Lond. B 265: 2057-2062. This paper analysed population trends of songbirds from 1965-1995 and assessed the likely impact of Magpies and Sparrowhawks. They concluded that: “magpies and sparrowhawks are unlikely to have caused the songbird declines because patterns of year-to-year population change did not differ between sites with and without these predators”.

    Newson et al. (2010) Population change of avian predators and grey squirrels in England: is there evidence for an impact on avian prey populations? J. Appl. Ecol. 47: 244–252. This paper, co-authored by GWCT, concludes that “Analyses of large-scale and extensive national monitoring data provides little underlying evidence for large-scale impacts of widespread avian predators and grey squirrels on avian prey populations, although we cannot exclude the possibility that a small number of negative associations between particular predator and prey species reflect causal relationships or that predators affect prey species at smaller spatial scales.” Writing explicitly of the impacts of corvids, the authors stated that: “For the corvids no significant negative associations were found.

    Madden et al. (2015) A review of the impacts of corvids on bird productivity and abundance. Ibis 157: 1-16. The authors of this review of 42 different studies found that: “Experimental studies that removed only corvid species were significantly less likely to show a positive impact on productivity than those removing corvids alongside other predators (16 vs. 60%). This suggests that the impact of corvids is smaller than that of other predators, or that compensatory predation occurs” and concluded that “These results suggest that in most cases bird populations are unlikely to be limited by corvid predation and that conservation measures may generally be better targeted at other limiting factors. However, negative impacts were found in a minority of cases, and those may require further investigation to develop management tools to mitigate such impacts where they are of economic or conservation concern.

    • Assessing the impacts of individual species: Jackdaw, Rook, Jay and Magpie

    It is very difficult or impossible to extrapolate from the many studies listed above the impacts of individual corvid species. In most studies on the effects of predator control, no information is given on how many of each species were controlled and none on the identity of nest predators, and hence it is often hard even to separate out the effects of bird vs mammal predation, let alone the contributions of individual bird species.

    Below we summarise the results of three key recent reviews (Macdonald & Bolton 2008, Madden et al. 2015 and Roos et al. 2018 – full references given above) on the potential impact of each species on the productivity and numbers of potential prey species.

    Jackdaw. Photo: Tim Melling


    This species is largely granivorous in winter and largely insectivorous in the breeding season, but in some situations, highly specialised individuals may take the eggs of other birds (Handbook of the Birds of the World).

    Macdonald & Bolton (2008) contains no explicit mention of Jackdaw, which was not identified as a wader nest predator in any study. Madden et al. (2015) identify one study of the possible impact of Jackdaw on productivity and four studies of the possible impact of Jackdaw on numbers of potential prey species; in all five cases, no impact was detected. Roos et al. (2018) also do not mention Jackdaw in the list of species whose impact on other species was assessed.

    Conclusion: GWCT do not make a case why Jackdaw should be killed under an unregulated open general licence. They do not present evidence that shows any serious impact of Jackdaw on bird populations, and we can find no such evidence. Without such evidence Defra cannot issue a scientifically valid general licence.

    Rook. Photo: Tim Melling


    Main food items include earthworms (Lumbricidae) and grain; a wide range of other small invertebrates also taken, notably beetles (Coleoptera) and cranefly larvae (Tipulidae), also such vertebrates as small lizards, frogs and small mammals, and eggs and nestlings of small birds (Handbook of the Birds of the World).

    Macdonald & Bolton (2008) contains only one explicit mention of Rook, from an unpublished doctoral study that suggested that while wader nest predation rates were higher near to rookeries, they were lower on sites with rookeries than on sites without rookeries. Neither Madden et al. (2015) nor Roos et al. (2018) identified any studies of the possible impact of Rook on the productivity or numbers of potential prey species.

    Conclusion: GWCT do not make a case why Rook should be killed under an unregulated open general licence. They do not present any evidence that shows any serious impact of Rook on bird populations, nor can we find any. Without such evidence Defra cannot issue a scientifically valid general licence.

    Jay. Photo: Andy Rouse


    Chiefly eats invertebrates during breeding season, notably caterpillars and beetles (Coleoptera) gleaned from foliage of trees; diet also includes eggs and nestlings of a range of birds up to size of a Sparrowhawk (Accipiter), much less frequently killing adult passerines, and is among the most frequent predators of other small birds’ nests in some areas; wide variety of seeds and berries eaten, especially in autumn and winter, including grain, beech mast, chestnuts and acorns. (Handbook of the Birds of the World).

    Macdonald & Bolton (2008) identified no studies of the possible impact of Jay on the productivity of wader nests, though differences in habitat selection are unlikely to bring Jays into contact with breeding waders. Madden et al. (2015) did not include Jay in their review. Roos et al. (2018) identified 59 cases where the evidence that Jay can limit prey species has been assessed. Of these, 3 (5.1%) indicated a negative impact of Jays, whereas 13 (22%) indicated a positive impact.

    Conclusion: GWCT do not make a case why Jay should be killed under an unregulated open general licence. They do not present evidence that shows any serious impact of Jays on bird populations, nor can we find any. Without such evidence Defra cannot issue a scientifically valid general licence.

    Magpie. Photo: Tim Melling


    Omnivorous, but chiefly a carnivorous scavenger. Diet varies according to local habitats, basically comprises invertebrates, especially beetles (Coleoptera), and small mammals and lizards, frogs, bird eggs and nestlings, as well as carrion and rarely even adult birds.

    Macdonald & Bolton (2008) identified Magpie as a predator of wader nests in just one study, in which it accounted for a single nest predation event. Madden et al. (2015) identified 41 cases where the impacts of Magpie on the productivity of potential prey species could be assessed, of which 4 showed a positive effect, 5 a negative effect and 32 no effect. Similarly they identified 96 cases where the impacts of Magpie on the numbers of potential prey species could be assessed, of which 6 showed a positive effect, 4 a negative effect and 86 no effect. Roos et al. (2018) identified 104 cases where the evidence that Magpie can limit prey species has been assessed. Of these, 6 (5.8%) indicated a negative impact of Magpies, 16 (15.4%) indicated a positive impact and 82 (78.8%) indicated no effect.

    Thomson et al. (1998) concluded that Magpies were not implicated in the decline of songbirds across the UK. Sage & Aebischer (2017) found a small effect of corvid (Carrion Crow and Magpie) removal on the nesting success of hedgerow passerines but could not demonstrate whether this was the result of the removal of Magpies or of Carrion Crows, suggesting that the former was more likely on ecological grounds. 

    Conclusion: GWCT do not make a case why Magpie should be killed under an unregulated open general licence. They do not present evidence that conclusively demonstrates a serious impact of Magpie on bird populations, nor can we find any. Without such evidence Defra cannot issue a scientifically valid general licence.

    • Summary

    We consider that the GWCT evidence fails to alter the case against the issue of General Licences for the control of corvids for the following reasons:

    1. The evidence of the GWCT’s own research does not and cannot, in almost all cases, distinguish between the impacts of corvids and the impacts of other bird and mammal predators. Other scientific literature is in several places misconstrued by GWCT to indicate an impact of corvids whereas the evidence being referred to relates to the impacts of general predator control
    2. Recent research indicates that mammals are generally much more important predators of birds’ nests than are corvids, but even for mammals there is scant evidence that nest predation influences subsequent population sizes
    3. The evidence of a number of key recent reviews is not considered in the conclusions reached; these generally conclude that there is no effect of corvids on the populations of other species
    4. The case against corvids generally is weak, but the case against individual species is either entirely lacking (Rook, Jay, Jackdaw) or almost so (Magpie).

    Nowhere in their submission do GWCT actually state that there is sufficient or strong evidence to justify lethal control of individual corvid species under the past or any future licensing system. Their review of the science insinuates that view but does not provide evidence for it.

    Useful visual from BASC consultation response.

    As Defra officials and Michael Gove look carefully at each cell in the Table usefully provided by BASC they must decide, on the basis of the science, whether there is scientific evidence to justify the issuing of licences for lethal control of each species, one by one, for the purpose of conserving wild birds etc. The GWCT response to the consultation will aid them in that it shows how poor is the case for lethal control of many corvid species.

    Wild Justice remains steadfast in its call to Defra not to issue future general licences which authorise the lethal control of Jays, Jackdaws, Rooks or Magpies for the purpose of conserving wild birds because the scientific evidence to support such a policy is either weak or, more often, entirely lacking.  The days of killing these four species under the pretence that such actions are backed by science or that they are an aid to nature conservation should be left in the past.

  165. Thank you BASC

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    Collared Dove – a serious threat to fisheries? Photo: Tim Melling

    We are grateful to BASC (British Association for Shooting and Conservation) for providing a very helpful visual aid to guide the progress of a review of the future of the general licences.  It is their Table 4 reproduced here – don’t bother with the details at the moment but just look at how Red the Table is.

    Table 4 from BASC submission to consultation on general licences.

    The table shows the magnitude of change that Wild Justice’s legal challenge has already had on licensed bird killing.  Ignore the details for a moment and just look at the colours.  The White areas were never covered by the revoked General Licences GL04, GL05 and GL06 and NE’s (Natural England’s) plan is that they wouldn’t be covered by the new ones either so we can regard them as ‘No Change’. There’s a lot of Red in the Table – these are areas where NE, after 10 weeks of consideration from receipt of our legal challenge could not come up with any argument for new licences.  BASC and GWCT (Game and Wildlife Conservation Trust) want all of the areas marked Red to be coloured Green – well it ain’t going to happen because there is no legal or scientific justification for that.  Both GWCT and BASC largely ignore the fact that NE has conceded that the previous licences were unlawful and ask for them to be reinstated.

    Let us consider what that would mean; BASC and GWCT apparently want a general licence which authorises unlimited and unsupervised killing of Collared Doves to prevent serious damage to fisheries! Under the wholly unlikely exceptional circumstances that Collared Doves ever do cause serious damage to fisheries then individuals could always apply for a specific licence to carry out lethal control of those Collared Doves just as they can at the moment under the equally unlikely circumstances that Willow Warblers are causing serious damage to fisheries!

    What Mr Gove needs to do is to look at every single Red box in the BASC table and ask his civil servants if there is any strong reason to change it from Red to Green – for most of those boxes he will find no justification whatsoever.

    Presumably NE have already done the equivalent of looking at this table and examining each cell dispassionately and rationally, that’s why this table has an awful lot of Red on it.  The cat is out of the bag – much of the rationale behind the revoked General Licences GL04, GL05 and GL06 was scientifically and legally flawed and it is right that it should change.

    Let us look at the three right hand columns which cover the ‘conservation’ justifications for general licensing of lethal control under the previous GL06. Let us take the middle of those three columns which relates to conserving wild flora.  We have checked with other wildlife conservation organisations and they have not submitted an angry and strident call for the Jay to be returned to a general licence to protect flora. Nor has anyone else in the real conservation community.  No, it is only BASC and GWCT who think that the conservation of flora requires an immediate return to the licensing regime of three weeks ago – and they are utterly wrong.

    Mr Gove will not need much Green ink when he comes to colour in his blank chart and decide on a future licensing scheme – he can leave most of the Red in place.

    Wild Justice’s own submission on the general licences dealt with the left hand of the three columns which related to the former GL06. This column is one of the most varied in colour with White, Red, Brown, Yellow and Green cells. Our submission dealt with whether it is appropriate to issue new general licences which authorise the lethal killing of Jays, Jackdaws, Rooks, Magpies and Carrion Crows for the purposes of conserving wild birds. Jays, Jackdaws and Rooks were clearly not regarded by NE as a serious threat to wild birds as they categorised them as Priority 3, coloured Brown in the Table, which indicated to us that NE themselves weren’t at all keen on issuing a new general licence for their widespread and unregulated killing. And that’s because there is no scientific justification for their widespread and unregulated killing in order to protect wild birds.

    If Mr Gove and his officials read through the submission from GWCT and BASC they will find no justification for colouring those cells for Jackdaw, Rook, or Jay in any colour than Red. NE were presumably too scared by the rural shooting lobby actually to colour those cells Red but they did the next best thing if you are a civil servant which is to colour them Brown, park them, and hope no-one notices.  Well, we have noticed! We haven’t yet seen any submissions from the BTO and the RSPB but we would be amazed, and quite frankly shocked, if they were asking for Jackdaw, Rook and Jay to be coloured in anything other than Red by Mr Gove.

    We believe that the scientific argument for not reinstating general licences for Jay, Jackdaw and Rook is unassailable and Mr Gove will find nothing in the BASC and GWCT submissions that would support such a move. And yet that is what BASC and GWCT demand alongside the reinstatement of landowners’ right to cull Collared Doves because of their serious impacts on fisheries!  These submissions are not conservation submissions, nor are they scientific submissions, they are submissions aiming to take licensed killing of corvids back into the nineteenth century where much of it resided until 23 April 2019.

    What about Magpie? Magpie is coloured Green in the table as NE had planned to issue a general licence for their lethal control.  The Wild Justice submission argued that there is no strong evidence for such a general licence and we stand by that. However, there is some evidence and most of it is laid out in the GWCT submission. We don’t believe that the science stacks up though to a case for a general licence for Magpie control. If we have time, and we may not as Mr Gove, in his rushed consultation has not allowed proper time for these matters to be examined or the facts to be laid out before him, but if we have time, we will set out a more detailed case for removing the Magpie from any general licence to conserve wild birds. But in short much of the literature reviewed by GWCT relates to control of Foxes and Carrion Crows as well as Magpies and we know that Magpies are the species for which there is least evidence of any impact on wild bird populations. And the Loddington case study falls into the category mentioned in our consultation response where we stated ‘Nor can it be a ‘problem’ if Species A causes a local and/or temporary decline in numbers of Species B if those impacts are balanced out by other local or temporary recoveries in numbers elsewhere or at other times. Only if Species A is responsible for a sustained decline in Species B can this be regarded as a conservation problem‘.  We stated this with studies such as Loddington in mind. As an antidote to Loddington is the RSPB experience at Hope Farm where no predator control is carried out and songbird populations have increased thanks to simple and effective habitat improvement that still allow that farm to operate at crop yields comparable with the local average.  One of the differences between Loddington and Hope Farm is that Loddington’s predators and carrion eaters have the advantage of large numbers of released gamebirds to feed on as carrion through the winter which is presumably an important driver for their high densities. 

    Whereas BASC and GWCT ask for the whole table to be coloured Green (so that the massive damage to fisheries caused by Collared Doves can be averted – yes, we are taking the mickey but only to illustrate the ridiculous nature of the demands from these two shooting organisations)  Wild Justice recognised that the Carrion Crow cell (in the column for conserving wild birds) should stay Green as there is some evidence for this species causing population level impacts on other species. That is where the science leads us. But Mr Gove should not just skip over this species without some thought. As our submission makes plain, the reasons that the UK has such high Carrion Crow densities is that activities in the countryside over which his department has control have caused that to happen. Changes to agriculture policy, absence of regulation of the number of non-native gamebird corpses available to carrion eaters, and the restitution of top predators to the countryside would all be measures that would reduce, perhaps completely eliminate, the everlasting need for lethal control of native wildlife.

    So the task in front of Mr Gove this week is not to colour in the table Green but to examine every cell in that Table and decide what colour the law and the science allow and demand.  That is what a proper review would entail and this important subject demands nothing less.  Mr Gove should also remember that specific licences are available to deal with any unforeseen, occasional, unlikely, departures from the general situation (and so anyone can apply for a specific licence if they feel that they have a case to control Collared Doves because of their serious impact on fisheries).

  166. Wild Justice response to consultation on general licences.

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    Today Wild Justice submitted a response to the Defra consultation on general licences – it is copied below.

    Wild Justice said:

    There is no scientific justification for general licences to be issued to kill Jackdaws, Rooks, Jays or Magpies for the purpose of conserving wild birds.  The science doesn’t show that these species have an important impact on native bird populations.  All four species were listed under the General Licence GL06 which was revoked by Natural England on 25 April in response to Wild Justice’s successful legal challenge.

    Response to Defra call for evidence on general licences – by Wild Justice

    Wild Justice

    Wild Justice is a not-for-profit company founded by Dr Mark Avery, Chris Packham CBE and Dr Ruth Tingay.  Our legal challenge demonstrated the non-compliance of Natural England when issuing the now-revoked General Licences GL04, GL05 and GL06.  This has prompted an urgent review of the licensing system. We are pleased that such a review is taking place as the revoked general licence regime was not only unlawful but also not scientifically robust and there is an urgent need for the licensing of bird killing to be overhauled.

    Our legal challenge

    Wild Justice sent, on 13 February, a Pre Action Protocol letter to Natural England claiming that the licences GL04, GL05 and GL06 which they had published on 1 January 2019 were unlawful as they did not allow Natural England to ensure that individual birds of the species listed were only killed after non-lethal means had been tried and/or properly assessed nor ensure that birds were only killed for the limited set of purposes set out in law. After considerable delay by Natural England, and an inadequate and ambiguous legal response by them (on 13 March) we lodged legal papers with the court seeking permission for judicial review of their decision on 21 March. On 23 April, Natural England announced the revocation of the General Licences GL04, GL05 and GL06 (from 25 April). Wild Justice had not asked for the revocation of these licences but had requested that once they expired on 31 December 2019 they would be replaced with a lawful alternative. If Natural England had simply complied with our request then the confusion of the last few weeks would not have occurred.

    Our successful legal challenge showed that Defra (and its predecessor departments) and Natural England (and its predecessor bodies) had been running an unlawful licensing regime since 1995.  We recognise that the current incumbents at Defra and Natural England did not bring this highly unsatisfactory state into being but that they are the people left holding the baby now.  However, species protection is a fundamental part of nature conservation and the fact that the government department and its agency with responsibility for wildlife protection have been operating an unlawful bird-killing regime is jaw-droppingly negligent.

    The legal background

    The laws protecting birds are the same today as they were three weeks ago when GL04, GL05 and GL06 were in place. Our successful legal challenge has not changed the law. What is happening now is the government is rushing to try to give effect to the law accurately in its licensing system.

    All birds are protected by law and have been for decades.  The legislators have been wise to do this but they also recognised that there must be circumstances, not the rule but occasional circumstances, when lethal control of protected birds is necessary and acceptable.  Some might argue even with this, but Wild Justice does not.  We accept that lethal control of some individual birds is at times necessary and that the existing laws allow this as an exception to the general protection given to all bird species.  The law stipulates that lethal control is to be used where there is no satisfactory alternative and there is an obligation on statutory agencies and government to ensure that non-lethal means are properly assessed.

    For the vast majority of bird species it is necessary to apply for a specific licence in order to carry out lethal control and, in England, Natural England operates that licensing system. The specific licences require an individual or entity to apply for a licence to kill a specific species (or species plural) up to a limited number of individuals for a specified purpose, eg a supermarket may apply for a licence to kill a single bird that has entered its premises, cannot be caught or encouraged to leave and is defecating on food.  This approach means that lethal killing is examined on a case by case basis and the statutory agency responsible has to make an assessment on the merits of each case. In contrast the General Licences GL04, GL05 and GL06 were simply published on the government webpage and were relied upon by an unknown number of individuals who killed an unknown number of birds but allegedly only for the purposes allowed by the law. Our challenge was not against the principle of general licences, but it is clear that the level of control of bird killing offered by specific licences is much greater than that for general licences. We do not contend that general licences cannot provide an efficient and effective way to regulate what would otherwise be unlawful bird killing, but it is obvious that the general licence approach has some drawbacks.

    This year, the scale of licensed killing of protected wildlife under specific individual licences emerged thanks to information requests by Mr Jason Endfield 7.  The numbers of birds killed every year under the revoked General Licences GL04, GL05 and GL06 are a matter of speculation but probably number millions of birds every year4.  Wild Justice is sceptical that all of this killing was legal.  Wild Justice believes that the licensing of killing of wildlife is such a fundamental part of Natural England’s public duties that it should report in some detail annually on the scale of killing that it has authorised through specific and general licences. 

    In the past, previous governments and agencies have seen it convenient to exempt some species of protected bird from the specific licensing system and set up the now-revoked General Licences GL04, GL05 and GL06 for bird killing. Until April there were 16 species listed on three now-revoked General Licences GL04, GL05 and GL06 which covered different conditions under which lethal control was authorised including serious damage to crops or livestock, protection of wild birds, human safety etc.  These are the same conditions that apply to the specific licensing system and Wild Justice recognises that these are lawful and generally acceptable reasons for lethal control after non-lethal methods have been tried/assessed as the law requires.

    The revoked General Licences GL04, GL05 and GL06 did not allow Natural England to ensure compliance with the law.  Any new system of licensing must do that.  We will set out our thoughts on the way forward below.

    The licensed killing of otherwise protected birds has fallen into disrepute and disrepair. Many in the farming and shooting communities have wrongly believed that the species listed on the revoked General Licences were ‘pest species’ and that they had free rein to kill them at any times and without any specific justification. This is not what the law allows and, we are sure, has led to the casual and unlawful killing of millions of birds over recent years.  The blame for this situation lies squarely with successive governments and statutory agencies who have not given sufficient priority to enforcing wildlife laws, publicising their content or ensuring compliance with them. 

    Thoughts and issues – towards a lawful and working licensing system

    All the above is by way of introduction to our comments on the request by the Secretary of State for evidence that will enable him to provide clarity for the future. We almost restrict our comments to the possibility of the Secretary of State issuing general licences that would authorise the lethal control of five species of corvid (Carrion Crow, Magpie, Jay, Jackdaw and Rook) to protect wild birds, as that is our particular area of expertise.  However, we make some general comments at the end and a specific point about the shooting of Woodpigeons.  In all that follows Wild Justice reserves its right to take a legal challenge on any future or past decisions by the Secretary of State or Natural England (depending on who is in charge at the relevant time).

    It is notable that most of the ‘problems’ addressed by the solution of killing otherwise-protected wild birds, under either general or specific licences, are human-bird conflicts. Serious damage to crops is where birds cause damage to human economic interests, likewise with livestock, spread of disease, human safety, human health etc. However, issuing a licence to kill one species of bird to protect another species of bird is another matter altogether. These species have evolved together (where native species) over thousands of years.  Generally speaking, we should let them get on with it and not pick winners and losers, and not side with either the predator or the prey. But at the very least there must be some identified ‘problem’ to be solved. That ‘problem’ cannot possibly be that Species A eats Species B if that is what they have evolved to do – that’s nature. Nor can it be a ‘problem’ if Species A causes a local and/or temporary decline in numbers of Species B if those impacts are balanced out by other local or temporary recoveries in numbers elsewhere or at other times. Only if Species A is responsible for a sustained decline in Species B can this be regarded as a conservation problem, and even then one would have to question how and why the ecological balance between the two species, which presumably has lasted for thousands of years, has been disrupted in our time – and the reason for that is likely to be caused by human intervention of some sort (eg habitat destruction or degradation).

    This may sound rather philosophical in nature but luckily we can park this argument for a while, as we consider the first four species one by one, as there is no good scientific evidence that Jackdaw, Rook, Jay or Magpie cause long-term sustained declines in population levels of their prey species and there is therefore no justification for issuing general licences which would allow for their control on the grounds of protecting wild birds: no general problem = no general licence in our view.

    Let us now take these species one at a time:

    Jackdaw. Photo: Tim Melling
    1. Jackdaw: we know of no evidence that would justify issuing a general licence for the lethal killing of Jackdaws for the purpose of conserving wild birds. Jackdaws are not causing declines in the population levels of other bird species. Newson et al2,12  did not even include this species in their list of predators to be considered in their analysis even though they would have had the data to hand.

    We know of no land-owning conservation organisation which killed Jackdaws regularly or in any numbers under the revoked General Licenceseg 9.

    We recognise that there might, unknown to us, be circumstances under which Jackdaws cause problems for species of conservation concern but if there are, these should be dealt with under the existing specific licensing system. We recommend that no general licence should be issued for the purposes of killing Jackdaws to protect fauna or flora.

    We recognise that there may be a case for authorising lethal control of Jackdaws because of serious damage to crops or livestock but that case, for serious damage, is for others to make. If such a case can be made then Defra must ensure that it is not used as a cover for more widespread casual killing of Jackdaws through prejudice.

    Rook. Photo: Tim Melling
    • Rook: we know of no evidence that would justify issuing a general licence for the lethal killing of Rooks for the purpose of conserving wild birds. Rooks are not causing declines in the population levels of other bird species. Newson et al2,12  did not even include this species in their list of predators to be considered in their analysis even though they would have had the data to hand.

    We know of no land-owning conservation organisation which killed Rooks regularly or in any numbers under the revoked General Licences eg 9.

    We recognise that there might, unknown to us, be circumstances under which Rooks cause problems for species of conservation concern but if there are, these should be dealt with under the existing specific licensing system. We recommend that no general licence should be issued for the purposes of killing Rooks to protect fauna or flora.

    We recognise that there may be a case for authorising lethal control of Rooks because of serious damage to crops or livestock but that case, for serious damage, is for others to make.  If such a case can be made then Defra must ensure that it is not used as a cover for more widespread casual killing of Rooks through prejudice. 

    In addition Defra must ensure that only Rooks killed under the provisions of the law (eg to prevent serious damage to crops) can pass into the human food chain.  Shooting Rooks for Rook Pie is not, as we understand it, legal under current legislation.

    Jay. Photo: Andy Rouse
    • Jay: we know of no evidence that would justify issuing a general licence for the lethal killing of Jays for the purpose of conserving wild birds. Jays are not causing declines in the population levels of other bird species. Newson et al2,12  found little evidence that predation by Jays affected the population levels of a large suite of potential prey species (mostly songbirds but also pigeons and Lapwing) and where there was any relationship it was often positive rather than negative.

    We know of no land-owning conservation organisation which killed Jays regularly or in any numbers under the revoked General Licences eg 9.

    We note that in a recent blog, the Chief Executive of the BTO, Dr Andy Clements, who is also a Board member of Natural England, wrote that ‘there may be insufficient scientific evidence to merit the inclusion of Jay on the licence list in order to conserve birds1.  We agree with this view although believe that there is no ‘may be’ about it and that the same argument applies to Jackdaw and Rook (above). 

    We recognise that there might, unknown to us, be circumstances under which Jays cause problems for species of conservation concern but if there are, these should be dealt with under the existing specific licensing system. We recommend that no general licence should be issued for the purposes of killing Jays to protect fauna or flora.

    We do not recognise any case for authorising lethal control of Jays because of serious damage to crops or livestock. 

    We recommend that no general licence is issued for the killing of Jays and that any rare circumstances that might arise when there is any such case should be dealt with under the specific licensing system.

    Magpie. Photo: Tim Melling.
    • Magpie:  we know of no evidence that would justify issuing a general licence for the lethal killing of Magpies for the purpose of conserving wild birds. There have been several large correlative studies of impacts of Magpies on various species of potential prey, mostly songbirds, but none has found any strong evidence for impacts – indeed there are often as strong evidence for positive impacts as negative ones2,6,12,15. Where it has been possible to attempt to disentangle the impacts of Magpies and Carrion Crows on prey species, these very strongly point to the Carrion Crow having a much greater impact than the Magpie, and the Fox is a bigger problem than the Carrion Crow11.

    We know of no land-owning conservation organisation which killed Magpies regularly or in any numbers under the revoked General Licences eg 9.

    We recognise that there might, unknown to us, be circumstances under which Magpies cause problems for species of conservation concern but if there are, these should be dealt with under the existing specific licensing system. We recommend that no general licence should be issued for the purposes of killing Magpies to protect fauna or flora.

    We do not recognise any case for authorising lethal control of Magpies because of serious damage to crops or livestock. 

    We recommend that no general licence is issued for the killing of Magpies and that any rare circumstances that might arise when there is any such case should be dealt with under the specific licensing system.

    Carrion Crow. Photo: Tim Melling
    • Carrion Crow: there is, in contrast to the four species above, evidence that Carrion Crows can cause problems for some species of conservation concern11 and Wild Justice recognises that, as a last resort, lethal control is allowed by the law and is sometimes warranted for nature conservation purposes.

    In contrast to the position with the four corvid species above, several conservation organisations do carry out lethal control of Carrion Crows on their land and receive criticism from many sides for doing so eg 9.

    However, the species on which Carrion Crows have a population-level impact are few in number and in all these cases the evidence points to Foxes being a larger problem than Carrion Crows11.  The evidence suggests that songbirds are not seriously affected by Carrion Crows; their impact seems particularly manifest with ground-nesting birds, but not all ground-nesting birds.  The main species of ground-nesting bird where some control of Carrion Crows appears to be justified, on conservation terms, by the science, are Curlew, Lapwing and Grey Partridge. These three species do not occur in all parts of England or in all habitats and so we question the wisdom of any nationwide general licence.  Killing Carrion Crows in Cornwall, for example, is of no value to the conservation of Curlew, Lapwing or Grey Partridge and such a general licence would be disproportionate. 

    We would be prepared to play a part in discussions to find a sensible way forward on this issue.

    But part of any sensible discussion would have to consider how it is that Carrion Crow and, for example, Curlew numbers now appear to be in conflict.

    We should first recognise that Carrion Crow numbers (and Fox numbers, for similar reasons) are much higher in the UK than in most European countries.  Our populations of generalist predators are noticeably out of step with those in other European countries.

    There are three main reasons, all of which are to do with man-made changes to the landscape, and all of which the Secretary of State has the power to reduce and/or ameliorate. Indeed, we would argue that addressing these issues at a strategic level amounts to a ‘satisfactory non-lethal alternative’ that the law requires, and that these measures are ones which only government can take. We would therefore suggest that the Secretary of State has a duty to implement these changes rather than authorise widespread lethal control of native species because their populations have been artificially inflated by man-made factors which are threefold;

    • Agriculture: intensive agriculture has made the landscape more attractive to successful generalist such as Carrion Crows at the expense of specialists like Curlew. For example, silage making will increase feeding opportunities for Carrion Crows and reduce breeding success of Curlews.  There are other examples.
      • Massive releases of non-native gamebirds: Over 50 million Pheasants and Red-legged Partridges are reared and released into the UK countryside each year. Around a third of them are shot so tens of millions each year die of other causes and are killed by predators or perhaps scavenged by predators after dying in road traffic accidents, of disease or other factors. This food bonanza, particularly over the winter period, is very likely to maintain high numbers of Carrion (yes, the clue is in the name ‘Carrion’) Crows, Foxes etc which then may predate species of conservation concern the following spring.  Feeding the problem and then attempting to control it through lethal means is ridiculous. Defra were asked in March 2014 by Labour MP for Corby, Andy Sawford, ‘What research has been done that addresses the range of ecological costs and benefits of rearing and releasing Pheasants for shooting? Does native wildlife benefit or is it harmed by Pheasant shooting? Does Defra have plans to do any such research?‘ and answered, ‘Defra has not assessed the impact of releasing pheasants or red-legged partridges on biodiversity and is not currently planning any research in this area due to other biodiversity research priorities.‘.
      • Lack of native predators: , if the UK had a more complete fauna of large predators then species like Goshawk would reduce Carrion Crow numbers and alter their ranging and feeding behaviour and reduce their impacts on species such as Curlew.

    The flooding of the countryside with non-native gamebirds, the continuing illegal killing of native predators and the conditions created by modern intensive agriculture are the ultimate conditions which have given rise to species declines whose proximate cause might be high predation by Carrion Crows (and Foxes). The solution may, in the short term be some targeted lethal control of some predator species in some places but the strategic solution, almost wholly in Defra’s gift, is better management of the countryside for wildlife (a vast subject but relevant to the National Park review currently being carried out by the Glover committee), strict regulation of gamebird releases leading to a very large reduction in numbers released each year and effective enforcement of the existing laws which protect predatory birds (and mammals).

    Conclusion: of the five corvid species considered above there is no good scientific evidence that four of the species (Magpie, Jay, Jackdaw and Rook) cause any population-level problems for nature conservation whatsoever. There is therefore no scientific justification for issuing open general licences for their lethal control in order to protect wild birds. For the Carrion Crow there is scientific evidence of a problem in specific circumstances but lethal control of Carrion Crows is addressing the symptoms of mismanagement of the countryside rather than their causes.  Defra is uniquely placed to address these underlying causes.

    General points:

    1. Failure to comply with Gunning principles: This consultation fails on two of the Gunning principles: Principles 2 and 3. On Principle 2 this consultation does not give sufficient information to allow intelligent consideration as it is vague about what it covers, it does not set out Defra’s plans or options, it does not state whether the Defra timetable or general intent for issuing licences resembles or has diverged from that set out by Natural England since 25 April and it makes no attempt to explain what the promised further consultation later in the year will cover that this consultation does not.  It’s a mess.  It also fails on Principle 3 as an announcement on a Saturday that responses must be received by the following Monday week when there is a Bank Holiday intervening leaves only five working days to consider this complicated subject. For postal submissions this leaves less than four full working days, depending on the time of the last post. Wild Justice could have prepared a more comprehensive response without these two failings in this consultation and we suspect that the urgency is more to do with Defra wanting to appear to be in control of things rather than any particular urgency on the ground now we have reached mid May which is after the main lambing period and after the period of damage to crops by most birds.
    2. Woodpigeons:  an unforeseen consequence of our successful legal challenge is that a spotlight has been thrown on the shooting of Woodpigeons. As far as we can make out, the shooting of Woodpigeons for ‘sport’ or for food is not authorised under any current legislation.  Woodpigeons that are legally shot, eg for the purpose of preventing serious damage to crops, may be sold as food. Any cursory reading of the shooting press will reveal that there is a lot of shooting of Woodpigeons for sport or commerce outside of the terms of the law.  This is presumably why, buried away in the recently-published GL31 is the phrase ‘IMPORTANT: this licence does not permit the killing of woodpigeons solely for commercial and/or recreational purposes, and only activities conducted in accordance with this licence are authorised. If there is evidence that this licence is being used inappropriately then Natural England may review this licence.’.  We believe that there is plenty of evidence that Woodpigeons were being shot for the purposes of commercial and recreational purposes before the revocation of GLO4, GL05 and GL06 and would be amazed if this is not continuing now – at a time when shooting of Woodpigeons to prevent serious damage to most crops is long gone (especially for Oil Seed Rape).  Now it may be that society thinks that Woodpigeons should be a species that can be shot for recreational or commercial purposes but that is not the current legal position as we understand it. Defra should take urgent and active steps to make this clear to stakeholders which go far beyond two sentences buried in GL31. Defra may wish to consider legislative change on this matter and if it does then it should take that opportunity to specify that only non-toxic shot should be used for these purposes in line with the recommendations of the Lead Ammunition Group report of 201510and the science laid out in the Oxford Lead Symposium of 201513.
    3. Non-native gamebirds: much lethal control of corvid species under the revoked General Licences Gl04, GL05 and GL06 was by gamekeepers rather than farmers. And much of that lethal killing will have been to protect non-native gamebirds (Pheasant and Red-legged Partridges) which are released into the countryside in their tens of millions each year4.

    The legal status of these species is problematic: whilst in captivity (eg rearing pens) they are classed as livestock. When released into the countryside they are classed as wild birds and form the stock of birds which are shot as gamebirds during their respective open seasons.  These wild birds (or at least the survivors after the shooting season) may be taken back into captivity at the end of the shooting season and revert to being livestock again. Natural England has already published a licence, General Licence GL26 which is a general licence for authorising lethal control of Carrion Crows, which treats gamebirds which are released but still being ‘tended’ as livestock.

    Of course, many gamebirds released in previous years survive as wild birds in the countryside and nest as ‘wild’ birds despite the fact that if it were not for annual massive releases of more of their conspecifics their populations would quite possibly dwindle away.  If Defra intends to issue general licences to kill large numbers of native birds largely to protect non-native birds which are destined to be shot at later in the year then it should make this perfectly clear in its licences.  

    • Mammals: Although the implementation of laws relating to killing of wild birds has been grossly inadequate the law has been clear and has a logical framework. In contrast the legal protection given to wild mammals in the UK is a hotchpotch with little clear rationale behind it. Defra might wish to look at these matters in the Environment Bill or elsewhere.
    • Poor regulatory framework for killing of wildlife: sport shooting is largely unregulated in the UK in contrast with many European countries where hunters and shooters need to be licensed, or the landholdings on which they shoot need to be licensed. No quotas are set for quarry species and there is no reporting of species-specific annual bags. The game shooting industry is the major source of wildlife crime against protected birds of prey. Government must do more to provide a strong regulatory framework, meaningful enforcement and publicity for good and bad practice.
    • Bird identification: many land managers (not all, by any means) have poor bird identification skills and will be uncertain about how to tell a Rook from a Carrion Crow (or even a Jackdaw, and probably a Raven).  There may well be many farm workers who do not know the difference between a Woodpigeon and a Stock Dove. This is an unsatisfactory state of affairs under which to issue general licences where the issuing authority cannot be sure that the users of the licences are capable of identifying the species correctly.
    • Wild Justice should have a seat at the table: we have seen much mention of meetings and phone calls between Defra and Natural England and stakeholder groups – we have had no communication from either Natural England or Defra on this matter (except a general email to stakeholders announcing this consultation) since we received Natural England’s email conceding the correctness of our legal challenge on 23 April. 


    1. BTO blog by Dr Andy Clements, 3 May 2019.
    2. BTO Press release. 2010. Are predators to blame for songbird declines?
    3. Defra response to letter from Andy Sawford MP, March 2014.
    4. Game and Wildlife Conservation Trust. 2018. How many birds are shot in the UK? Game and Wildlife Review 2017 pp. 41-2
    5. Game and Wildlife Conservation Trust. 2019. The impact of pheasant releases: balancing the positive with the negative.
    6. Gooch, S, Baillie, SR and Birkhead, TR, 1991. Magpie Pica pica and Songbird Populations. Retrospective Investigation of Trends in Population Density and Breeding Success.  Journal of Applied Ecology 28: 1068-1086  DOI: 10.2307/2404226
    7. The Guardian; Watchdog permits 170,000 wild bird killings in five years.
    8. The Gunning principles
    9. Harper, M (RSPB), 2018. The conservationist’s dilemma: an update on the science, policy and practice of the impact of predators on wild birds (5)
    10. Lead Ammunition Group – report to Defra.
    11. Madden, CF, Arroyo, A and Amar, A. 2015.  A review of the impacts of crows, ravens and Eurasian Magpies on bird productivity and abundance.  Ibis 157: 1–16 
    12. Newson, SE, Rexstad, EA, Baillie, SR, Buckland, ST & Aebischer, NJ. 2010. Population changes of avian predators and grey squirrels in England: is there evidence for an impact on avian prey populations.  Journal of Applied Ecology 47: 244-252 doi: 10.1111/j.1365-2664.2010.01771.x
    13. Oxford Lead Symposium.
    14. Roos, S, Smart, J, Gibbons, D and Wilson, J, 2018. A review of predation as a limiting factor for bird populations in mesopredator‐rich landscapes: a case study of the UK Biol Rev 93: 1915-1937
    15. Thompson, D, Green, RE, Gregory and Baillie, SR. 1998. The widespread declines of songbirds in rural Britain do not correlate with the spread of their avian predators. Proceedings of the Royal Society of London, B 265: 2057-2062

    Wild Justice, 9 Lawson Street, Raunds, Northants, NN9 6NG.

  167. Mr Gove, please stop the casual killing of Jays

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    Common Jay (Garrulus glandarius) collecting peanuts from ground (under feeder) UK. Photo: Andy Rouse

    Michael Gove has taken back control of issuing general licences from Natural England (possibly because Gove’s predecessors as Secretary of State had depleted Natural England’s staff resources so much that they couldn’t possibly cope with the work) and has issued a consultation on general licences.

    It is a muddled consultation issued on the Saturday of a Bank Holiday weekend and closing at 5pm tomorrow, Monday.

    At Wild Justice, we are preparing a formal, technical response to the consultation which we will submit tomorrow and which we will publish on this blog, and through our newsletter, tomorrow after the consultation closes.

    The consultation asks that membership organisations seek the views of their members and collate them – Wild Justice is not a membership organisation so we are asking members of the public to respond to the consultation with one simple ask, as follows:

    ‘Please Mr Gove, don’t allow the killing of Jays under any future general licences. There is no scientific or economic case for allowing this beautiful bird to be killed. On the previous discredited and revoked general licences the Jay was listed on all three of them suggesting that it might be a hazard to crops, livestock, human health, nature conservation etc. I note with pleasure that in the documents issued by Natural England before Defra grabbed back responsibility for these matters, that the plans for licensing of lethal control of Jays had shrunk to the possibility of licensing control for the purpose of protecting wild birds. There is no scientific case for this and I ask you not to issue a general licence for Jay-killing.

    The BTO Chief Executive Dr Andy Clements, who is also a Board member of Natural England, wrote that ‘there may be insufficient scientific evidence to merit the inclusion of Jay on the licence list in order to conserve birds’ and I agree with him, except I think it is even now obvious that there is no ‘may be’ about it.

    The RSPB, which manages over 150,000ha of land, and carries out limited predator control on its nature reserves, does not kill Jays because it sees no need and no conservation value in killing them.

    The science does not allow you, Secretary of State, to authorise an open general licence to kill Jays as there is no evidence of any conservation problem that such killing could possibly help to prevent.’

    If you do respond to the consultation then please remain polite. Here are the details of how to respond.

  168. The Wild Justice legal challenge to the general licences GL04, GL05 and GL06

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    Wild Justice’s first legal case was a challenge of the General Licences GL04, GL05 and GL06 which ‘authorised’ the lethal control of 16 species of bird. Similar licences have been issued each year, for many years, on 1 January. We initiated a formal legal process where we challenged the decision of a public body, in this case Natural England. The decision we challenged was the issuing of those three general licences. The legal system requires such challenges to be made in a formal way and completed within three months of the decision being challenged. So, in essence the clock started ticking on 1 January for any challenge of these general licences.

    Wild Justice’s legal success against Natural England had the following chronology:

    1 January – Natural England issued General Licences GL04, GL05 and GL06 on website.

    4 January – an information request was sent to Natural England about the decision-making process of issuing the licences.

    25 January – Natural England replied saying that no further assessment or consideration had been made for 2019 because no issues had arisen in 2018.

    13 February – “Pre Action Protocol” legal letter sent from Wild Justice’s lawyers to Natural England setting out why we considered the General Licences issued on 1 January, which ‘authorise’ killing of 16 bird species, to be unlawful.  In essence, these birds can only be killed under certain legal conditions and NE has to be satisfied that those conditions are met before issuing the licences.  NE had not satisfied itself of those things and so the licences are not lawful.

    Here is the letter;

    26 February – Natural England respond, a day ahead of the normal deadline for response, asking for two more weeks

    27 February – Wild Justice says – no, Natural England can have one more week.

    1 March – Natural England ask for an off-the-record, without-prejudice meeting with Wild Justice without lawyers present.

    11 March – Chris Packham, Ruth Tingay, Mark Avery and two lawyers meet Natural England for an off-the-record and without-prejudice meeting; Wild justice insisted that lawyers were present and we’re glad that we did, as our lawyers are wonderful and the discussion after the meeting would have been difficult without them having heard the discussion, and indeed been part of it. We cannot disclose the details of the meeting as we had agreed Natural England’s request for confidentiality but we are probably not pushing our luck to say that the meeting was polite and business-like.

    13 March – Wild Justice receives confused and ambiguous written legal response from Natural England which does not concede the legal argument, nor provide evidence for the legality of current system.

    Here is that letter:

    You can make your own mind up about this letter from Natural England. And remember this letter was received after four weeks when it should normally be sent after two weeks, and after a meeting with Wild Justice. Try these little tests of the letter. First, does it say anywhere that Wild Justice was wrong and that Natural England was going to fight this case through the courts with all its might? Second, does it say that Wild Justice was right and that Natural England was going to admit that the General Licences GL04, GL05 and GL06 were unlawful and undertake not to issue similarly unlawful licences in 2020 as requested by Wild Justice? We couldn’t find either position clearly stated in this letter and on the basis of the legal advice we received, and on the basis of the ticking clock which meant that we had just two weeks to complete the next stage of the legal process we put into place actions that would allow us to continue with the legal challenge.

    15 March – Wild Justice launches crowdfunder on Crowdjustice platform to raise funds for legal challenge – this was the first public mention of what the case was about – Wild Justice gave Natural England over a month of quiet contemplation to work out the implications of our challenge and its response.

    Mark Avery, one of the three co-directors of Wild Justice wrote on his blog ‘Our lawyers wrote to Natural England on 13 February but they only replied on Wednesday (after four weeks) and their response was confused and evasive. We’re not sure whether Natural England are admitting that they are presiding over an illegal licensing system or not! It may be that they are playing the Theresa May game of kicking the can down the road and hoping that something like a miracle happens but it’s terribly difficult to be sure. And the clock is ticking as we must file our arguments with the court in the next two weeks to be within time. In fact, it will be around my birthday, Brexit Day (perhaps) on 29 March that the legal case has to be filed. For me, this is a question of why the agency whose job it is to protect wildlife and uphold wildlife law, and its parent government department which has similar responsibilities, have allowed millions of birds to be killed unlawfully (according to our legal advice) for nearly four decades.‘.

    21 March – legal claim forms were issued in the court on behalf of Wild Justice asking for judicial review.

    25 March – crowdfunder reaches target of £36,000 in 10 days.

    23 April – Out of the blue Natural England announces revocation of three General Licences on 25 April and that, at least for now, anyone wanting to kill any of the species formerly listed on those General Licences will need to apply for and receive an actual licence from Natural England.  A review of the General Licences is planned.

    That’s how we got to the sudden, unexpected, and actually unrequested revocation of the three general licences GL04, GL05 and GL06 and the start of a process which should lead to better licences that authorise those actions which are allowed by the law. It appears that the licensing of lethal control of those species formerly included in the species lists og GL04, GL05 and GL06 is now very much up for review in the short and medium term. This must be a good thing and is actually long overdue.

    Wild Justice is pleased that its actions have stimulated a serious and urgent review of a flawed licensing system. Wild Justice will play a constructive part in that process, as you will see when we publish our response to the government consultation on general licences on Monday. However, even now we are looking at other cases where we can use the legal system on behalf of wildlife.

  169. Wild Justice blog

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    Hi there!

    We have a blog.

    We will be blogging.

    Watch this space.