Author Archives: MarkAvery

  1. Leading constituencies for our Woodcock petition

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    The leading constituencies supporting our Woodcock petition, so far, are as follows. As expected, they are mostly Conservative rural constituencies (with one former Conservative now sitting as an Independent) and the semi-rural Labour constituency of Sheffield Hallam.

    1. Derbyshire Dales, Sarah Dines MP115 signatures
    2. Thirsk and Molton, Kevin Hollinrake MP110 signatures
    3. North Norfolk, Duncan Baker MP110 signatures
    4. Sheffield Hallam, Olivia Blake MP102 signatures
    5. Somerton and Frome, David Warburton MP – 99 signatures
    6. South Norfolk, Richard Bacon MP – 97 signatures
    7. Torridge and West Devon, Geoffrey Cox MP94 signatures
    8. Suffolk Coastal, Therese Coffey MP – 92 signatures
    9. Skipton and Ripon, Julian Smith MP – 92 signatures
    10. Stroud, Siobhan Baillie MP91 signatures

    And bottom of the list still, with not a single signature so far, still, is Birmingham, Ladywood, Shabana Mahmood MP

    We’re on 20,600 signatures, nearly (tomorrow) a month into the six-month life of this petition, and just over a fifth of the way to 100,000 signatures – but it’s a long road to a parliamentary debate.  We’ll keep you updated on progress.

    Please help to promote this petition – click here

  2. Our Woodcock petition – the leading constituencies

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    The leading constituencies supporting our Woodcock petition, so far, are as follows. As expected, they are mostly Conservative rural constituencies (with one former Conservative now sitting as an Independent) and the semi-rural Labour constituency of Sheffield Hallam.

    1. Derbyshire Dales, Sarah Dines MP102 signatures
    2. Thirsk and Molton, Kevin Hollinrake MP99 signatures
    3. North Norfolk, Duncan Baker MP96 signatures
    4. Somerton and Frome, David Warburton MP95 signatures
    5. Sheffield Hallam, Olivia Blake MP90 signatures
    6. Torridge and West Devon, Geoffrey Cox MP87 signatures
    7. Dumfries and Galloway, Alistair Jack MP84 signatures
    8. Stroud, Siobhan Baillie MP83 signatures
    9. South Norfolk, Richard Bacon MP82 signatures
    10. Suffolk Coastal, Therese Coffey MP81 signatures
    11. Skipton and Ripon, Julian Smith MP81 signatures

    And bottom of the list still, with not a single signature so far, is Birmingham, Ladywood, Shabana Mahmood MP

    We’re on 17,500 signatures, not yet a month into the six-month life of this petition, and over a sixth of the way to 100,000 signatures – but it’s a long road to a parliamentary debate.  We’ll keep you updated on progress.

    Please help to promote this petition – click here

  3. Defra’s vague and evasive response to our Woodcock petition

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    Our petition seeking an important change to the Woodcock shooting season has received a response from DEFRA – it’s a poor response which is pasted below in seven numbered paragraphs but it amounts to 25 words highlighted in red.

    We’re not satisfied with this as a response and Chris Packham has written to the Petitions Committee asking them to exercise their power to seek a proper response from DEFRA.

    We’ll also now be seeking further signatures to the petition to increase the pressure and we ask you for your help in promoting the petition widely to gain more signatures.

    There is still time for DEFRA to act before the shooting season opens, prematurely, on 1 October. We still want that date pushed back to 1 December as has been recommended by the Game and Wildlife Conservation Trust of all people.

    Here’s what Chris Packham wrote to the Petitions Committee:

    Dear Petitions Committee

    I am writing in response to Defra’s response to the Wild Justice petition to limit the shooting season of Woodcock (Petition 619615).

    The DEFRA response is not a proper response to our petition – most of it is just faff and padding. It is the type of response that will turn the public off engaging in the petitions process because it treats their request with disdain and entirely avoids addressing its key issue. Actually it’s insulting. So could I respectfully ask the Petitions Committee to solicit a proper response from DEFRA and ask for it to be provided as a matter of urgency because as it stands there is still time for DEFRA to adjust this year’s shooting season for this seriously threatened bird.

    DEFRA’s response amounts to the 25 words highlighted in red below. It says that it doesn’t think that shooting is relevant but gives absolutely no science or evidence to back up this view. Nothing. This is unsatisfactory . . . it implies that Government could write down any old unjustified stuff to brush off petitions that are hugely supported by the public . . . and this would render the whole petition process pointless. It’s lazy, counterproductive, undemocratic and betrays a lack of accountability. But DEFRA are accountable to the public, the public who signed this petition. They need to get out of bed, summon some respect and prepare a proper reply.

    In fact, as DEFRA must well know, and as spelled out in the link provided in our petition, the Game and Wildlife Conservation Trust recommend (on the basis of their own research) just what we suggest – that shooting of Woodcock should not start until 1 December rather than the current 1 October. Our petition asks that this is made a legal condition of shooting by changing the opening of the shooting season. This has not been in any way addressed by their response . . . Instead their response blathers on about grants, plans and schemes which are not yet running, may never run, and have not been practically tested in any regard for positive conservation outcomes and certainly not for Woodcock. Whereas what our petitioners request could be actioned now, for nothing, and the science says it would help.

    Thus our petition is specific and scientifically well-informed whereas DEFRA’s response is vague and evasive – we ask for a specific well-justified government action, DEFRA waffles on about lots of other things it is doing or might possibly do. Thus this response is not adequate, like I said , it’s insulting and inadequate.

    If this is how DEFRA responds to well justified conservation measures that can so easily, very cheaply and certainly quickly be implemented then we stand absolutely no chance of meeting the legally binding target of stopping wildlife decline by 2030.

    I append the Defra response with further comments on its shortcomings below.

    Best wishes

    Chris Packham

    In brief, paragraph by paragraph of DEFRA’s response: para 1, true but not a response to the petition and not specific to it, and promising nothing concrete; para 2, true but forms the background to our petition and is not a response to it; para 3, true, and is relevant to our petition but is not a response to it; para 4, DEFRA claims that many factors may be at play, they might be, but we have pointed to one simple government action that would address one factor and DEFRA has not ruled it out with any evidence, in fact it ignores the evidence that has led GWCT and ourselves to want shooting not to start until 1 December, therefore this is an inadequate response; paras 5-7, these all relate to aspirations to create or restore priority habitat in general (not necessarily habitat for Woodcock in particular) and planting trees won’t create habitat for woodcock until those trees are woodlands. This is an inadequate response and is not specific to our petition. They amount to saying ‘We’re doing some general stuff, or at least we might do in future, so we can’t do this very easy and simple thing that will help this species now’.

    The DEFRA response:

    1. Defra published a Nature Recovery Green Paper considering options for reforming protection to better support the recovery of species, such as woodcock.
    2. All wild birds are protected in accordance with the provisions set out in the Wildlife and Countryside Act 1981. Some species of birds, including the woodcock, are listed in Schedule 2 of the Act, and may be hunted during the open season. In England and Wales, the open season for woodcock is from 1 October to 31 January. Outside of this period, the close season helps to make sure that woodcocks are able to breed successfully and move between breeding and wintering grounds.
    3. The first breeding woodcock survey was undertaken in 2003 and estimated a breeding population of 78,000 pairs in Britain. A further survey in 2013 estimated 55,000 pairs, representing a decline of 29%. As a result, the woodcock has been on the red list of Birds of Conservation Concern in the UK since 2015. During winter, our resident birds are joined by migrants from breeding populations in northern Europe and western Russia, increasing the Great Britain non-breeding population to 1.4 million individuals.
    4. The reasons for the decline of the breeding population of woodcock in Great Britain are not fully understood but are likely to include: disturbance; habitat loss as a result of land drainage; the drying out of natural woodlands; changes in surrounding woodland management; the maturation of new plantations; and overgrazing (reduction of the field layer) by deer. While further work is needed to enhance our understanding, the Government’s current view is that the woodcock population is more likely to be influenced by the extent and quality of habitat, rather than shooting. We will continue to keep this evidence under review.
    5. Woodcock will be supported by a number of measures already in train. We are committed to the recovery of species in England, and that is why within the Environment Act 2021 we have set a new legally binding target to halt the decline in species abundance by 2030. Since 2010, 364,803 football pitches of new priority habitat has been created or restored and we will continue to build on this as we develop the Nature Recovery Network. Furthermore, Defra published a Nature Recovery Green Paper consultation on proposals to support our ambitions to restore nature and halt the decline in species abundance by 2030. The consultation has now closed. We are considering the responses to the consultation and the Government will publish its response in due course.
    6. The woodcock will benefit from a number of woodland grant schemes funded by both the Countryside Stewardship scheme and the Nature for Climate Fund, some of which specifically target management for declining woodland birds. These grants include the Woods into Management Forestry Innovation Funds, which aim to restore vulnerable woodland habitats, improve biodiversity and conserve threatened species, as well as the England Woodland Creation Offer.
    7. More broadly, environmentally sustainable farming is fundamental to our agricultural transition outside of the EU. We are introducing three environmental land management schemes: the Sustainable Farming Incentive, Local Nature Recovery, and Landscape Recovery. These schemes will pay for activities to create, manage and restore habitats such as woodland, connecting isolated habitats to form networks, and species management, all of which will benefit woodland bird species, such as the woodcock.
  4. Hen Harrier Fest – Thank you for coming!

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    Photo by Hugh Warwick

    A big thank you! To the hundreds of you who turned out in the rain, stood in the rain, listened in the rain and cheered… in the rain! Hen Harrier Fest was a day of inspiration, shared joy, collaboration and hope – as well as just a little bit of sogginess.

    Hen Harrier Fest took place this Sunday. The gates opened shortly before the heavens, and an anorak-sporting crowd descended upon the beautiful grounds of Adlington Hall and Gardens in Cheshire. Our fantastic host, Camilla Legh, welcomed us to the Hall which proved to be a brilliant venue for the day – we’re really grateful to Camilla and her team for having us!

    Throughout the day a suite of passionate, knowledgeable and articulate speakers took to the stage – covering everything from the right to roam, to beavers; from the plight of Hen Harriers to inspiring nature poetry. We’d like to say a big thank you to lots of people who brought the day together.

    Thank you to all of our speakers for their time and dedication:Jenny Shelton (RSPB), Indy Kiemel Greene, Dr Cathleen Thomas (Hen Harrier Action), Natalie Bennett, Brittany Maxted (Poole Harbour Ospreys), Guy Shrubsole (Right to Roam), Sandra King (Beavers Trust), Olivia Blake (Labour Party), Hugh Warwick, Gill Lewis (Hen Harrier Action), Megan McCubbin and Carol Day (Leigh Day).

    Thank you also to our superstar team of volunteers – whether it was helping cars park, making children’s crafts or building make-shift rain shelters, your support made the day such a success!

    And a big thank you to all of the organisations, charities, groups and caterers who brought their stalls and tasty treats to keep the crows entertained.  

    To those of you who came – thank you! We hope you had a great day and have managed to dry off. We’ll leave you with some photos of the day, kindly taken by Guy Shorrock and Hugh Warwick. Scroll through our gallery below (click the little arrows either side of the image), and please share yours with us on social media!

    Photos by Guy Shorrock and Hugh Warwick

  5. Woodcock shooting in England opens in 75 days unless Defra acts

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    https://www.woodcock-hunting.com/shoot-details/woodcock-shoot-north-devon/61

    There’s a remarkable amount of ignorance about Woodcock shooting – even among shooters. We’ve been told several times since we started our petition to shorten the Woodcock shooting season that nobody shoots Woodcock these days. Well that must be news to this shoot in North Devon advertising Woodcock shooting starting from 1 October even though the Game and Wildlife Conservation Trust advice is;

    You’ll note that this is a Woodcock shoot, specifically targetting (literally) Woodcock, and from 1 October. It also claims to be ‘a very popular shoot and days go quick’.

    Here’s another one which states that the best time to shoot is November-January. It’s specifically a driven Woodcock shoot with access to a ‘tailor-made Woodcock estate’ where 70-100 Woodcock can be killed in a day – that’s what they are selling here;

    https://www.woodcock-hunting.com/shoot-details/driven-woodcock-hunt-in-somerset-nr-taunton/24

    Here’s another example , this time in Cornwall where a lot of Woodcock shoots can be found.

    https://www.woodcock-hunting.com/shoot-details/woodcock-shoot-near-lauceston-cornwall/62

    Woodcock shooting in England opens in 75 days time on 1 October, that’s 61 days earlier than the science says is sensible, unless Defra acts now to change the shooting season.

    Please sign our petition to put back the Woodcock shooting season until 1 December as recommended by the science – click here.

  6. Our new petition – thank you for such great support

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    On Tuesday morning we launched our newest petition, to the Westminster government, asking for a shortening of the Woodcock shooting season. By Tuesday bedtime the petition had far surpassed the 10,000 signatures needed to trigger a response from the Westminster government. We’re keen to see what our environment department, responsible for wildlife conservation, says about our very modest, cost-free and science-led proposal. We wrote to the Department for Environment, Food and Rural Affairs and the Northern Ireland Department of Agriculture, Environment and Rural Affairs on 21 March on this subject and they have both been dragging their heels so this petition is a sharp nudge in the ribs to make them address this need.

    Even the pro-shooting Game and Wildlife Conservation Trust favour a delay in shooting but their rather quiet pleas to shooters have not been heeded, and now, it seems that GWCT is resiling on their advice for non-scientific reasons – their position is comical.

    This is a UK issue and is highly appropriate for a UK petition. Our letter was copied to the politicians in Wales and Scotland with responsibility for these issues and for there to be progress in Britain we assume that discussions would need to take place between Westminster, Cardiff and Edinburgh.

    We’ve been asked why we aren’t asking for an outright ban of shooting – this Twitter thread is relevant to that question – click here.

    Seven weeks today, on 1 September, the Woodcock shooting season will open in Scotland, and a month later in England, Northern Ireland and Wales. Whereas the best scientific advice is for shooting not to start until 1 December. This can be remedied very easily, just about at the stroke of a pen if politicians act. We want them to act.

    And so do you, as the reception to our petition shows. 648 out of 650 UK parliamentary constituencies have contributed signatures to this petition (only West Tyrone and Birmingham Ladywood are missing) and here are the current leading constituencies:

    1. North Norfolk (Con) 79 signatures
    2. Sheffield Hallam (Lab) 76 signatures
    3. Thirsk and Moulton (Con) 76 signatures
    4. Somerton and Frome (Independent) 75 signatures
    5. Dumfries and Galloway (Con) 72 signatures
    6. Derbyshire Dales (Con) 71 signatures
    7. Suffolk Coastal (Con) 71 signatures
    8. South Norfolk (Con) 66 signatures
    9. Westmorland and Lonsdale (LibDem) 65 signatures
    10. Stroud (Con) 65 signatures

  7. Please respond to Northern Ireland consultation on General Licences

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    We’d like to invite you to take c20 minutes to respond to a consultation on general licences in Northern Ireland. It is important that you do (please) respond because otherwise improvements to the licences that we have achieved through our successful legal challenge  – see here – might be lost. Also, we feel there is more to be gained if we can secure a strong response.  Anyone, living anywhere in the UK can respond to the consultation but if you do live in Northern Ireland then your response will probably be even more valuable.

    There are 45 questions but not all of them need to be answered and some require only a choice between YES and NO although a few words of explanation would probably be useful too.

    Here is the link to the consultation – click here – and the closing date is Thursday 21 July which gives you 13 days, including two weekends, to find the time please.

    The questions are grouped in four sections; one for each of the three general licences and a few general questions at the end. Wild Justice is most concerned that the so-called conservation licence is reformed properly – if you are strapped for time then please at least answer questions 30-38.

    OK.  Deep breath!  Let’s go!

    Q1-5 – these are simple and about you.

    Q6-17   General Licence TPG1 – preserving public health or safety.

    These 12 questions relate to 12 species of bird and ask whether each should be included on this general licence. The answer for each, we suggest, is NO. [Feral Pigeon is the only species listed on the equivalent licences for Scotland and Wales, Feral Pigeon and Jackdaw are listed for the England equivalent licence. Northern Ireland is suggesting removing 3 gull species, Rook and Wood Pigeon from the  licence but we believe that House Sparrow, Starling, Hooded Crow, Carrion Crow, Jackdaw and Magpie, as well as Feral Pigeon, should also be removed].

    So please tick the box NO for every species and, if minded to, add the following words in the boxes for the following species:

    Feral Pigeon ‘An individual licence could be issued if there were a good enough case.‘  

    All other 11 species ‘An individual licence could be issued if there were a good enough case. General licences for this species for this purpose do not exist anywhere else in the UK.

    Q18-29  General Licence TPG2 – protection of livestock, crops etc

    These 12 questions relate to the same 12 species of birds and ask whether you think that a general licence should exist to enable them to be controlled to protect crops and livestock etc.

    Wild Justice would, at this stage, live with general licences for 5 of these species and would tick the box YES (but you may disagree and should go with whatever you think). For the other 7 species we suggest the following words to go in the boxes.

    YES Hooded Crow, Carrion Crow, Rook, Wood Pigeon and Feral Pigeon – as we believe they can cause damage to crops (pigeons and Rooks) or can attack livestock (the crows).

    NO Great Black-backed Gull, Lesser Black-backed Gull, Herring Gull,   with the words ‘An individual licence could be issued if there were a good enough case.’  

    NO Magpies and Jackdaw with the words ‘No evidence of such an impact. An individual licence could be issued if there were a good enough case.‘  

    NO  House Sparrow and Starling  with the words ‘An individual licence could be issued if there were a good enough case. General licences for this purpose do not exist anywhere else in the UK. No evidence for such an impact. This is a Red-listed UK species.

    Q30-38  General Licence TPG3 – the ‘conservation’ licence

    These questions relate to just 9 of the species.

    Wild Justice would, at this stage, live with general licences for just 2 of these species and would tick the box YES (but you may disagree and should go with whatever you think). For the other 7 species we suggest the following words to go in the boxes.

    YES  Hooded Crow and Carrion Crow – as we believe that they can have serious impacts on some endangered breeding waders such as Curlew.  

    NO  Great and Lesser Black-backed Gulls   with the words ‘An individual licence could be issued if there were a good enough case. General licences for this purpose do not exist anywhere else in the UK.

    NO Jackdaw with the words ‘An individual licence could be issued if there were a good enough case. Jackdaw has been removed from similar general licences in England and Wales recently – Northern Ireland should do the same.

    NO Magpie with the words ‘An individual licence could be issued if there were a good enough case.  Magpie was removed from the Welsh general licence this year – Northern Ireland should do the same

    NO  Rook, Wood Pigeon and Feral Pigeon  with the words ‘No evidence of any conservation impact whatsoever. General licences for this purpose do not exist anywhere else in the UK.’

    Q39 – 44  Some general questions

    Q39-40 Skip, unless you have any particular expertise or views

    Q41 YES with the words ‘That is what the law requires. Lethal methods should only be used as a last resort.‘ 

    Q42  NO  with the words ‘Northern Ireland should follow the same process as in other UK nations. Designated sites are extra special and should not be places where unregulated, unmonitored, unjustified and unlimited killing of wildlife can take place.

    Q43  NO

    Q44  ‘Yes. Follow Wales and limit use of conservation general licence to breeding season and only to protect a published list of species of conservation concern.’

    Q45  Over to you.  

    And you’re done so you can submit your response.  Closing date midnight 21 July.  Thank you.

    Such consultations are a bit tedious but we know that vested interests such as shooters will respond to the consultation and put pressure on the Northern Ireland authorities to go backwards rather than forwards.  

  8. Join us for Hen Harrier Fest, 24th July 2022!

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    Hen Harrier Fest will take place at Adlington Hall & Gardens in Cheshire on Sunday 24th July, and we’d love to see you!

    If you’re planning to attend, please register on our Hen Harrier Fest webpage, where you’ll also find lots of other information about this event.

    We look forward to seeing you there!

  9. Our ‘right of reply’ letter in The Field magazine

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    In April this year, The Field magazine published an inaccurate and unpleasant article about Wild Justice, authored by Tim Bonner, CEO of the Countryside Alliance.

    We asked the editor for a right of reply, either as our own comment piece or as a letter. The editor allowed us to submit a letter as a right of reply, limited to 500 words and subject to editing.

    That letter has now appeared in the July 2022 edition of The Field:

    The endless attacks on Wild Justice, either as an entity or on its three Directors as individuals, are what we’ve come to expect (e.g. see here, here, here, here, here, here, here, here, here, here, here, here, here). The level of abuse over many, many years reflects the impact of our campaigning and legal challenges and we won’t be deterred by what is quite obviously a widespread attempt to undermine our integrity and standing.

    Judging by the speed with which our most recent legal challenge was crowdfunded (over £40K raised in a single day), neither will our supporters.

    Thank you all for your continued backing and encouragement.

    If you would like to support the work of Wild Justice despite the ongoing abuse towards us, or maybe because of it, then you can donate to our work here and/or subscribe to our free newsletter here.

  10. Your comments when donating to yesterday’s crowdfunder

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    Thank you!

    Yesterday, between 0530 and 2030, 1519 people donated over £40,000 to ensure that we can pay our brilliant legal team (and court costs and, if we lose, adverse costs against us) for the work they’ve done so far on this challenge. That has involved legal research, talking to experts, preparing a formal legal letter (see here – it’s not just a friendly note!) and filing a much more detailed legal case which sets out a statement of facts and grounds for judicial review.

    Thank you to all who have made that possible – and we loved the comments that you made. Here are just a few examples:

    Sheila – Thank goodness for Wild Justice. I would be in complete despair if you were not here to defend our beautiful wildlife & environment. I am so worried for our flora & fauna. Thank you for all that you do. You are heroes.

    Judi – Long awaited action and from people who get results! Bravo, wish I could give more.

    Chris – Great work I think for many reasons this is the most important fight you are taking on.

    Colin – Fully supportive. Enforcement seems to have been sacrificed on the altar of low taxes! Regulators must do their jobs effectively.

    Anon – So important, the profits need to go to upgrading the sewerage system and not to shareholders. Increased population demands it.

    Jacqui – I live close to the Thames at Maidenhead and can often see discharges floating down it. It needs to be much cleaner to protect local people and wildlife.

    Mark – I am a kayaker, wild swimmer and love to see our waterways from the water. With its rich and varied wildlife both in and living from the water all this is at risk because of sewerage plants up and down the country. Thank you for fighting for our beautiful waterways.

    Mark – Thank you for your good work – which should be unnecessary if government did its job properly.

    Michael – I expect every other angler in Britain to support this action, with their cash.

    Linda – Water is the life blood of this planet and imperative that we keep it clean.

    Carol – Good luck! We need a clean up!

    Andrew – I am proud to be associated with the good work that you do.

    Richard – Good luck, team. Stop regulators becoming Government stooges.

    Joanna – Excellent work as usual. Love what you are doing and will always chip in if I can. Thank you so much.

    Sarah – Thank you for taking on this challenge – it is essential work to call the regulatory bodies to account.

    Brian – Live by the Wye, which has virtually died in last few years.

    Gwenllian – I am so glad that I read the article in the Guardian this morning and followed the crowdfunding link.

    Steve – The UK’s record on environmental security and preserving biodiversity is bad enough as it is without Ofwat failing to do its job.

    Colin – Thank goodness someone is holding the dysfunctional Government Agency Ofwat to account for their fecklessness.

    Vivian – Time to link Shareholders dividend to the amount of sewage discharge each company makes. The more discharges the less money available for Shareholders. That would soon put a stop to such practice.

    Anon – Good luck fighting this. Its disgusting how much is being pumped into waterways.

    Janet – Thank you for speaking on behalf of all of us who deplore the dumping of sewage in our waterways. Disgusting acts of vandalism. This has to stop.

    Andrew – I make this donation because I know that Wild Justice’s campaigns are effective and powerful.

    Susan – So sorry I can’t donate more x

    Anon – Isn’t it ironic that citizens have to mobilise and self-fund to challenge and make accountable a government body, funded with tax payers’ money, that should make companies that are getting away with environmental murder accountable but doesn’t.

    Anon – From the Guardian 22 May 2022, about the rivers where I live. “Only one popular river spot for bathing and water sports in and around Oxford has bacteria within safe levels, a survey by a campaign group has found”.

    Liz – I really applaud your efforts and get up and go to challenge Ofwat on this. Hats off to you. Amazing job and thank you. As an open water swim in both lakes and the sea, the work you’re doing is so important trying to maintain our biodiversity and health.

    Paula – What would we do without you. Thank you.

  11. A new ambitious legal challenge – Ofwat where are you?

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    You don’t need to be an expert to know that dumping raw sewage into rivers, lakes and the sea is bad news for those who use our waterways – from fish to those who want to take a dip in the water. And yet untreated sewage was discharged into watercourses over 350,000 times in each of the last two years.

    We wrote to Ofwat (the water services regulator for England and Wales) back in April telling them that we believed they were failing to meet their responsibilities to regulate discharges of raw sewage – this was our formal legal letter click here. Their response didn’t convince us and so we have now filed detailed legal papers with the high court asking for permission for a judicial review of Ofwat’s inactivity.

    Ofwat – where are you?

    Water quality matters to all of us whether we are anglers, wildlife watchers, wild swimmers, kayakers or any other type of water lover. How crazy is it that raw sewage is so often dumped into watercourses?

    We aim to get Ofwat to face up to its legal responsibilities and the only way to do that is to go to court. Please support the crowdfunder we have launched today – we’ve stuck our necks out to bring the case this far without fundraising so we definitely need your help in raising the funds to carry this challenge all the way.

    To learn more about this legal challenge – please click here.

  12. Wild Justice’s Raptor Forensics Fund helps secure 3rd gamekeeper conviction

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    We’re delighted to learn that our Raptor Forensics Fund, established in 2020 to help support police investigations into alleged raptor persecution crime, has played a part in the conviction of a criminal gamekeeper in Wiltshire.

    21-year old Archie Watson, employed as a gamekeeper for a pheasant shoot on Galteemore Farm, near Avebury, was convicted of multiple raptor persecution and firearms offences at Swindon Magistrates Court on 1st June 2022.

    The corpses of at least 15 birds of prey (11 buzzards and 4 red kites) were found decomposing at the bottom of a well on the estate in 2020, and Watson was caught on a secret camera tossing corpses inside. Experts at the Natural History Museum at Tring, Hertfordshire, were asked to identify and verify the corpses, many of which were in an advanced state of decomposition. This was funded by our Raptor Forensics Fund.

    Watson pleaded guilty to possessing three red kites and four buzzards, but denied killing them. He claimed he had ‘found’ them on the estate. He received a 12-month community order to carry out 180 hours unpaid work and was ordered to pay £393 costs and £95 surcharge. The court ordered the forensics costs (£288) to be reimbursed to the Raptor Forensics Fund.

    This is the third conviction that our Raptor Forensics Fund has helped secure. The first one was gamekeeper Hilton Prest who was found guilty in December 2021 of the unlawful use of a trap in Cheshire (see here). The second one was gamekeeper John Orrey who was convicted in January 2022 of beating to death two buzzards he’d caught in a trap in Nottinghamshire (here).

    Thank you to all those who contributed to our Raptor Forensics Fund and thanks also to the PAW Forensic Working Group (a sub-group of the Partnership for Action Against Wildlife Crime) who administer our fund and ensure that police officers can access it without delay to help progress their investigations into raptor persecution crimes.

    If you’d like to donate to our work, please click here.

  13. Conservationists seek explanations from Dorset & Sussex police forces re: investigations into poisoned white-tailed eagles

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    In recent months, at least two young white-tailed eagles from the Isle of Wight Reintroduction Project have been found poisoned on game-shooting estates in southern England – one in Dorset and one in West Sussex.

    The police handling of the two investigations has caused serious concern amongst both the public and conservationists. Dorset Police has closed, prematurely, its investigation and Sussex Police has failed to comment on its investigation, seven months after the dead eagle was discovered (October 2021).

    This week, Wildlife & Countryside LINK, the largest environment and wildlife coalition in England, has written letters to the Chief Constables of Dorset and Sussex Police to express concern about the handling of these investigations. In the case of the poisoned eagle in Dorset, LINK has asked for a full explanation of why the investigation was closed so abruptly before even a search had been conducted.

    These letters have been written by LINK’s Wildlife Crime Working Group, of which Wild Justice is a member.

  14. Hen Harrier Fest 2022 – venue announced

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    We’re delighted to be able to tell you that Hen Harrier Fest will be held at Adlington Hall & Gardens in Cheshire on Sunday 24th July 2022.

    Thanks to the enormous generosity of our host, Camilla Legh, this event will be free to attend!

    However, to enable us to manage numbers we will be asking you to let us know if you plan to come along – registration will be open shortly.

    Plans are well underway for this event and we’ll be making further announcements shortly.

    Chris, Mark and Ruth look forward to welcoming you to what promises to be an excellent day in a stunning location.

    To be amongst the first to hear news and updates about this event and our other activities, we recommend you subscribe to our free newsletter HERE

  15. Chris Packham in conversation with Wild Justice lawyers

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    As many of you already know, we are privileged to be able to work with some brilliant environmental lawyers at Leigh Day and barristers from Matrix Chambers.

    A few weeks ago, Tessa Gregory (partner at Leigh Day) hosted an exclusive interview with leading silk David Wolfe QC (Matrix) and Chris Packham for a broad discussion on environmental legal challenges and a bit of an insight in to some of Wild Justice’s cases. Chris also talks about why he took the decision to take libel action against a number of individuals, in a case that is currently in progress in the High Court.

    The interview is now available to watch on You Tube:

  16. Rivers and Sewage

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    You’ve probably seen water pollution mentioned a lot in the news recently. Cases of sewage discharge and run-off from farming being released into rivers (like the River Wye), lakes (like Windermere) and into the sea (like in Kent) have hit the headlines repeatedly.

    These incidents have rightly caused outrage and concern. Campaigning groups like WASP and petitions like Matt Staniek’s have drawn attention to the problem and are calling for change.   

    The problem is widespread and it’s a big one – but who actually is responsible for sorting it out? Why is nobody being held accountable? As far as we can see, nobody wants to own up to being responsible for monitoring and enforcement when it comes to the issue of water quality and sewage pollution.

    Whilst water companies are responsible for what actually flows into our rivers, it’s not very clear who has the responsibility for monitoring and regulating planned and unplanned sewage discharges. We asked questions of three public bodies about their roles: the Department for Environment, Food and Rural Affairs (Defra), The Water Services Regulation Authority (Ofwat) and the Environment Agency (EA).

    The responses to our Environmental Information Regulations requests reveal a confused tangle of finger-pointing; each body suggesting another bears the responsibility for monitoring and dealing with this issue. We’ve had a look at what the law says and we believe Ofwat is ducking its responsibilities and we’ve written a Pre-action Protocol letter to them, to which we expect a response next week. You can read our letter below; section 6 lays out the case most clearly and section 6.30 describes the unlawfulness, we claim, of Ofwat’s approach:

    PS yesterday we heard from Ofwat that they need another two weeks to respond to our letter – they are clearly finding it difficult to explain their position. We’ll keep you posted and we’ll keep Ofwat on their toes.

  17. More high lead levels in Waitrose game meat

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    The story so far: Lead is a poison and has been removed from many formerly common uses such as for water pipes and fishing weights, and in petrol and paints. But it is still legal to use lead ammunition to shoot gamebirds such as Pheasant, Red-legged Partridge, Grey Partridge and Red Grouse (amongst others). Maximum lead levels are set for meats such as beef, pork, chicken etc but not, utterly bizarrely, for game meat. The maximum legal lead level for most meats in the UK is 0.1mg of lead per kg of meat, measured as wet weight.

    It is well known these days that lead ammunition which passes through a bird or mammal leaves tiny fragments of lead in the flesh of the shot animal. Most of these are too small to be noticed in food preparation or consumption. Non-toxic ammunition for shotguns, primarily steel, is available at similar prices to lead ammunition. Some jurisidictions (eg some US states, Denmark) have banned the use of lead ammunition in many contexts. The UK is thinking about controls on the use of lead ammunition which might come in in 2025 or so.

    If you go into a supermarket or a game dealer or a butcher and buy, say, Pheasants for human consumption it is perfectly legal for that meat to contain very high levels of lead – much higher than the maximum legal level for non-game meat. We see this as a serious failure of regulation by the authorities.

    Waitrose stuck its head above the parapet in 2019 and said that it was going lead-free for game meat, and received considerable praise for taking this stance (see here). However, testing of game meat on sale in Waitrose stores in 2020 and 2021 showed that this promise had not been met. Our tests published in December 2021, and covered in The Times, showed high levels of lead in Waitrose Pheasant meat. At the time Waitrose’s position was that these high lead levels must have been acquired from the environment. That seems to us, and all the experts we have spoken to, to be ridiculous. We don’t believe it, we don’t know anyone else who believes it, and we don’t really think that Waitrose can believe it.

    The Waitrose results for lead in their game meat are pretty similar to those found in Sainsbury’s and Harrods game meat – it would be very difficult to make a case that they are much better or much worse.

    So we decided to test some more game meat from Waitrose and collected Pheasant breasts and Woodpigeon breasts from Waitrose stores in north London and Essex in late January 2022, sent them off to a laboratory in the north of Scotland and received the results at the end of March.

    Here are the results of those tests, and tests of farmed duck samples from Waitrose, highlighted in yellow and set in the context of our previous findings;

    Our samples are quite small – the shelves weren’t packed with game meat when we sampled them – but they are worth reporting. First, farmed duck on sale in Waitrose had low lead levels as expected, as all samples of chicken and pork we have tested have had, and as is required by law. The Woodpigeon and Partridge (we don’t know which species of partridge they were) samples had lead levels that would be illegal to sell in other meats – 15/16 of the samples had levels higher than the maximum legal levels for non-game meats.

    These samples were from the same shooting season, 2021/22, as our previous samples reported before Christmas so it’s not surprising that Waitrose haven’t had time to fix this issue yet. But they do have an issue if they are going to live up to their ‘going lead-free’ promise.

    Talking to Waitrose: after Waitrose came out with its incredible ‘explanation’ that the high lead levels in their game meat were due to environmental contamination we asked to meet with Waitrose and that meeting finally happened on 30 March, a few days after we received our latest test results reported here.

    We had a good meeting with Waitrose’s John Gregson and we indicated the headline results of our further sampling. Wild Justice believes that Waitrose has performed poorly after being praised by us and others for their ‘lead-free’ promise. We suggested that Waitrose must have been let down by its supply chain but that if Wild Justice could test Waitrose game for lead levels then surely a company that made £7.5bn sales in the year ending January 2022 might spare a few quid to test the standards of its food. We understand from Waitrose that they are seriously considering testing their game meat for lead levels next season. We intend to continue testing game meat from Waitrose and other stores next season.

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

    Notes:

    1. One sample of Waitrose duck, the first of a batch, was excluded from these results because its high lead levels were suspected to be due to contamination by an earlier sample. So we have followed the advice of the laboratory and discounted its value. For the record, it was 0.21mg/kg WW.
    2. One sample of Waitrose Woodpigeon meat returned very high lead levels, >2500 mg/kg WW, and this sample was thought to have contained a lead pellet that was missed in the preparation of samples as all whole or large pellet fragments were removed before testing. Obviously, the lead levels in Woodpigeon meat would be much higher if this sample were included but again, we discount it on the advice of the testing laboratory.
  18. Glyphosate levels in human urine – preliminary results

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    We asked you, in late January whether you would take part in a study of glyphosate levels in human urine – our taking the p*ss study. As always, you responded brilliantly and from 9 February until last week the results gradually rolled in. Thank you.

    We received 120 results and if you were one of the participants you will have received, or will soon receive, an email thanking you for taking part and giving you the option of adding to our knowledge later in the year.

    The range of glyphosate levels was from ‘below detectable levels’ to 3.4ng/ml with a median value of 0.9ng/ml, and 84% of participants had detectable levels of glyphosate in their urine.

    How do these results compare with other studies? Our results are very much in line with previous results obtained in the UK, Europe and North America but more detailed comparisons are difficult since many previous studies were of small sample sizes (whereas our study, thanks to you, is a very decent size) and previous studies, and ours, are not representative samples of the population as a whole. Our participants are middle-aged and older with few under-40s in the sample and we have noticeably more females than males in our sample. None of this is surprising and doesn’t affect the value of what we are investigating.

    To see previous results from across Europe, including from the UK, but from self-selected samples of people, have a look at this website – click here.

    The next stage of this study will be to ask most of the current participants to repeat the process of taking a urine sample, sending it off for analysis and reporting the results to us later in the year. If we get enough repeat measures then we will find out more about two things: do people with higher/lower measured urine glyphosate levels from our first sample have higher/lower urine glyphosate levels when measured a second time? In other words, are there consistent differences between individuals? And, do measured urine glyphosate levels differ between different times of year? Is there seasonal variation. The answers to these questions are helpful in pinning down what influences glyphosate levels. And to look at potential correlates of urine glyphosate levels we will be asking participants in the next stage to fill in a short questionnaire about their age, gender, lifestyle, location, diet etc.

    This first stage of our study has produced a large sample of interesting results which seem very consistent with previous studies. The next stage of our study is much more ground-breaking and may (who knows? it depends on what we find) take knowledge of factors affecting glyphosate levels in human urine further forward. Thank you to everyone who has answered the call to action and we hope that you will be able to carry on being a part of this study.

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  19. Call for UK Government to timetable plans for tackling wildlife crime

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    Wild Justice is a member of Wildlife & Countryside LINK, which is the largest environment and wildlife coalition in England, bringing together 65 organisations to use their strong joint voice for the protection of nature.

    LINK covers many policy areas and Wild Justice is represented on a number of committees, including the very active Wildlife Crime Group.

    The Wildlife Crime Group is calling for the Westminster Government to commit to a detailed timetable for the progression of a number of recommendations made in a recent United Nations Office on Drugs & Crime report on how to tackle wildlife crime in the UK, including recommendations covering legislation, enforcement, prosecution, sentencing and monitoring.

    A detailed blog outlining some of these recommendations has been written by the LINK Wildlife Crime Group Chair, Martin Sims, and can be read here.

  20. GWCT – ‘I’m only a simple farmer but…’

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    Dear Teresa

    I trust you are well, but I wonder whether you may have been on holiday recently as I’ve received a rather strange letter from one of your staff. It’s about the request, by Wild Justice, that I change the shooting season for Woodcock in England, Wales and Scotland to protect the declining UK breeding population. Your letter doesn’t really seem to add anything to this matter.

    Let me deal with the three points in your letter after making a more important point first.

    First, and fundamentally, the Wild Justice request asks for the open season for Woodcock shooting only to start on 1 December so that the declining UK population is, shall we say, shielded, by the much larger numbers of continental birds which arrive in late autumn/early winter. Wild Justice correctly cites a GWCT paper published in British Birds less than two years ago which says that shooting should not start until that date. Moreover, that advice is currently on your website, today, I’ve just been looking at it. If you have forgotten it then you can check it here – click here. Now I know I am only a simple farmer but it seems pretty clear to me that GWCT is recommending that shooting of Woodcock does not start until 1 December. Your letter doesn’t withdraw that view, your website still states it, and your recently published paper said that. If you are now resiling from that view then you’d better explain why and on what grounds, please, and put the science on your website. Can you tell me that you are sure that doing what Wild Justice has asked would definitely not help the UK breeding Woodcock population? I’m guessing not, partly on the basis of what is on your website, right now, today, visible to all.

    And now to turn to your three ‘points’:

    1. You say that there is an ‘indication’ that shooting pressure has declined but your letter does not provide any evidence or figures to support that view. I’ve got plenty of boffins here in the department and when they say ‘indication’ they usually mean ‘just a hint’ or ‘not very reliable evidence’ – is that what your letter meant? We are in a difficult position here because the UK does not require hunters to report on their shooting totals and so there are no official data on this matter at all. I understand that GWCT has good contacts in the shooting industry but your data are self-reported, non-verified numbers from shooters – nobody would regard those as being highly reliable. They are also very unlikely to be representative of all shooting since your supporters, many of whom are my friends, tend to be at the slightly wealthier end of the scale and may not represent what other shooters do. This point is made much better than I could make it, as a simple farmer, by the highly respected Nicholas Aebischer of your staff in his paper Fifty-year trends in UK hunting bags of birds and mammals, and calibrated estimation of national bag size, using GWCT’s National Gamebag Census where he states ‘In an ideal world, sites would be selected at random from among the pool of available sites, as is the case with, for instance, the Breeding Birds Survey (Gregory et al. 2000; Harris et al. 2018). In a situation where the collection of bag statistics depends on the good will and cooperation of shoots and shooters, and where the pool of available sites is un-known, this is not possible‘. That is the same point that I have made above, is it not? That paper states that ‘…woodcock Scolopax rusticola bags increased by 50% during the first 25 years, but stabilised or slightly declined since‘ – is that what the ‘indication’ is based upon? I don’t think we can rely on that very strongly, can we? And, of course, it does not distinguish betweeen pre-December and post-November shooting so fails to illuminate the point with which I am wrestling.
    2. Your letter argues that any restraint in shooting Woodcock will reduce the chance that suitable habitat measures will be carried out. Really? This is contradicted in your next point when you say that lots of Woodcock are shot in places where they don’t breed – sooooo, which do you really mean? Your letter states that ‘importance of … ‘enlightened self-interest’ in delivering practical, privately funded conservation should not be underestimated‘ but I think we’d both have to admit in private, if not in public, that the importance of ‘enlightened self-interest’ shouldn’t be overestimated either and that there are many examples, in shooting but in other areas too (I have to deal with fisheries remember!) where enlightened self-interest is completely obscured by actions based on short-term selfish gain.
    3. Your third point is that some areas don’t have breeding Woodcock so the birds shot there, at any time of year, must be continental birds. Are you sure? This seems to me, as a simple farmer, to ignore two important points. First, you have stated, and still state, that not shooting Woodcock until after the end of November is a good thing to protect the UK breeding population. So how, all of a sudden, has it become OK to shoot earlier in the year? Second, even with my knowledge of birds, I know that birds can breed in one part of the UK and winter in another part of the UK – indeed I believe this is commonplace. So how do you know, indeed do you know, that birds present in early autumn are not UK breeding birds? If you had tagged a great number of these birds, in non-breeding areas, early in the season, and followed them back to their breeding grounds then there might be something in this but my reading of your excellent study is that the sample size of such birds would be vanishingly small and would not provide me with any confidence that what is conjectured in your letter is, in fact, true.

    I wish you had written to me privately because then these matters would just have been between us but you’ve slapped this letter on your website, followed by a request for donations, and so everyone can see it. I’m afraid that it looks such a poorly argued case that it doesn’t make it easy for me to accept it at all. It’s rather difficult to get past the fact that GWCT said (and still says) ‘Don’t shoot Woodcock until December‘ but that when someone else takes notice of that, and let’s be clear, most shooters haven’t taken any notice at all, then you say you didn’t really mean it. People will wonder what else you say when it suits you but then repudiate when anyone takes notice of it, won’t they?

    In this case, I will probably come under pressure from Wales and Scotland to act and I will have to have a pretty good case to ignore the case for action. In fact, I wonder if this is a subject on which I ought to give the pesky Wild Justice a win – their case is perfectly fair, based on science (your science, the advice that is on your website still) and is pretty moderate. No-one can argue that shooting Woodcock is of great importance financially and no-one can argue that the UK breeding population of Woodcock is not falling. No-one would argue that shooting can’t be having an impact, and you yourselves suggest that it really might be. Whereas it was easy for us to brush off a petition calling for a complete ban on shooting this Red-listed UK species (see here), it is much more difficult to ignore Wild Justice’s call without looking as though I am pretty uninterested in taking modest measures that could lead to a recovery of declining species and am actually more interested in maintaining outdated, scientifically unjustified shooting practices. I’ll be thinking hard about these matters.

    with warm best wishes as always, and I hope you did enjoy your holiday,

  21. GWCT can’t read their own advice, it seems

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    GWCT can’t play an honest and straight game these days.

    Here is their statement in response to Wild Justice’s letter to DEFRA and DAERA on Woodcock shooting;

    https://www.gwct.org.uk/blogs/news/2022/april/gwct-woodcock-statement-in-response-to-wild-justice/

    And here is their own advice still present on their own website;

    Just to make it a bit easier for GWCT’s Head of Advisory to see what his organisation’s advice is let’s put it in larger letters for him:

    Woodcock should not be shot when it’s too early in the season, generally we recommend not shooting Woodcock before 1st December.

    We hope that’s not too nuanced.

  22. Badgers in Northern Ireland: Update 1.4.22

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    Over the last month, we’ve been getting ready for a potential challenge of a proposed Badger cull in Northern Ireland. Thanks to your generous support, this morning we’ve surpassed £30,000 towards our legal costs in our Crowdfunderthank you to every one of you who has donated.

    Last week, we heard some news – news of a Badger cull was formally announced by Edwin Poots,

     Minister for Agriculture, Environment and Rural Affairs, Northern Ireland. This proposed cull will likely see around 4,000 Badgers killed in one year, largely using the inhumane method of shooting.

    Wild Justice is challenging this decision in the courts alongside our friends and partners in the Northern Ireland Badger Group (NIBG). We’re hitting the ground running; a cull could start as early as July this year so we need to act fast. On Tuesday we filed an application for judicial review of this decision at the Royal Courts of Justice in Northern Ireland, asking for an early hearing.

    We say the consultation about whether to go ahead with the controversial programme of shooting Badgers withheld vital information so that contributors were not able to participate effectively. Our legal team have been working hard so far, but we’ve still a long way to go.

    We can’t do this without your support. Over 1,100 of you; wildlife advocates and campaigners, have donated to our Crowdfunder so far. We’re blown away. Please spread the word and consider donating if you can.

  23. We ask for changes to the Woodcock shooting season.

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    Woodcock. Photo: Tim Melling

    The Woodcock is a wading bird, a bit like a large Snipe, which generally roosts in the day, often in woodland, and feeds by probing for invertebrates in soggy areas at night.  It is also a gamebird and some 160,000 Woodcock are shot in the UK, in recreational shooting, each year.

    Last week, Wild Justice wrote to George Eustice, the Secretary of State at DEFRA, and to Edwin Poots, the Minister for Agriculture, Environment and Rural Affairs in Northern Ireland, asking them to exercise their powers to change the seasons for Woodcock shooting across the UK. Slightly surprisingly, it seems that Mr Eustice still has the power to vary the shooting seasons in Wales and Scotland as well as in England but we assume this would be done in consultation with the Welsh Minister, Leslie Griffiths, and Scottish Cabinet Secretary, Mairi Gougeon.

    The UK Woodcock breeding population is in decline and that is not in doubt. It has been moved from the UK Amber list to Red list because of this ongoing, well-documented population decline.  Under those circumstances there is an argument that all Woodcock shooting should be halted but our suggestion is more modest than that – it is for the shooting season to open not on 1 October (1 September in Scotland) but on 1 December.

    The rationale for such a change has been set out by the pro-shooting Game and Wildlife Conservation Trust and rests on the fact that the UK Woodcock population is swelled by large numbers of migrants from Europe and Asia in winter, and in mid winter the continental birds outnumber the UK birds by about 10:1. The arrival of Woodcock in late autumn is well known to naturalists and gives rise to the full moon in November often being known, to shooters and conservationists alike, as the Woodcock moon (for examples see here, here, here).

    GWCT have asked shooters to show restraint and not to shoot Woodcock until 1 December but we are asking Mr Eustice and Mr Poots to make that suggestion a matter of law by a small but significant change to the shooting season.

    A change to the shooting season is a simple matter and does not require primary legislation. It could be done, at no cost and with no delay in the next few weeks and be in place for next autumn’s shooting season.  There is ample evidence from advertisements offering Woodcock shooting that the call for voluntary restraint has not been heeded.

    This simple and precautionary change in order to reduce the pressure on a declining species of conservation concern is a modest request of politicians.  We see it as a test of their commitment to wildlife conservation. If the decline of UK biodiversity is to be halted and reversed then much more expensive and radical action will be needed in many other areas of wildlife policy. Our proposal is simple, is based on science, is administratively easy and has trivial financial implications.  If politicians cannot take action like this, then we cannot trust them to make good their promises to deliver a better future for wildlife.

    Our letter to ministers:

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  24. Debating Badgers in Parliament – some first thoughts

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    https://hansard.parliament.uk/commons/2022-03-21/debates/3A62786C-3340-47E7-9DC0-D95B1EE9BD57/BadgerCulling

    Westminster Parliamentary petitions: Wild Justice supports the use of parliamentary petitions across the UK parliaments. They are a valuable way of bringing matters to the attention of politicians that might otherwise be avoided. All UK residents and citizens living abroad are entitled to sign such petitions. A Petitions Committee exists to run the process in the Wetminster parliament and acts as a gatekeeper to which petitions can go ahead and if and when they are debated. Almost always, a petition that receives 100,000 signatures in a 6-month period is subsequently debated in Westminster Hall, primarily by backbench MPs but with closing remarks from Opposition Shadow Ministers and Government ministers. Any petition which reaches 10,000 signatures receives a response from the government department responsible for that matter in England. Relatively few petitions reach 10,000 signatures, very few of those started get anywhere near 100,000 signatures.

    Petition 333693 on how Badgers are killed in England: this petition was initiated by Wild Justice. Since someone has to submit the petition, in this case it was submitted by Mark Avery and the parliamentary process regards him as ‘the petitioner’. We regard ‘Wild Justice’ as the petitioner but that is of little importance since this petition was signed by 106,108 people and they all have an equal share in it. Thank you to all who signed the petition.

    This petition was very clearly about how Badgers are culled in the DEFRA-sponsored Badger cull which purports to be a key means of eradicating bovine tuberculosis (bTB) in cattle. Here is the complete text of the short petition;

    Shooting of Badgers is licensed by Natural England as part of the DEFRA Badger cull. 24,000+ Badgers were shot in 2019.

    Shooting is poorly monitored and Wild Justice believes it has never met the animal welfare standards recommended by a 2014 Independent Expert Panel, whose recommendations were accepted by DEFRA. This method of culling is inhumane and should be banned immediately.

    https://petition.parliament.uk/petitions/333693

    This petition was submitted by Wild Justice on 3 August 2020, immediately received the half a dozen signatures that each petition needs to jump the first hurdle but was not considered by the petitions team until late September (let’s put it down to covid). There was initial pushback from them saying that this petition was very similar to an existing petition until we pointed out that our petition was quite clearly about shooting, and about whether shooting was humane, and did not even mention vaccination. Our petition was published on 24 September 2020 and closed 6 months later on 24 March 2021 having passed 100,000 signatures. It took almost a year, until 21 March this year, for this successful petition to be debated (let’s put it down to covid although many petitions which reached 100,000 signatures after ours have been debated in the interim).

    Support for this petition came from across the UK, but unsurprisingly primarily from England, and unsurprisingly, mainly from rural areas many of which are experiencing Badger culls.

    At the time when this petition started Wild Justice pursued a legal challenge to the lawfulness of this method of culling – that challenge was unsuccessful (which doesn’t, of course, mean that shooting Badgers is acceptable).

    In the run up to the debate many Wild Justice supporters drew the debate to the attention of their MPs (thank you for doing that), Mark Avery met, virtually, Nick Fletcher MP from the Petitions Committee to brief him on the petition and our thoughts, and we and other organisations, particularly the Badger Trust (many thanks!) briefed MPs on the issues.

    The debate: and so, at 4:30pm on Monday afternoon, a small number of MPs met to debate this petition and in the public gallery Mark Avery and the Executive Director of the Badger Trust, Peter Hambley, attended in person. You can read the transcript of the debate – click here – or watch the video of it – click here and move to 10 minutes into the video for the start of the debate.

    Here are our initial thoughts on the debate.

    1. Nick Fletcher MP’s introduction: we are grateful to Mr Fletcher (Conservative, Don Valley) for the time and care he took to get briefed on the subject. His introduction was polite and fair. He stressed that ‘I have spoken to the petitioner, Mark Avery, and his main request is whether, should the Government continue with culling, it can be carried out more humanely. The Animal Welfare (Sentience) Bill has just gone through Parliament. Surely that attitude to improving animal welfare should be reflected in our approach to TB reduction. Trapping and then killing is far better than wounding a badger and then letting it die a slow, painful death.‘. He might have added that the British Veterinary Association withdrew support for shooting free-running Badgers because this method is not humane as long ago as 2015. He might have pointed out that government did not adopt the welfare standards (fewer than 5% of badgers should take >5minutes to die) recommended by an expert panel and that monitoring of shooting shows that those standards have not been met in any subsequent year of Badger culls involving over 100,000 animals being shot.
    2. Mike Amesbury MP (Labour, Weaver Vale): Mike didn’t say much, but it was good to hear ‘Not only does culling not respect animal welfare…’
    3. Chris Loder MP (Conservative, Dorset West): if this name sounds familiar to you then it might be because Mr Loder went out on a limb, and has not been supported by fellow Conservative MPs when he said that White-tailed Eagles weren’t welcome in his constituency. Mr Loder comes from a farming family. It is unclear that Mr Loder actually read or thought about the petition and he certainly didn’t address the point made by his colleague Mr Fletcher in opening the debate, that this is about how to cull (if such a cull is to continue, as Mr Loder clearly thinks it should). Mr Loder failed to address the choice in front of this government about the method of culling – should it continue with the current less humane method or ensure that all Badgers culled (if the cull is to continue) should be culled by the most humane method available. If this were an exam question then Mr Loder failed to read the question carefully and deserves to get low marks.
    4. Jim Shannon MP (Strangford, DUP): Mr Shannon agrees with Mr Loder, and owns a farm and is a member of the Ulster Farmers Union. He is also the treasurer of the All Party Group on shooting. Mr Shannon said that he supported the culling of badgers but failed to address the issue of the petition, pointed out by Mr Fletcher at the start, of whether he supported the less humane method of shooting at free living Badgers (though we can infer that he does). Although he uttered the rather empty words that Badgers ‘must be handled compassionately’ he did not say whether he thought shooting at Badgers in the dark was compassionate or whether he would favour a move to a more humane method. If this were an exam question then, like Mr Loder, Mr Shannon failed to read the question carefully and deserves to get low marks.
    5. Sir Bill Wiggin (Conservative, North Herefordshire): Sir Bill is a farmer too, and a shooter too, funny that. Sir Bill regards, it seems, gassing as the only alternative to shooting in the dark with rifles – it clearly is not. Sir Bill, like Mr Loder and Mr Shannon, failed to read the question carefully and deserves to get low marks.
    6. Daniel Zeichner (Labour, Cambridge): spoke for the Opposition EFRA team. He was well-briefed and on top of the subject to a large degree. Labour’s position would, in theory, avoid these welfare issues by switching to Badger vaccination, biosecurity and movement controls. Mr Zeichner made these points of direct relevance to the petition ‘The petition has a significant number of signatures. It focuses on the killing of badgers rather than the bovine TB issue, which I shall return to. The view expressed is that the shooting of badgers is poorly monitored and inhumane. Anecdotally, one is certainly told of cases where badgers are not shot cleanly and are left with injuries. According to Natural England’s compliance monitoring report for 2020, badgers were shot at but not retrieved in 11.4% of cases, but only one case of a badger being shot at but wounded and lost was reported; presumably some of the rest may not have been found. As with all such figures, the situation is not clear. I suggest that there is some cause for concern.‘ and ‘Can the Minister say why the number of badgers culled through free shooting rather than cage-trapping has changed so dramatically? According to the figures in the very good briefing prepared by the House of Commons Library, those numbers have increased from rough parity in 2014 to around four in five in 2020, creating a greater risk of inhumane culling. What is the reason for that? It seems that that is directly relevant to the question raised by the petitioners.‘. Mr Zeichner had read the exam question and scored high marks from us as a result.
    7. Dr Lisa Cameron MP (Scottish National Party, East Kilbride): made a useful short intervention on vaccination.
    8. Sir Robert Goodwill MP (Conservative, Scarborough and Whitby): made short interventions in favour of continued culling but failed to differentiate between shooting free running Badgers in the dark and the welfare issues it poses and cage-trapping. Sir Robert, like Sir Bill, Mr Loder and Mr Shannon, failed to read the question carefully and deserves to get low marks. That’s a clean sweep of back-bench MPs who favour continued culling who swerved the welfare issues associated with shooting in the dark – it’s almost as if they cannot face up to the issue even though they come from rural constituencies, claim to be farmers or know about farming and are largely supporters of fieldsports. Hmm.
    9. Jo Churchill MP, (Conservative, Bury St Edmunds), Parliamentary under Secretary of State, DEFRA: the Minister, briefed by all those officials in DEFRA did not address the question of the welfare issues associated with the current and planned methods of Badger culling. The closest she came was to say, very briefly ‘we need to approach this issue in the most humane way possible‘ without giving any indication of what that is, despite the recommendations of an expert committee in the early years of this large-scale cull which her department have neglected to implement. Like Sir Robert, Sir Bill, Mr Loder and Mr Shannon, all those who spoke in favour of culling, the minister of the very department responsible for the cull and the way it is carried out could not bring herself to address the welfare issues involved.

    It would be possible to read into this failure to address the welfare issues associated with a government-led massive cull of wildlife; that the Department responsible for it does not really care about the suffering its policy is imposing on our wildlife.

    Wild Justice will be writing to DEFRA for clarification of their views on the welfare issues associated with shooting of free-running Badgers.

  25. Debating Badgers in Parliament

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    Yesterday afternoon, parliament debated our petition from last year, signed by over 106,000 of you. MPs gathered to discuss the issue of culling, following our call to ban the shooting of badgers immediately.

    The discussion was generally civilised, with points presented from both sides of the debate. Some MPs, like Daniel Zeichner, spoke to defend badgers, and for his party’s support of a TB vaccination programme. Other MPs spoke in favour of continued culling, despite recent new research questioning its effectiveness.

    You can watch the full debate back here, or if you prefer you can read the whole transcript here. We’ll be analysing the discussion in full, and will report back with some of our thoughts very soon…

  26. Update: DAERA and delays, delays delays…

    Comments Off on Update: DAERA and delays, delays delays…

    It seems we’ve encountered yet another delay with the Department of Agriculture, Environment and Rural Affairs’ (DAERA) promised consultation on General Licenses in Northern Ireland. The consultation, which was promised by 21 March 2022, has yet to materialise on DAERA’s website.

    In December last year, Wild Justice were successful in a legal challenge to Northern Ireland’s general licences for the killing of wild birds.

    At the time, DAERA conceded that their general licences were flawed and unlawful. They also said they’d replace them with interim licences, and reassured us that a full public consultation would be launched in due course. After several delays, we were told the consultation would finally launch on March 21.

    Once again we’re left waiting, and once again we’ll keep you updated as things develop…

  27. More progress on general licences in Wales

    Comments Off on More progress on general licences in Wales
    A Jackdaw – should soon be better protected in Wales

    UPDATE: THESE RECOMMENDATIONS WERE APPROVED BY THE NRW BOARD ON THURSDAY 24 MARCH

    At their Board meeting next week, Natural Resources Wales is expected to approve further improvements to their general licences in line with what Wild Justice has argued both in consultation responses and in the courts. And many Wild Justice supporters can take credit for their responses to the consultation being a part of that process – thank you!

    The board paper (Review of NRW’s approach to regulating the shooting and trapping of Wild Birds: General Licences 22-03-15 click here – paragraphs 31 and 32) takes on board Wild Justice’s arguments about the ‘conservation licence GL004’ by:

    • restricting the scope of the protected species to those which actually nest in Wales (see our blog on this subject almost two whole years ago – click here)
    • restricting the period under which the conservation licence can be used (see the judgment of Justice Jarman – click here)
    • removing Magpie, Jackdaw and Jay (see previous Wild Justice blog on Jackdaws, and Mark Avery’s several blogs on Jays) from GL004 (leaving only one species, namely Carrion Crow).

    NRW is being too modest about its proposals. They will, if approved, mean that Wales has by far the best, the most scientifically robust, conservation general licence across the UK (see this comparison – click here).

    We’ll have to see what the NRW Board says about the paper but given that NRW has done an evidence review, carried out a public consultation and told a judge what the limits on their licence GL004 are, it would be an exceptional slap in the face for the science, the public, the courts and NRW staff if the Board were not to approve these recommendations.

    We note that elsewhere in the paper (paragraph 30) NRW proposes to ‘define in the general licence the particular species-to-purpose combinations where lethal control is authorised’. That sounds sensible if it means, as we believe it does, that it will be made clear that you can’t kill a Woodpigeon because it might attack a lamb nor a Magpie because it might eat your Oil Seed Rape crop. We’ll look closely when more detail is available but on the face of it, this too reduces the casual licensing of casual killing of birds. We recommend this approach to other nations.

    Well done, NRW staff! Let’s hope your Board follows through on these sensible measures. You will be leading the way across the four UK nations…

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  28. Important new study on Badger culling

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    Today an important paper on Badger culling has been published in the journal Veterinary Record. The paper reports on new and detailed analysis, and concludes that Badger culling has been ineffective in reducing bovine Tuberculosis in cattle herds.

    It is significant because it is is the largest examination of Government data on Badger culls, which have seen over 140,000 Badgers killed, to date.

    Authored by biologist Thomas Langton, and vets Dr Mark Jones and Dr Iain McGill, the study compares both the incidence and prevalence of bovine TB in areas where Badger culls have taken place, and those where they haven’t. Over the duration of the study, incidences of TB peaked and began to decline; however there was no statistical evidence showing any difference in the rate and nature of decline between culling and  no-culling areas. You can read the full study here; we’ve shared the abstract from it below.

    To us, this looks like yet another reason to be highly sceptical about whether culling works – whether it reduces bTB levels. Looking at the evidence, it seems killing large numbers of Badgers isn’t beneficial for farmers and their industry. It certainly isn’t good for Badgers, and it’s often carried out in an inhumane way.

    Wild Justice will review this study carefully in the coming days, and we’ll of course update you with any developments from here…

    Analysis of the impact of badger culling on bovine tuberculosis in cattle in the high-risk area of England, 2009–2020
    Thomas E. S. Langton, Mark W. Jones, Iain McGill

    Abstract
    Background
    Since 2013, badger culling has been part of the UK Government’s strategy for controlling bovine tuberculosis (bTB) within a high-risk area (HRA) in England. Government surveillance data now enables an examination of bTB herd incidence and prevalence, its headline indicators, within and outside cull areas over the period 2009–2020.

    Methods
    Analysis compared herd incidence and prevalence data from within and outside badger culling areas. A range of models (GLMs, GLMMs, GAMs and GAMMs) were used to analyse incidence and prevalence in culled and unculled areas using frequentist and Bayesian approaches. Change in incidence across ten county areas within the HRA for the period 2010–2020 was also compared.

    Results
    Analyses based on Defra published data using a variety of statistical methodologies did not suggest that badger culling affected herd bTB incidence or prevalence over the study period. In 9 of 10 counties, bTB incidence peaked and began to fall before badger culling commenced.

    Limitations
    There are limitations around the data available on culling location, temporal information and other confounding factors. As such, further analysis of any future datasets that may be released on bTB levels in areas where badger culling has been implemented is warranted.

    Conclusion
    This examination of government data obtained over a wide area and a long time period failed to identify a meaningful effect of badger culling on bTB in English cattle herds. These findings may have implications for the use of badger culling in current and future bTB control policy.

  29. Link Guest Blog: Ask your MP to end Badger cull cruelty on 21 March

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    Today the Wildlife and Countryside Link have hosted a blog from Wild Justice on their website. You can read what we said below:

    In 2020 Wild Justice launched a Parliamentary Petition calling for an immediate ban on the licensing of the shooting of Badgers by Natural England. When it closed in March 2021, the petition had gathered 106,108 signatures from the public.

    After almost a year’s wait, we’ve finally got a date for the petition to be debated in the Westminster Parliament; Monday 21 March 2022 [NOTE, previously advertised as 14 March but rescheduled by the Petitions Committee]. We’re asking the public to encourage their MPs to attend on that day and make the case for Badgers.

    Since the first Badger culls were proposed in England in 2010, an estimated 140,000 badgers have been killed in England, for which shooting was the preferred method. Earlier in 2020, Wild Justice challenged the legality of free shooting of Badgers. We argued that Badger shooting is inhumane and that in licensing it Natural England is not taking account of the recommendations made to government by an expert panel on the animal welfare aspects of culling. In June 2021, we heard our challenge had been unsuccessful.

    In 2014, an Independent Expert Panel, chaired by Sir Ranald Munro, delivered a report to the Government following the first year of culling. The report concluded that shooting Badgers was likely to cause suffering in a significant proportion of cases. Between 7.4% and 22.8% of Badgers that had been shot took more than five minutes to die from blood loss, bullet wounds and organ failure. After the following year of pilot culls, the Independent Expert Panel was disbanded by DEFRA Secretary of State Owen Paterson. Since then, independent monitoring of cull contractors has reduced, and shooting has remained the primary method of killing Badgers in cull areas.

    Support for this method of culling has continued to dwindle; in 2015, the British Veterinary Association stated that they “can no longer support the use of controlled shooting as the pilot culls have failed to demonstrate that this method can be used effectively and humanely”.

    The coming debate is another opportunity to register public concern about the Badger cull which has grown in projected scale since it first started. The number of signatures demonstrated that this is an important public issue.

    When the date for the Parliamentary debate was announced, we in turn asked our supporters to consider writing to their MP. The more Badger-friendly voices we can encourage to attend, the better. There is still time to do this; if you live in England, consider sending an email to your MP and ask them if they’ll attend on Monday 21 March. We’ve included some suggested wording on our blog, but feel free to use your own words too.

    If you’d like to watch the debate yourself, it can be streamed from the Parliament YouTube channel.

    Add the date to your diary: Monday 21 March, at 16:30.

  30. What’s happening with Badgers in Northern Ireland?

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    Our Crowdfunder for a legal challenge of a proposed Badger cull in Northern Ireland has just passed £25,000 in donations. Thank you to everyone for your support and contributions!

    So, where are we at with news of this proposed cull? Wild Justice have been in detailed correspondence with the Department of Agriculture, Environment and Rural Affairs (DAERA) about our challenge. Throughout this correspondence, DAERA have repeatedly told us they believe our challenge, should it be launched at the moment, would be premature. We’ve still had no formal statement from DAERA on whether they intend to go ahead with their proposed cull or not.

    In the meantime, the news and comment in the wider political and farming sector suggests very strongly that DAERA are in fact intending to implement a Badger cull. An article in Irish Farmers Journal last week mentioned the proposed cull and that DAERA’s officials are working ‘at pace’ to finalise their new TB Strategy which remains one of DAERA’s ‘top priorities’. That doesn’t sound like the decision to implement a cull is in the balance to us.

    Wild Justice have also heard that DAERA will be reporting on this strategy, and their plans for a cull, to the Committee for Agriculture, Environment and Rural Affairs on Wednesday morning, at 10am. We’ll be watching this with interest, and you can too.

    So, whilst DAERA may be telling us that filing the next set of legal papers would be premature, we’re still actively preparing, with our friends in the Northern Ireland Badger Group, to challenge any plans to cull Badgers in Northern Ireland and to take that challenge through the courts.

  31. Allegations about Chris Packham are defamatory, High Court rules

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    Wild Justice co-director Chris Packham is suing three defendants for libel after a series of articles, videos and tweets, published in 2020 and 2021 accused Chris of mis-using his role as a BBC presenter to ‘defraud’ the public.

    A preliminary hearing took place at the High Court in February 2022 and yesterday the judgement was published.

    Chris, partner Charlotte and some of his legal team at the High Court in February

    The following is a press statement from Chris’s lawyers, Leigh Day:

    Country Squire articles, videos and tweets about Chris Packham were defamatory.

    A series of nine articles in Country Squire magazine, two videos on YouTube and eight tweets about Chris Packham were defamatory, according to a judgement handed down today.

    An initial trial of preliminary issues about the meaning of the articles, videos and tweets rejected the contention that all were expressing an opinion.

    The defendants claimed that when they contended that Mr Packham misused his role as a BBC presenter to defraud the public into making charitable donations on the false pretext that tigers had been mistreated by a circus and rescued by a zoo, they were expressing an opinion.

    They relied on question marks, reference to the need for clarifications, an invitation to the reader to “make up your own mind” as part of their case.

    However Mr Justice Johnson held that the meaning of each article is defamatory of Mr Packham at common law and amounts to a statement of fact.

    He rejected arguments that serious allegations of fraud were mitigated. References to the police and other investigating bodies “were not presented in a way to suggest that the reader should keep an open mind. They again reinforce the central theme of the publications that the claimant has perpetrated a fraud on the public”.

    He said the parts of the publications that express opinions were ancillary to the defamatory meanings that the articles convey.

    Following the determination of the meanings of the publications, it is expected that a substantive trial will be held towards the end of the year.

    Mr Packham began proceedings following repeated allegations in Country Squire magazine that he defrauded the public into donating funds for the Wildheart Trust, where he is a trustee, by falsely claiming that it had rescued emotionally and physically broken tigers from European circuses.

    The claims were independently investigated by the Fundraising Regulator and found to be unsupported, but the defendants refused to remove the articles, tweets and videos from the public domain and since the proceedings were issued, repeated the allegations.

    Following the judgment, Chris Packham said:

    “Truth and love, and a love of truth are things we cherish. They give us the ability to proceed, to become better people. They give us a chance of making a better world. So we must protect them, sometimes at great personal cost. And that is why I have no choice but pursue this course of litigation.
    “In this case the three defendants have proactively sought to damage my reputation. There is a line in the sand and it’s been crossed and I aim to ensure that they and any others who seek to employ such methods cross back again. And stay there.”

    Chris Packham is represented by Leigh Day partner Tessa Gregory and solicitor Carol Day, who said:

    “Our client is pleased the judge has recognised these very serious allegations are defamatory at common law. The burden of proof is now on the defendants to show a lawful defence to these claims in a substantive trial.”

    ENDS

    The full judgement can be read here:

  32. Update: The Schrodinger’s Pheasant conundrum.

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    You might remember our recent head-scratcher involving gamebirds; when is a Pheasant livestock, and when is it wildlife? Today news of our legal challenge to DEFRA was reported in the Guardian online – we expect it’ll be in the print edition tomorrow.

    Updates to the English General Licence GL42, earlier this year, meant gamebirds, such as Pheasants and Red-legged Partridges, were classified as livestock if they were ‘dependent’ on food, water or shelter provided by gamekeepers even after they had left their release pens in the countryside. By being classified as livestock, this opened the door for gamekeepers to shoot other wild birds, like Rooks, Jackdaws, Crows and Magpies in order to ‘protect’ the gamebirds for a longer period, and under wider circumstances, than had previously been the case.

    The article in the Guardian reports on today’s news of a U-turn by Defra brought about by Wild Justice’s threat of legal action (not simply public outcry, as the article suggests). DEFRA conceded that only food, water or shelter provided ‘by or within the release pen’ is relevant when assessing if a gamebird is wild, or livestock.

    Defra agreed to revise the definition, telling Wild Justice’s lawyers: “The secretary of state does not consider pheasants to be livestock within the meaning of the WCA 81 [Wildlife and Countryside Act, 1981] once they cease to be kept”.

    We consider this to be good news. Wild Justice are, however, still deeply sceptical about whether the whole General Licence system is the best way to regulate activity in the murky field of ‘pest control’. We’ll be keeping an eye on things, as always…

  33. Update: DAERA delays again on Consultation on General Licences…

    Comments Off on Update: DAERA delays again on Consultation on General Licences…

    Back in December, Wild Justice were successful in a legal challenge to Northern Ireland’s general licences for the killing of wild birds.

    The Department of Agriculture, Environment and Rural Affairs (DAERA) conceded that their general licences were flawed and unlawful. At the time they said they’d replace them with interim licences, and reassured us that a full public consultation would be launched in due course.

    Initially we were told the consultation would begin in early February. Early February came and went. Following some prodding, DAERA then promised the consultation would happen sometime between late February and early March – but definitely no later than March 7 2022. 

    March 7 has now passed. Yesterday, we heard from DAERA that they’re aiming for the consultation to go public on 21 March 2022. The reason given for multiple delays was a vague one; Officials are awaiting final clearance from the Minister.”

    Will we see the consultation appear on the 21st? We will wait and find out, and of course keep you updated as we go…

  34. Please write to your MP about Badgers

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    Last year, over 106,000 of you signed our petition asking for a ban on shooting Badgers in England. Yesterday, we finally heard that our petition will be debated in Parliament very soon – Monday 14th March at 16:30. Update: The debate on Shooting Badgers in England has been postponed to Monday 21st March, at 4:30.

    Once again, we need your help. We’d like to make sure we have as much impact as possible in this debate, arguing in defence of these charismatic animals and pushing to enact the ban we called for.

    You can help in two ways:

    1. Watch the debate live on the Parliament YouTube channel.
    2. Write to your MP, and ask them to attend the debate in person.

    Writing to your MP.

    Please write to your MP, informing them about the debate and asking them to attend. We’ve provided some suggested wording below, and here is some introductory guidance:

    • Where you live: Writing to your MP about this debate is particularly useful if you live in England, as this was the remit of our petition – however, please still consider writing if you live in Scotland, Wales or Northern Ireland. This debate could have repercussions across the four nations. For example, we’re currently fundraising for a legal challenge to a proposed Badger cull in Northern Ireland, which would use shooting as the method of killing Badgers.
    • Who exactly your MP is: If your MP is a Government or Shadow Minister, it is unlikely they’d attend. Do still ask – and perhaps ask them to share your views with their backbench colleagues who may be able to attend instead. You can find your MP’s contact details here.
    • Your details: Don’t forget to include information about yourself – MPs often require an address, and even telephone number, in order for them to respond to a constituent’s email.
    • Your signature: If you signed our petition in 2020 – don’t forget to mention it!


    Dear_____

    I am writing to you as one of your constituents, to ask you to stand up for a wildlife issue that is very important to me. Last year a petition calling for an immediate ban on shooting Badgers in England gathered over 106,000 signatures.

    The petition is being debated in Westminster Hall, on Monday March 21st at 16:30. As your constituent, I am asking you to attend this debate, and support the call for a ban on the inhumane practice of shooting Badgers.

    I feel that this is an important and timely debate, coming at a crucial time for Britain’s wildlife. As you know, the Animal Welfare (Sentience) Bill (2021-22) is currently making its way through the House of Commons, drawing attention to animal welfare issues and recognising animals as sentient beings. In England, the Environment Act has set in stone targets to end the decline of species by 2030.

    It seems to me that in the midst of a biodiversity crisis, we should not be pursuing massive culls of a native species. These types of interventions should only be considered if there’s robust scientific evidence to show they’re the only way to address a problem and they can be carried out humanely.  I don’t believe either of these factors is true in the case of the culling of Badgers.

    May I please ask you to attend the debate on shooting Badgers on Monday 21st March at 16:30?

    Yours sincerely,

    Provide name (including surname) and address and telephone number (to show that you really are a constituent and therefore deserve a proper response)


  35. Breaking News: Date confirmed for Badger-shooting debate

    Comments Off on Breaking News: Date confirmed for Badger-shooting debate
    Photo credit: Vincent Van-Zalinge

    Breaking news: you may remember our petition calling for a ban on shooting Badgers in England. You might have been one of the the 106,108 people who signed it back in 2020.

    At the time, we argued that shooting is poorly monitored and is a method of culling that is inhumane. We said we believe it has never met the animal welfare standards recommended by a 2014 Independent Expert Panel, whose recommendations were accepted by DEFRA. We therefore called for a ban on shooting Badgers in England. 

    Today we’ve heard our petition will be debated by MPs in Westminster Hall at 16:30 on Monday March 14th. Update: The debate on Shooting Badgers in England has been postponed to Monday 21st March, at 16:30. This is rather short notice, so we’d like your help in making sure Badgers get a fair debate on the day. Nick Fletcher MP, a member of the Petitions Committee, will open the debate.

    If you live in England, please consider writing to your MP and asking them to attend the debate on the 21st. By speaking up, you’ll demonstrate there is a widespread support of this ban across the country.

    We’ll be updating shortly on the time and full details of the debate [updated 17:10, 2 March], and will also share some suggested wording for contacting your MP in due course and initially through our newsletter. For now, please add the date to your diaries, and consider watching live on the day.

    More details soon…

  36. Chris Loder MP and the eagles (3) – Poll Results & MP Responses

    Comments Off on Chris Loder MP and the eagles (3) – Poll Results & MP Responses

    Recently Chris Loder MP ruffled feathers after declaring that his constituency county of Dorset ‘is not the place for eagles to be reintroduced’. Following the news of two White-tailed Eagles found dead under suspicious circumstances, one of which was on a shooting estate in Dorset, Mr Loder’s views highlighted the frustrating and far-too-frequently seen culture of intolerance towards birds of prey in the UK.

    We wanted to see if this feeling was shared widely– so we launched a simple Twitter poll asking if birds of prey, like White-tailed Eagles, are welcome where you are.

    Twitter Poll: 99.3% of respondents said ‘birds of prey welcome’, 0.3% said ‘birds of prey, no thanks!’.

    We’re pleased to say of the nearly 4,000 of you who responded, the overwhelming majority (97.3%) welcome birds of prey. The tiny minority (0.3%) saying ‘no thanks’ to birds of prey represented less than 30 people. This is quite a clear-cut result, even if we know our audience is generally a wildlife-friendly one.

    We were also interested to see if this anti-eagle sentiment was shared by other MPs and elected representatives across the UK – so we asked you to write to them. Thank you to those who did; we’ve now started hearing some responses back. They’re mixed, and interesting.

    Some, like this response from, are generally supportive of the reintroductions and welcomed an investigation into the two recently reported deaths:

    Dear ________
    
    Thank you for contacting me about White-Tailed Eagles.
    
    I would like to assure you that my ministerial colleagues are committed to the recovery of species, including wild birds. I welcome that the Environment Act 2021 includes a new legally binding target to halt the decline in species abundance by 2030. I know that ministers continue to provide opportunities for successful reintroductions such as white-tailed eagle to the Isle of Wight, pine marten in the Forest of Dean, and restoring populations of hen harrier and curlew.
    
    I am aware that several schemes to reintroduce white-tailed eagles have been working across the UK. Like you, I was very concerned to hear that two of these eagles have recently been found dead. I welcome that police are investigating these deaths, with post-mortem and toxicological examinations being conducted.
    
    Thank you again for contacting me on this issue.

    Others were more aligned to Mr Loder’s views – sharing a similar scaremongering rhetoric about the risk of White-tailed Eagle reintroduction to people’s pets:

    Thank you for your email concerning the potential reintroduction of white-tailed eagles to Herefordshire.
    
    I am not against the reintroduction of certain species in principle.
    However, I am reluctant to support the reintroduction of large predators and raptors due to their impact on livestock and people’s pets.
    
    As a resident of Herefordshire, I am sure that you can appreciate the stress and misery which is caused to farmers by dogs which attack or worry their livestock.
    However, in the case of dogs worrying livestock, there is at least an owner that is legally responsible for the behaviour of their pet.
    
    Eagles of course have no owner, and there would therefore be no way of compensating farmers affected when they attack sheep.
    That is not even to mention the potential anguish which could be caused when eagles kill or carry away beloved family pets.
    
    The cost of these reintroduction programmes cannot be ignored.
    I believe that the money spent on these could be used better in other areas of conservation.
    
    Thank you again for writing to me.
    Yours sincerely

    Then some were short but sweet – like this one:

    Thanks. Mr Loder’s views are his own and he is not accountable to me. I support the Eagles!
    

    Whilst only a tiny sample, it goes to show opinions are divided. These three responses were all from Conservative MPs, so attitudes differs even within political parties. The fact that misinformed opinions and inaccuracies about wildlife are shared quite widely is a worrying thing. As always, we’ll be working to correct and challenge this.

  37. New research: lead levels in pheasant meat haven’t reduced two years on from voluntary transition to non-toxic shot.

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    Two years ago a group of shooting organisations, including BASC and the Countryside alliance, announced a five-year, voluntary transition away from using toxic lead shot in the UK. 

    New research, reported yesterday in The Guardian, has shown that to date, this voluntary phase-out has had no measurable effect in reducing the levels of lead in pheasant meat. Of 215 birds found to containing pellets or pellet fragments, 99.5% were shown to have been shot using lead.

    In response to the news, Wild Justice said: “Another 12 months of zero progress from the shooting industry. All talk and no action. UK governments should simply ban the use of lead ammunition rather than let this charade continue.”

  38. Please help us defend Badgers in Northern Ireland

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    This morning Wild Justice launched a new fundraising appeal. Once again we are looking to challenge a proposed cull of Badgers – this time in Northern Ireland.

    So far, over 500 of you have backed our fundraiser, donating over £12,000 towards our challenge. Thank you to everyone who’s donated!

    So, what’s this about?

    Back in 2021, the Department of Agriculture, Environment and Rural Affairs (DAERA) proposed a cull of Badgers that could commence as early as July 2022.  

    Working closely with our friends, the Northern Ireland Badger Group (NIBG), we looked into the legality of DAERA’s proposal, and we spotted an issue. In their proposal, DAERA made repeated references to there being a ‘business case’ for culling badgers. Despite multiple requests being made, neither Wild Justice nor NIBG have been granted access to this ‘business case’, nor the evidence used to make it. For this reason, we believe that DAERA’s proposition to carry out a cull of Badgers has not been subject to lawful consultation with the public.

    Wild Justice are now seeking a Judicial Review of the lawfulness of DAERA’s proposed Badger cull and have sent DAERA a formal legal letter as the first step in this process. Now comes the part when we ask for your help!

    The first stage of the challenge will cost £50,000; these funds will go towards paying our lawyers, court costs, the costs of research and costs awarded against us if our challenge is unsuccessful. Wild Justice is meeting the costs of the NIBG in this case. Some of this money has already been spent from our savings but we can’t take the challenge all the way without raising more funds.

    Please support our fundraising appeal here. We’re really grateful for any support you can give us.

    This is just the latest attempt to cull Badgers in the UK; it’s a topic Wild Justice have campaigned on a lot in the past, particularly relating to culls in England. This time we’re taking the fight to Northern Ireland, and we’d really appreciate your support.

  39. Chris Loder MP and the eagles (2) – what does your elected representative think?

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    Chris Loder MP’s views (see preceding blog post) don’t seem to be getting much support on social media – our little poll has passed 2000 votes and there are fewer than 1% of responses saying ‘No thanks’ to birds of prey.

    But given the continuing unremitting news of illegal killing of birds of prey, and persecution of other wildlife and general lack of respect for wildlife, this seems like an opportune moment to check in with our elected representatives and speak up for birds of prey as iconic and threatened wildlife.

    So, Wild Justice is asking you to write to your MP or MSP, MS or MLA (England, Scotland, Wales, Northern Ireland) along the following lines, just as a guide;

    TEXT TO CONSIDER SENDING TO YOUR ELECTED REPRESENTATIVE:

    Dear ______

    I am writing to you as a constituent, to ask for your opinion on a wildlife issue that is very important to me. I was saddened to hear the recent news that two White-tailed Eagles have been found dead in Southern England, but I was dismayed to read Chris Loder MP’s view that ‘Dorset is not the place for eagles to be reintroduced’ and that eagles are ‘killing our lambs and plaguing our farmers’.

    White-tailed Eagles are a native UK species; they belong here. Dedicated conservation organisations, such as the Roy Dennis Foundation, have worked hard to reintroduce this remarkable bird, which was previously driven to extinction in the UK through a range of factors but mainly the type of human persecution that is now, rightly, illegal.

    White-tailed Eagles have been successfully reintroduced to Scotland, thanks to a lengthy and expensive, but very successful, project by many individual conservationists and conservation organisations. Since the recent releases on the Isle of Wight, members of the public have been thrilled to spot White-tailed Eagles soaring in skies across the UK; from Scotland to the Midlands, and even over Westminster.  On Mull the reintroduced White-tailed Eagles draw people to the island to see the birds, enjoy the scenery and spend their tourist money in the local community. Whichever way you look at it, they are an asset.

    Birds of prey, including eagles, have suffered centuries of persecution in the UK. It’s disheartening to see outdated, anti-bird-of-prey sentiments being expressed by elected political representatives. Raptor persecution is still a problem today, despite it being a wildlife crime, and perpetuating these antiquated opinions is not what we need in the midst of today’s biodiversity crisis.

    I hope to see the UK become a place that White-tailed Eagles, and indeed all native birds of prey, are both welcome and able to thrive in a healthy natural environment, free from persecution.

    Can I ask if you would welcome White-tailed Eagles and other birds of prey in your constituency?

    Yours sincerely,

    Provide name (including surname) and address (to show that you really are a constituent and therefore deserve a proper response)

    We’d be interested to see any responses you get. There will be some Wild Justice supporters who are constituents of Chris Loder himself – please do write to him politely but firmly if you disagree with his views.

    It seems very strange that when UK wildlife is in such a poor state, that elected representatives can speak out against restoring wildlife to its former areas, and when so often the reason for wildlife lossses is criminal behaviour, that elected representatives can act as though that criminality is a low priority. We need a re-boot of the political consciousness so that all that talk about restoring wildlife and stopping its decline is translated into action. Please send that message today.

  40. Chris Loder MP and the eagles (1) – a quick poll

    Comments Off on Chris Loder MP and the eagles (1) – a quick poll

    Last week, following the news that two White-tailed Eagles from the Isle of Wight reintroduction project had been found dead, and an appeal from Dorset Police for information, Chris Loder MP took to Twitter to declare that ‘Dorset is not the place for eagles to be reintroduced’. He also stated that he’d prefer Dorset Police to focus on issues other than potential wildlife crime. Following widespread public criticism, Mr Loder doubled-down on his viewpoint, going on to accuse eagles of ‘killing our lambs and plaguing our farmers’.

    Mr Loder is entitled to have whatever views he wants on the matter of White-tailed Eagles (although his statements included inaccuracies which should have been checked) but his remarks exemplify the intolerance which is shown all too often to wildlife in our country.  Whenever conservationists seek to restore lost wildlife there seems to be an uproar, whether it be White-tailed Eagles, Pine Martens, Beavers or even restoring woodlands or wetlands. Mr Loder is not alone in his views and, in a strange way, he has done us all a favour by voicing them so publicly.

    So here is a quick and easy way you can voice your views. Yesterday evening we launched a simple poll on Twitter asking whether you welcome White-tailed Eagles or not – over 1000 responses have been received overnight with overwhelming support for eagles  – please add your voice in their favour here – the more the better. Thank you!

    We’ll come back to this issue later today.

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  41. Update: Consultation on General Licences in Northern Ireland

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    Back in December, Wild Justice were successful in a legal challenge to Northern Ireland’s general licences for the killing of wild birds.

    At the time, the Department of Agriculture, Environment and Rural Affairs (DAERA) conceded our claim that the decision to issue three general licences on 10 September 2021 that permit the killing of birds in the province is unlawful.

    DAERA also stated they’d be replacing their flawed general licences with interim licences, and promised that a full public consultation would be launched in due course. We’ve been waiting patiently.

    So far in 2022, Wild Justice have pressed DAERA on when it will be consulting on general licences. Last week, we received a reply, saying the consultation will start in late February or early March. This is later than DAERA promised, but as least we have an idea of timelines.

    We will be keeping a close eye on this, and will update as things develop…

  42. It’s our birthday!

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    Three years ago Wild Justice had its public launch. We’re still very much new kids on the conservation block and yet, with your support, we’ve made some progress on a wide range of issues. We’ve had some successes, and some disappointments, but we’ve made waves and made public bodies sit up and pay attention – and begin to raise their game in some areas. That’s not bad for an organisation which is essentially three mates and is only in its infancy.

    As a birthday present we’d ask you to spend a moment thinking of whether you have some friends, relatives or colleagues who would be interested in Wild Justice’s campaigns and legal challenges. If so, please tell them about this website and our free newsletter and then maybe they’ll help us celebrate our fourth birthday and the achievements of the year to come. Thank you!

  43. Delaying tactics

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    We’ve learned, since our public launch on 13 February 2019, that public bodies almost always try to delay any legal challenge against them, despite the procedures set out for judicial review proceedings. We’ve decided to push back harder on these requests as below. The procedure in England requires all the relevant steps of a legal challenge to be carried out in a timely manner. If more time is sought then good reasons should be given.

  44. Our legal letter challenging Defra’s General Licence GL42

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    We recently blogged about our initial steps to challenge Defra on the lawfulness of General Licence GL42. Whilst we wait for a response, here is the letter setting out the legal issues which DEFRA has to address.

    Unless we receive a legally watertight and convincing response to that letter by 4pm a week today we will proceed to seek permission for judicial review of DEFRA’s decision.

  45. Wild Justice starts legal challenge of DEFRA’s general licence GL42.

    Comments Off on Wild Justice starts legal challenge of DEFRA’s general licence GL42.

    Our infographic above captures the absurdity of DEFRA’s position on whether birds such as Pheasants and Red-legged Partridges are or are not livestock. It seems they are whenever it suits the shooting industry but not when it doesn’t.

    On 1 January, the Department for Environment, Food and Rural Affairs (DEFRA) issued a new general licence, GL42, which authorises the killing of certain species of birds (mostly of the crow family), in England, to protect livestock from serious damage. Changes to the wording in that licence, that Wild Justice understands were introduced after pressure from shooting and farming interest groups, attracted public concern (see this article in The Guardian and this from George Monbiot). Last week, after receiving legal advice, Wild Justice sent a formal legal letter to DEFRA as the first stage of a challenge of the lawfulness of GL42. Unless we receive a legally watertight and convincing response to that letter we will proceed to seek permission for judicial review of DEFRA’s decision.

    The context for this legal challenge is that all wild birds in the UK are protected by law with two main exceptions, both of which are in play in this case: gamebirds and species listed on general licences.

    Gamebirds, which include the non-native Pheasant and Red-legged Partridge, can be killed in the open seasons. Around 50 million Pheasants and 11 million Red-legged Partridges are released into the UK countryside every year (Covid, Brexit and Wild Justice’s legal action will have reduced numbers in the last couple of years) and around 30% of these birds are shot while the rest die of disease, starvation and are taken by predators, most notably mammalian predators such as foxes.

    General licences permit the killing of certain specified bird species, such as species of crow, under certain specified circumstances with certain specified conditions attached. If you meet the conditions and are acting in the specified circumstances then you are covered by the general licence to kill listed species. You don’t have to apply for your own licence, you are covered by the general licences which are published on government websites.

    The 2022-23 version of GL42 appears to broaden the circumstances under which gamebirds can be considered livestock and therefore can be protected from corvids. It does so by introducing the concept that gamebirds can be ‘dependent’ on their human owners or keepers even after they are released into the countryside, at any time in the future and at any distance from their release site.

    Wild Justice said:  Any licence authorising killing of wildlife should be clear about when it can be used. DEFRA’s GL42 fails that test. In any case, why is DEFRA fiddling with definitions of livestock while wildlife declines?

    Coverage of this story in the Guardian – click here.

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  46. Wild Justice Raptor Forensic Fund helps secure conviction of buzzard-killing gamekeeper John Orrey

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    Gamekeeper John Orrey, 63, of Hall Farm, Kneeton, Nottinghamshire was sentenced today at Nottingham Magistrates Court (see here) after being convicted of the following 5 x wildlife crime and 4 x firearms charges:

    • Possession of two dead stock doves.

    • Intentionally killing a common buzzard on 8/1/21

    • Intentionally killing a common buzzard on 9/1/21

    • Using a cage trap to kill or take a wild bird

    • Possession of an article (slash hook) capable of being used to commit an offence

    • Failure to comply with condition of shotgun certificate (weapon not securely stored)

    • Failure to comply with condition of firearms certificate (ammunition not securely stored)

    • Failure to comply with condition of firearms certificate (weapons and ammunition not securely stored)

    • Possessing ammunition for a firearm without a certificate

    Photo of John Orrey from BBC News

    In relation to the killing of the buzzards, for each bird he received an 18-week suspended sentence to run concurrently and a £500 fine for each bird. He was also ordered to pay £650 costs and £50 victim surcharge, and £180 compensation to the Raptor Forensics Fund established by Wild Justice in 2020.

    Our fund was used to pay for the cost of two post mortems on the Stock Doves found dead inside Orrey’s trap – they had both been shot (this is illegal as they’re a protected species). We’re delighted that Nottinghamshire Police were able to access this fund to help during the preliminary investigation into Orrey’s crimes and we’re even more delighted to hear that the District Judge ordered Orrey to pay a compensation fee covering the full amount. This money will go directly to the Raptor Forensic Fund to be recycled on another case.

    This is the second conviction that our Raptor Forensics Fund has helped secure. The first one was gamekeeper Hilton Prest who was found guilty in December 2021 of the unlawful use of a trap (see here).

    Thank you to all those who contributed to our Raptor Forensics Fund and thanks also to the PAW Forensic Working Group (a sub-group of the Partnership for Action Against Wildlife Crime) who administer our fund and ensure that police officers can access it without delay to help progress their investigations into raptor persecution crimes.

  47. An open letter to the statutory conservation sector

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    Wild Justice is one of a very large number of NGO signatories to this open letter to the statutory conservation sector in England, Wales and Scotland. It’s pretty strong wording for a letter of this type and that is because the NGO cosnervation community is losiong patience with the statutory sector as it continues to fail our wildlife despite warm words from politicians.

  48. Judicial Review and Courts Bill – we get a mention, but not by name

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    https://hansard.parliament.uk/commons/2022-01-25/debates/7807EF40-EB32-461F-9594-9BB21B919988/JudicialReviewAndCourtsBill

    Yesterday the Judicial Review and Courts Bill was debated in Committee. The Opposition were trying to get rid of Clause 1 which would allow, under some circumstances, judges to impose Suspended or Prospective-only Quashing Orders when a party, perhaps a party such as Wild Justice, wins a Judicial Review of a decision by a statutory body. This could mean, as we understand it, that you or we could take a legal challenge, at considerable expense, win it by persuading the courts that the public body had behaved unlawfully, but instead of getting a rapid change to matters on the ground such resolution of an unlawful state of affairs would be postponed. So you win, but nothing changes for ages.

    As the coalition of countryside and environmental organisations, Wildlife and Countryside Link, say:

    Judicial Review is an important tool for securing remedies for unlawful decisions which will or could harm the environment.

    Clause 1 of the Judicial Review Bill introduces changes to JR that could make it impossible for claimants to secure effective remedies for unlawful decisions.

    As currently drafted, clause 1 would … introduc[e] the possibility (through suspended and prospective quashing orders) that the decision could be found unlawful, but the remedy denied or delayed and harmful consequences allowed to continue.

    Claimants faced with this potential outcome will be significantly less likely to invest time and money overcoming the considerable JR hurdles, for fear of wasted effort and expense. The knowledge that winning might not actually prevent the damage that prompted litigation could prevent many potential claimants from starting proceedings.

    https://www.wcl.org.uk/docs/assets/uploads/The_Judicial_Review_Courts_Bill_and_the_Environment_Briefing_for_Report_stage_20.01.22.pdf

    The Justice Minister, James Cartlidge MP, did his job in opposing the amendment on this subject, thus:

    Amendment 1 and amendments 2 and 3, which are consequential on amendment 1, would remove one of the new tools we are proposing—namely, prospective-only quashing or quashing with limited retrospective effect. Let me remind the House of an example I have used previously of a real situation where the existence of the remedy could have been useful. It occurred when Natural England, in response to a threatened judicial review, decided to revoke general licences enabling farmers, landowners and gamekeepers to shoot pest birds. The revocation created immediate chaos for licence holders. I do not seek to re-litigate this case in the Chamber, but as I have said before, had the proposed remedies been available, Natural England may have been more willing to contest the judicial review, knowing that even if the existing licensing scheme was found to be unlawful, the court had the ability to protect past reliance on old licences. Such cases provide a tangible example of how more flexible remedies will allow courts to respond pragmatically and assist our constituents, rather than detract from their interests.

    Column 910 https://hansard.parliament.uk/commons/2022-01-25/debates/7807EF40-EB32-461F-9594-9BB21B919988/JudicialReviewAndCourtsBill

    That real situation was Wild Justice’s (they dare not name us, we are treated like V***emort) successful legal challenge of Natural England’s unlawful general licences – the challenge that has led the way to significant changes of general licences across the UK (and we hope there is more to come).

    Read the last sentence of the Minister’s words. He’s saying that the fact that the general licences were unlawful is very inconvenient to his constituents but what he might really mean is that it is a bit inconvenient to a tiny proportion of his constituents who were using those unlawful general licences but with whom he tended to associate himself. Or, that even if the licences were unlawful then it should be possible, under the government’s proposals, to carry on the behaviours unlawfully permitted to save some gamekeepers any inconvenience. It’s a very strange example to choose, but it’s interesting that it was the best he could do, and may not be the wisest line to take for a government mired in controversy over whether laws are meant for everyone except themselves.

    It’s interesting that the Justice minister suggests that in future Natural England might have taken the case to court – really? Knowing, as they did, on the basis of the strongest and clearest legal advice that their licences were unlawful? Really? And at public expense fight a doomed case? Really?

    What does this government really mean by the courts ‘responding pragmatically’? It should not mean turning a blind eye to unlawfulness and allowing it to persist. But that is the message we take from the minister’s own words on why Clause 1 is such a good thing. Why is a Justice Minister arguing for continued unlawfulness rather than a rapid adoption of the law? Mr Cartlidge, are you in the right job?

    Maybe the Minister should have a chat with his fellow Conservative and former Cabinet minister, David Davies MP, who said;

    Judicial review is a cornerstone of British democracy. It empowers everyday people to challenge decisions made by public bodies. Whether it be central government or local authorities, rule makers are held accountable by ordinary people. This is a small, but important, check on the balance of powers in our democracy.

    https://www.wcl.org.uk/docs/assets/uploads/The_Judicial_Review_Courts_Bill_and_the_Environment_Briefing_for_Report_stage_20.01.22.pdf
  49. Hapless Natural England on the wrong side of the argument again?

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    This new ‘guidance’ from Natural England looks very worrying to us.

    The whole drift of this guidance is to allow developers to do less for wildlife.

    This is a particularly striking example:

    Oh good oh! This is written by England’s statutory nature conservation body. Who’d have known?

    Natural England used to be a nature conservation body of repute – no longer.

    Wild Justice is seeking legal advice on this guidance. We would be interested to hear the opinions of experts on the ramifications of the policy shifts signalled in this paper. It might even be that Natural England staff are pretty uncomfortable with this. Please let us know at admin@wildjustice.org.uk All communications will be treated sensitively.

  50. Glyphosate: taking the p*ss study

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    Wild Justice is interested in the use of the powerful pesticide glyphosate in the environment – as are many others.  With your help – click here for details – we have contacted local authorities across the UK to ask about their compliance with the requirements of pesticide legislation and simply asking questions is nudging local authorities to make further reductions in use. Glyphosate, is also used in gardens and on farmland. 

    There are concerns, hotly disputed, that glyphosate may be a carcinogen. UK authorities do test some foods for glyphosate levels. 

    The renowned entomologist, Prof Dave Goulson, is campaigning for a ban on the use of glyphosate in gardens – see his petition here.  

    Based on fairly small sample sizes there is an indication, no more than that, that levels of glyphosate in UK residents are higher than the average in Europe. You probably have glyphosate in your body – over 70% of Europeans do, and the UK figures are slightly higher than average. Would you like to find out?  If so, and if you would consider participating in a future Wild Justice investigation of glyphosate levels in UK citizens, then read on.  

    How to discover your own glyphosate levels: this website will send you a glyphosate testing kit that you can use in your own home and send off a urine sample to a laboratory in Germany which will send you your results.  The cost of the testing and postage is about £40 (depending on the £/euro exchange rate) so it is a significant investment. And all you’ll get for it is a figure for the glyphosate level in your urine that you can compare with averages for other European countries.   However, if you share your results with us at Wild Justice, we will ask you whether you would like to take part in a study of glyphosate levels in UK citizens that will track glyphosate levels in individuals to discover more about their trends through the year and any links with lifestyle etc.  We will pay for all the test kits of those invited to participate in the study.  What we can study will depend on the number of you who are interested in participating.  

    Mark Avery sent off for a urine testing kit last autumn, followed its instructions and got his results by email a couple of weeks later. Mark’s glyphosate levels were 2.5nm/ml – a bit higher than both the European and UK averages.  Mark said ‘The process was pretty straightforward and I was interested to find that my levels were higher than average.  I wonder why. We don’t use pesticides in the garden but I live in an arable farming area where glyphosate is used, and my local authority uses glyphosate too. Perhaps I am picking up glyphosate from the food I eat.  I’m interested to know more but that would need a bigger sample of people. Will you join me in taking the p*ss?’.  

    So, the offer on the table to you is to find out your own glyphosate levels through buying a test kit and sending off your urine to be tested. When you get your results then if you’d like to share them with us please forward them to Wild Justice at admin@wildjustice.org.uk . Depending on the response, we may invite you to become part of a study to investigate glyphosate levels and their variability and lifestyle correlates.  Wild Justice will then reimburse the costs of testing kits.  

    Do consider this: you will probably find that you have glyphosate in your urine – 70% of people across Europe who have done similar tests do find that. Levels vary and there are no levels yet set by governments that indicate dangerous levels.  There is some evidence that glyphosate is a carcinogen but opinions differ, and the levels at which it has any human health impact, if any at all, are not well known. So it is just possible that you will find that you have ‘high’ levels of glyphosate in your urine and you might find that worrying. It is very likely that you will find that you have some glyphosate in your urine which will mean that you are like most other people living in Europe. If you would rather not know how much glyphosate you have in your urine then please don’t send off for a test kit.  If you are interested to learn what your glyphosate levels are and feel pretty confident that you can cope with any results that come through, then that is your choice.  Give it some thought before doing anything please.

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  51. A disappointment on burning regulations

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    Earlier this week, we had a disappointment when the Court of Appeal did not give us permission to appeal the refusal of our case against the Westminster government on its feeble burning regulations.

    We have taken this challenge as far as we can and we are very disappointed that, in this case, the courts have not been helpful in holding DEFRA to account. We still believe that we had a strong case (otherwise we would not have persevered with it) and that the decision that DEFRA made on limiting burning on blanket bogs was not only cowardly and feeble in its scope but unlawful in the way that it was made. But we haven’t persuaded the courts of our case.

    Protecting upland habitats from damage, and protecting the carbon stored in peatlands, will remain an area of importance and interest to Wild Justice, as it is to many other environmental organisations. Greater limits to burning on peatland soils should be brought in, and we’ll be working with others to bring this about as soon as possible.

  52. Top recognition for Wild Justice lawyer

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    Huge congratulations to David Wolfe QC, who has featured in The Lawyer’s Hot 100 list published today.

    David is a barrister at Matrix Chambers in London and here is what they had to say:

    The prestigious list – from the leading UK legal magazine The Lawyer – celebrates the work of the top 100 lawyers in the UK from private practice, in-house and the Bar. The list, which is published annually, recognises extraordinary lawyers who have completed ground-breaking work in the past 12 months.

    The Lawyer recognised David for his work on a number of significant environmental cases in 2021 including Save Stonehenge World Heritage Site and Wild Justice.

    The Lawyer commented:

    “…on many occasions Wolfe’s presence has resulted in real change in the battles for climate and social justice. His work is increasingly strategic in nature as he manages ever-larger teams, and helps equip the next generation of barristers with the skills to carry on the fight.”

    The full article is available here.

    Photo of David talking with Chris Packham during a Wild Justice gathering last year (photo copyright Wild Justice)

    We are privileged to be able to work with a team of exceptional lawyers from Leigh Day and Matrix Chambers who have been with us right from the start; indeed they encouraged us to form Wild Justice as a legal entity. Without their expertise and encouragement, we simply wouldn’t be making the progress we’ve achieved over the last few years.

    David has been central to our work and not only is he an intellectual dynamo, he’s also a thoroughly lovely guy. We’re delighted to see this richly-deserved recognition from his peers.

    Well done!

  53. The Bunker Podcast features Mark Avery explaining the ills of driven grouse shooting

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    The Bunker is an independent political podcast examining the big issues of the UK.

    In this week’s episode, Wild Justice Co-Director Mark Avery discusses driven grouse shooting with host Arthur Snell, with a particular focus on the illegal killing of birds of prey that takes place on many driven grouse moors.

    You can listen to the 25 minute podcast here : https://kite.link/BK1201Raptor

  54. Wild Justice’s Raptor Forensics Fund helps secure 2nd gamekeeper conviction

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    We’re delighted to learn that our Raptor Forensics Fund, established in 2020 to help support police investigations into alleged raptor persecution crime, has played a part in the conviction of a criminal gamekeeper in Nottinghamshire.

    The full details of this conviction will be made public after a sentencing hearing later this month but for now, a summary article can be read here.

    This is the second conviction that our Raptor Forensics Fund has helped secure. The first one was gamekeeper Hilton Prest who was found guilty in December 2021 of the unlawful use of a trap (see here).

    Thank you to all those who contributed to our Raptor Forensics Fund and thanks also to the PAW Forensic Working Group (a sub-group of the Partnership for Action Against Wildlife Crime) who administer our fund and ensure that police officers can access it without delay to help progress their investigations into raptor persecution crimes.

  55. What are regulators for? Wye, Wye, Wye?

    Comments Off on What are regulators for? Wye, Wye, Wye?

    There have been a few local media reports about Wild Justice taking legal action on the shocking state of environmental protection on the River Wye but we haven’t said anything about this case until today when we talked to the respected ENDS report.

    This just happens, a complete coincidence, to follow a long and good piece about the River Wye on the BBC R4 Today programme yesterday. Have a listen to it – click here (1:35 – 1:45) – it’s a good summary and well worth listening all the way through to the remarks of Jesse Norman MP, where he said he was much less confident about progress than the report made everything seem, and ‘I do not think it is right at this stage to strike a note of confidence of any kind‘ , and ‘The agencies involved, Natural Resources Wales, Natural England and the Environment Agency have, in my view, done a deplorable job, so far, in their failure to come together with an all-river action plan‘.

    That sounds about right to us, which is why we have been in legal correspondence with all three agencies for the past couple of months. Previous spokespeople in the piece seemed to be happy with the progress that had been made – we don’t think they should be. The trouble is that the progress made is a bit like a debtor paying off their massive debts at the rate of a pound a month – you can call it progress if you like, it’s marginally better than nothing, but it really doesn’t do the job, and never will.

    The Wye is a Special Area of Conservation (see here) and should have, in theory does have, the highest environmental protection that the UK can hand out, but as the radio piece said, last year it turned lime green because of pollution. That doesn’t sound very protected to us, and it doesn’t sound much like progress.

    Wild Justice has given the three agencies the chance to get things right, but we haven’t gone away and we will be monitoring the situation closely over the next few months.

    Wild Justice told ENDS: Statutory agencies exist to regulate damaging activities. The Wye is a test case. Wild Justice is watching things closely.

  56. New legislation proposed by Westminster government on hare coursing

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    Photo via shutterstock

    Yesterday the Westminster government announced its intentions to crack down on cruel and illegal hare coursing. Wild Justice welcomes these proposals.

    The main points are:

    • Increasing the maximum penalty for trespassing in pursuit of game under the Game Acts (the Game Act 1831 and the Night Poaching Act 1828) to an unlimited fine and introducing – for the first time – the possibility of up to six months’ imprisonment.
    • Two new criminal offences: firstly, trespass with the intention of using a dog to search for or pursue a hare; and secondly, being equipped to trespass with the intention of using a dog to search for or pursue a hare both punishable on conviction by an unlimited fine and/or up to six months’ imprisonment.
    • New powers for the courts to order, on conviction, the reimbursement of costs incurred by the police in kennelling dogs seized in connection with a hare coursing-related offence.
    • New powers for the courts to make an order, on conviction, disqualifying an offender from owning or keeping a dog.

    Wild Justice has played a small part in helping government to get to this point. This is what we’ve done:

    • met senior police officers to learn what they thought was the way forward
    • met with the NFU and offered our help and support
    • promoted a petition on this subject by including it in our newsletter over a year ago
    • worked as part of Wildlife and Countryside Link to recommend some of the changes that have now been accepted by government

    As we say, we’ve only played a small role in this issue because it’s quite a crowded field (as it were). Hunting and farming organisations have largely worked on their own and separately from conservation and animal welfare organisations who have approached the issue from a different perspective. Wild Justice is obviously interested in the legal aspects of this issue, and the fact that this is one of the many wildlife crimes that need sorting out in the countryside. We look forward to seeing some action taken on wildlife crimes by government and landowners in other areas, particularly upland areas. There are clear parallels – crimes against wildlife, motivated by killing for entertainment and profit, occurring in remote rural areas.

    You may be interested to listen to this piece on yesterday’s Today programme (from 52.48 to 57.00) where Chief Inspector Phil Vickers describes some of the facts behind hare coursing. The strange part of the interview is that landowners are seen as the victims of this illegal activity and Brown Hares, who certainly are victims, hardly get a mention…

  57. General licence confusion continues – Schrodinger’s Pheasant

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    https://www.theguardian.com/environment/2022/jan/03/law-change-allows-wild-birds-killed-protect-game-birds-england?CMP=Share_iOSApp_Other

    Yesterday this piece appeared in the Guardian online – we guess it will be in today’s print edition.

    The story relates to the new general licences for England, which are very largely unchanged from last year’s licences. These are the licences, not just in England but across the UK, that Wild Justice has caused to be reformed since our original legal challenge back in spring 2019.

    The law hasn’t changed, despite the Guardian headline; what has changed (back to a previous version) is the wording of the conditions of the licences. And they have changed to being two-year licences rather than annual ones. Talking of changes, it’s good to see that the Guardian has changed their original image of two Rooks to one of two Carrion Crows – Rooks are not really predators of gamebirds at any stage of the gamebirds’ lives.

    Pheasants and Red-legged Partridges (RLPs) are not native UK species. RLPs are native to Europe but Pheasants are primarily Asian species. The reason that Pheasants are common sights in the countryside is that 51 million of them are reared in captivity and released into the countyside in summer for shooting in autumn/winter (see a previous blog here). They may not be native but they are certainly beautiful.

    Pheasant. Photo: Andrew Parkinson

    So, Pheasants and RLPs are ‘livestock’ when they are being hatched and reared in captivity – there’s no doubt about that – they are just like chickens. The captive-reared birds are then transferred into the countryside to release pens from which they are, you guessed it, released in July-September ahead of the shooting season (starts 1 September for RLPs and 1 October for Pheasants). Are they livestock then? Well, we think they probably are, but in very large pens without roofs are they really in captivity because some time in this period they will become able to fly. What the Guardian piece refers to is the situation after the birds are ‘released’ and they are free to roam the countryside – are they still livestock then? Well, at some stage they become wild birds and they are out of the control of their ‘owners’. How do you recognise this transition? In Wild Justice we refer to this dilemma as Schrodinger’s Pheasant – can a Pheasant which occasionally nips back to a release pen to have a look around but spends most of its time dodging Foxes and cars still be livestock?

    Once a Pheasant or RLP is a wild bird then it is unlawful to kill bird species listed on the general licences to protect them – because they are simply wild birds (that’s the law). In fact, this is perhaps an interesting dilemma but an almost entirely pointless discussion because well-grown Pheasants (and RLPs) are not predated by any of the species listed on the general licences – they are too big for species like Carrion Crow to tackle. They aren’t called Carrion Crows for nothing.

    Wild Justice is very interested in DEFRA’s definition and we have explored this issue with them before. We will take legal advice again. If any old Pheasant wandering around the countryside is livestock when it suits shooting interests then it may be livestock when it doesn’t suit them. Pheasants cause many road traffic accidents each year, including some of human fatalities – do shooting organisations really want their members to be liable for insurance claims because their livestock are running wild? How about the many, many gardens that are visited by large numbers of released gamebirds which damage vegetables and flowers? It seems to us, but we will seek advice, that there are quite considerable disbenefits to shooting interests of the route down which DEFRA has gone (we’re guessing at the behest of shooting organisations).

    Watch this space.

  58. Thank you for your feedback

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    We get hundreds of emails a week and all of them are read. We can’t possibly reply to them all but we do read them. Our free newsletter is our main means of communicating with people interested in our work and we’re always pleased to have new subscribers – click here.

    Our latest newsletter prompted many of you to respond to it wishing us a happy new year – thank you.

    Here are some of your comments:

    • Wishing you all the best and strength to continue this important campaign for the good of all.
    • Bless you all & thank you for your amazing work this year. Love you Chris!! Please keep up yr valuable efforts which Nature the environment & all of us depend .
    • Just donated, thank you for everything you do for animals. I am furious that we still have to fight the same battles at the start of 2022 but I think that despite all the horrendous things happening there are still more good people around than bad and together we can all make a difference. The bullies don’t like that so let’s keep doing it!
    • Happy New Year to you all. What fantastic things you have achieved.
    • As ever I find the news coming from your actions really heartening. It gives me hope. Thank you. Please continue in your great work with every effort, as I am trying in my small way.
    • I would just like to say how much I appreciate the work of everyone involved in this work. It’s great and really cheers me up. Much love and happy new year to everyone.
    • Thank you for all you do.
    • Thank you …all of you….for committing to all that you do. I donate when I can…as a 78 year old Great Grandmother…..I wish that Wild Justice Existed many years ago. I respect and admire the founders and all the volunteers. Thank you, all of you. A Healthy, Productive, successful, truthful 2022 are my sincere wishes.
  59. A quick review of Wild Justice’s 2021

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    Here’s a quick run through our work in 2021 – for more details see individual blog posts:

    January: our challenge of the legality of general licences in Wales elicits very useful clarification of the system including the highlighting of the need for there to be a ‘present danger’ to species of conservation concern for lethal control to be authorised.

    February: DEFRA launches gamebird release consultation as a result of Wild Justice’s legal challenge – hundreds and hundreds Wild Justice supporters take the opportunity to respond. Our petition to the Westminster government on Badgers passes 100,000 signatures (but still awaits a Westminster Hall debate)

    March: Wild Justice is a member of the Wildlife and Countryside Link partnership which launches a petition calling for legally binding targets in the Environment Bill – great response from Wild Justice supporters. We write to DAERA in Northern Ireland to point out flaws in their general licences which open them up for legal action, We write to Natural Resources Wales about their lack of response to the legal judgment in January on general licences.

    April: as part of Wildlife and Countryside Link, Wild Justice supports the End Wildlife Crime campaign ahead of the May elections for Police and Crime Commissioners.

    May: tests of Sainsbury’s game meat show that they have high levels of lead but we give Waitrose the benefit of the doubt in showing some signs of improvement in line with what they had told their customers. We highlight a potential breach of the general licences described in the pages of a shooting magazine.

    June: Wild Justice writes to Natural England about the very poor quality of their IUCN assessment for their Hen Harrier reintroduction project. WCL petition on Environment Bill passes 200,000 signatures. Wild Justice’s Ban driven grouse shooting petition is debated in Westminster Hall. Despite appeals, we lost our challenge on the humaneness of Badger culling in England.

    July: Wild Justice starts a legal challenge over the DEFRA feeble Heather and Grass Burning regulations. In Northern Ireland, DAERA issue a consultation on changes to their general licences in response to Wild Justice’s concerns over their scientific and legal flaws. Shooting Times columnist changes his story and says that what he wrote in the magazine was untrue.

    August: Wild Justice broadcasts a Hen Harrier Day programme highlighting the importance of the uplands for people, for the climate and for wildlife. NRW consults on general licences in Wales following our legal challenge. Wild Justice writes to several local authorities in England and Wales about their use of glyphosate .

    September: The Pheasant-shooting season approaches with, in England, restrictions on numbers that can be released thanks to Wild Justice’s legal challenge on gamebird release numbers.

    October: Scotland-based Trees for Life win an important legal challenge over Beaver protection which Wild Justice supported financially. As the COP26 starts in Glasgow our e-action, for people, for the climate and for wildlife passes 37,000 emails sent to every elected politician in the four UK national legislative bodies.

    November: the Environment Act becomes law and includes a legally binding target on species abundance thanks to the WCL campaign in which Wild Justice played a very active role.

    December: DAERA, finally, concede the unlawfulness of their general licences, issue new improved interim general licences and commit to consulting on the way forward. Wild Justice highlights continuing high lead levels in Sainsbury’s, Waitrose and Harrods game meat.

    Wild Justice is entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  60. Glyphosate use by local authorities – updated

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    Since we asked you to contact your local authority about their use of glyphosate, Wild Justice supporters have contacted over 275 local authorities across the UK.

    This is the template letter that many of you have used – click here.

    And here is the list (recent additions in red):

    Aberdeen City Council; Aberdeenshire Council; Adur & Worthing Councils; Allerdale Borough Council; Amber Valley Borough Council; Angus Council; Antrim and Newtonabbey Borough Council; Ards and North Down Borough Council; Argyll and Bute Council; Armagh, Banbridge and Craigavon Council; Arun District Council; Ashford Borough Council;

    Babergh District Council; Banes Council; Barnsley Metropolitan Borough Council; Basildon Council; Basingstoke and Deane Borough Council; Bassetlaw District Council; Bath and North East Somerset; Bedford Borough Council; Bedfordshire Borough Council; Belfast City Council; Blaby District Council; Blackpool Council; Bolton Council; Bolton Metropolitan Borough Council; Bournemouth, Christchurch and Poole Council; Bracknell Forest Council; Bradford Council; Braintree District Council; Breckland Council; Brentwood Council; Bristol City Council; Broadland District Council; Bromley Council; Buckinghamshire County Council; Burnley Borough Council; Bury Council;

    Caerphilly County Borough Council; Calderdale Council; Cambridgeshire County Council; Cannock Chase Council; Cardiff Council; Carlisle City Council; Carmarthenshire County Council; Central Bedfordshire Council; Ceredigion County Council; Charnwood Borough Council; Cheltenham Borough Council; Cherwell District Council; Cheshire East Council; Cheshire West and Chester Council; City of Edinburgh Council; City of York Council; Colchester Borough Council; Conwy County Council; Copeland Council in West Cumbria; Cornwall County Council; Cotswold District Council; Coventry City Council; Craven District Council; Crawley Borough Council; Crowborough Town Council; Croydon Council; Cumbria County Council;

    Dacorum Borough Council; Dartford Borough Council; Daventry Council; Derby City Council; Derbyshire County Council; Derbyshire Dales District Council; Derry City & Strabane District Council; Devizes Town Council; Devon County Council; Doncaster Council; Dorset Council; Dudley Metropolitan Borough Council; Dumfries and Galloway Council; Durham County Council;

    East Ayrshire Council; East Cambridgeshire District Council; East Devon District Council; East Dunbartonshire Council; East Hampshire District Council; East Hertfordshire Council; East Lindsey District Council; East Riding of Yorkshire; East Staffordshire Borough Council; East Sussex County Council; Eastleigh Borough Council; Elmbridge Borough Council; Erewash Borough Council; Essex County Council; Exeter City Council; Exmouth Town Council; Fareham Borough Council; Fenland District Council; Fermanagh & Omagh District Council; Fife Council; Filton Town Council;

    Flintshire County Council; Forest of Dean District Council;

    Gateshead Council; Glasgow City Council; Goudhurst Parish Council; Gravesham Borough Council; Great Yarmouth Borough Council; Gwent Council;

    Hackney Council; Hampshire County Council; Harborough District Council; Harrogate Borough Council; Harrow Council; Hart District Council; Hartlepool Borough Council; Havant Borough Council; Havering Borough Council; Herefordshire Council; High Peak Borough Council; Horsham District Council; Hull City Council; Hyndburn Borough Council;

    Ipswich Borough Council; Isle of Anglesey County Council; Isle of Wight Council;

    Kent County Council; Kings Llyn and West Norfolk Borough Council; Kirklees Council;

    Lambeth Council; Lancashire County Council; Lancaster City Council; Leeds City Council; Leicester City Council; Lincolnshire County Council; Liverpool City Council; London Borough of Barnet; London Borough of Bexley; London Borough of Camden; London Borough of Greenwich; London Borough of Hammersmith; London Borough of Haringey; London Borough of Hounslow; London Borough of Islington; London Borough of Merton Council; London Borough of Newham; London Borough of Redbridge; London Borough of Richmond upon Thames; London Borough of Sutton; London Borough of Tower Hamlets; Luton Council;

    Malvern Hills District Council; Manchester City Council; Medway Council; Mendip District Council; Mid Devon District Council; Mid Suffolk District Council; Milton Keynes Council; Mole Valley District Council; Monmouthshire County Council;

    New Forest District Council; Newark & Sherwood District Council; Newcastle – Under Lyme Borough Council; Newcastle City Council; Newcastle Under Lyme Borough Council; Newry, Mourne & Down District Council; North Ayrshire Council; North Devon County Council; North East Derbyshire District Council; North Hertfordshire District Council; North Lincolnshire Council; North Lincolnshire Council; North Norfolk District Council; North Northamptonshire Council; North Tyneside Local Council; North Yorkshire County Council; Northumberland Council; Northumberland County Council; Norwich City Council; Nottinghamshire County Council;

    Orkney Islands Council; Oxfordshire County Council;

    Pembrokeshire County Council; Pendle Borough Council; Perth and Kinross Council; Perthshire Council; Powys County Council;

    Reading Borough Council; Redbridge Council; Reigate & Banstead Borough Council; Rhondda-Cynon-Taf County Borough Council; Ribble Valley Borough Council; Richmond Council; Rochdale Borough Council; Rossendale Borough Council; Rother District Council; Rotherham Metropolitan Borough Council; Royal Borough of Greenwich; Rushcliffe Borough Council; Rushmoor Borough Council, Rutland County Council;

    Sandwell Council; Scarborough Borough Council; Scottish Borders Council; Sedgemoor District Council; Selby District Council; Sevenoaks District Council; Sheffield City Council; Shepton Mallet Town Council; Sherwood District Council; Skipton Town Council; Somerset County Council; South Cambridgeshire District Council; South Derbyshire District Council; South Gloucestershire Council; South Hams District Council; South Kesteven District Council; South Lakeland District Council; South Lanarkshire Council; South Norfolk Council; South Oxfordshire District Council; South Ribble Borough Council; South Somerset District Council; South Staffordshire Council; Southampton City Council; St Albans District Council; Stafford Borough Council; Staffordshire County Council; Stockport Council; Stockport Metropolitan Borough Council; Stratford-upon-Avon District Council; Stroud District Council; Suffolk County Council; Sunderland City Council; Surrey County Council; Swale Borough Council; Swansea Council; Swindon Borough Council;

    Teignbridge District Council; Telford and Wrekin Council; Telford Town Council; Tendring District Council; Tewkesbury Borough Council; Thanet Council; Thurrock Council; Torbay Council; Trafford Council; Trending District Council; Tunbridge Wells Borough Council;

    Uttlesford District Council;

    Vale of Glamorgan; Vale of White Horse District Council;

    Wakefield City Council; Wakefield Metropolitan District Council; Waltham Forest; Warrington Borough Council; Warwick District Council; Waverley Borough Council; Wealden District Council; Welwyn Hatfield Borough Council; West Berkshire Council; West Devon Borough Council; West Lindsey District Council; West Lothian Council; West Norfolk; West Northamptonshire Council; West Oxfordshire District Council; West Sussex County Council; Westminster City Council; Whitehall Town Council; Wigan Metropolitan Borough Council; Wiltshire Council; Winchester City Council; Wirral Borough Council; Wokingham Borough Council; Wokingham Council; Wolverhampton City Council; Worcestershire County Council; Wyre Forest District Council;

  61. Chris Packham lauded in The Great Outdoors Magazine Reader Awards 2021

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    Huge congratulations to Wild Justice co-director Chris Packham who has been voted Outdoor Personality of the Year in The Great Outdoors Magazine Reader Awards 2021!

    Receiving a whopping 42.5 per cent of the public vote, conservationist Chris Packham was widely respected by TGO readers for his “passion” and “tireless championing of the environment”, even in the face of adversity. As one voter eloquently put it: “‘Dedication to the cause doesn’t go far enough for Chris Packham – he is relentless in his determination to protect and conserve our wildlife and habitats. Chris experiences personal attacks on his home and abuse through social media for standing up for his beliefs and still remains focused, determined and resolute. We must protect our planet. Who wouldn’t admire that?”

  62. Hampshire Police release CCTV image of man they’d like to question in relation to arson attack at Chris Packham’s home

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    Hampshire Constabulary have released a CCTV image of a man they believe may hold key information about an arson attack at Wild Justice co-director Chris Packham’s home in October.

    Just after midnight on Friday 8th October 2021, two masked men were caught on security cameras driving a Land Rover up to the gates of Chris’s house before setting it alight and then fleeing in a second vehicle.

    The Land Rover exploded and the fire spread to Chris’s gates and fence, causing significant damage.

    The attack was an escalation in a long-running hate campaign against Chris, believed to be linked to his campaign work against raptor persecution and fox-hunting.

    Police have been continuing to explore lines of enquiry to identify those responsible and now believe that the man pictured may hold key information to their investigation.

    Do you know who this man is?

    Any information, no matter how small or insignificant you feel it might be, could help aid the police investigation and identify those who are responsible for this crime.

    If anyone has any information in relation to this incident, please call 101 quoting incident reference 44210403698.

    Thank you

  63. The state of general licences across the UK nations

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    Wild Justice’s first legal challenge was of general licences in England. General licences are used by statutory agencies to authorise the killing of what might be called ‘pest’ species – although we object to that as a blanket term.

    All wild birds are protected by law but there are circumstances under which they can be killed – for example to protect human health, crops or endangered species. If you think that a particular Robin, to take a daft example, is a threat to nature conservation interests then you can apply for a specific licence to kill it. However, you will have to explain the problem that you claim is caused by this Robin and say why non-lethal means of solving the problem won’t work.

    The general licences streamline, or circumvent, that process for a small number of species which really can cause such problems, for which non-lethal solutions might not work and, let’s be honest, the licensing authorities don’t want to have to deal with lots of individual applications, they’d rather issue a general licence on their website. It is easy to see that a general licence published on a website may be less well scrutinised by its users than a piece of paper sent to them personally in the post.

    Wild Justice has described the general licensing system as being too often ‘the casual licensing of casual killing’ of birds. Our legal challenges, supported by you, have led to rapid reform of the general licences across the UK with Northern Ireland making the most recent changes in reaction to a Wild Justice legal challenge. Here are some headline changes to the licensing system since we started our challenges:

    • the species that can be killed have been reduced in number – for example all gull species are now removed from these licences
    • the species that can be killed for alleged conservation purposes have been greatly reduced
    • the species which are alleged to benefit from the use of the conservation licences have, in some areas, been better defined and listed for the first time – the lists are pretty bizarre but the task now is to make them better
    • in 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 theoretically limits the time of year duruing which the licence can be relied
    • 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)

    Here are three tables which set out the current position for the three different categories of general licence in each of the four UK nations.

    Table 1 – human health and safety

    Species listed on general licences as potential threats to human health or safety

    Northern Ireland is clearly out of line with the other UK nations in listing so many native species. We think Scotland (NatureScot) and Wales (NRW) have probably got it about right.

    Table 2 – serious damage to crops/livestock

    Species listed on general licences as potentially causing serious damage to crops or livestock

    Northern Ireland is again out of line – we’d like to see House Sparrow and Starling removed from the Northern Ireland list as they have been from those of other UK nations. We’re pretty unconvinced of the necessity of having general licences which authorise the killing of Magpies or Jackdaws, in particular, to protect crops or livestock.

    Table 3 – nature conservation

    Species listed on general licences as potential threats to nature conservation

    We have concentrated our actions on the conservation lists so far. Once Jay, Jackdaw and Magpie are removed from these lists across the UK then we will take a breath and regard these lists as almost fit for purpose. We know of no conservation organisations which routinely kill these three species for conservation reasons, and the science does not support their inclusion in such lists. Remember, removing them from the general licences merely means that an individual must apply, with details, for a specific licence, which may be granted or refused after the application has been scrutinised, it isn’t an end to all lethal control.

    Why does Wild Justice care about the general licences?

    • we care about all wildlife and these are wildlife-killing licences
    • we believe that the licences have been largely the product of prejudice and not science
    • the conditions which restrict the use of these licences are often flouted
    • the licences are not enforced or monitored by the authorities
    • they aren’t even understood by those who think they are using them properly
    • the licences allow, in theory, unlimited killing of species which are natural parts of our countryside
    • sometimes the methods used to kill birds under these licences are not humane

    These general licences have been a neglected area of wildlife law and policy for too long – we’re proud of the fact that we have shone a bright light on them, and that greater scrutiny, backed by legal action, has resulted in rapid change and improvement. Though there’s still some way to go…

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  64. High lead levels in Waitrose and Harrods game meat

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    Today’s Times carries an account of the results of Wild Justice’s tests of lead levels in supermarket game meat

    Last week, we told you about the high levels of lead in Sainsbury’s game meat, now we have the results of similar tests of game meat purchased from Waitrose and Harrods. Both stores are selling game meat with high lead levels too. 

    It is particularly disappointing that Waitrose’s game has high lead levels as they have promised to go lead-free – there is no indication from our results that they have made any progress with this at all. Waitrose Pheasant fillets bought in stores in Essex and London in late November, and tested for lead content at the University of the Highlands and Islands, had high lead levels – higher even than the results from the samples that we had analysed from last year’s shooting season. 

    Other meats, such as beef, chicken, pork, have Maximum Levels of lead set by regulations. The MLs for these meats are 0.1mg of lead per kg of wet weight of the meat. No such MLs are set for game meat despite there being high levels of lead in game meat which mostly derive from contamination by lead ammunition. 

    Our tests, from last shooting season and this season show that chicken and pork samples have low lead levels (as expected), but game meat samples from Waitrose, Sainsbury’s and Harrods all have high levels of  lead. In all cases the samples of game meat had levels of lead that would be illegal if they were found in other meats. See table below.

    The median levels of lead are probably the fairest comparisons as they are not so influenced by the occasional very high sample; Waitrose’s Pheasant fillets from this year had the highest median lead levels of any of our samples from this or last shooting season. 

    Lead is a poison – that’s why it has been removed from paints, fishing weights, water pipes and petrol – but it is still shot into wild birds such as Pheasants whose meat then goes into the human food chain. As lead shotgun pellets pass through the flesh of a bird or mammal tiny fragments fly off the pellet and are distributed through the animal. These are too small to see or remove and they give the game meat high lead levels. 

    The Food Standards Agency and NHS England warn against eating game shot with lead, especially by pregnant women, women trying to become pregnant and young children. 

    Waitrose told The Times that they believe that these results were caused by environmental residues and not by lead shot. Wild Justice believes that this is overwhelmingly unlikely. Dr Mark Taggart, whose laboratory analysed our game meat samples, told The Times that it was unlikely that the very high lead levels were caused by birds consuming lead in the countryside. 

    Wild Justice said: Two years ago Waitrose promised that their game meat would be lead-free by now – it isn’t. Their game meat has high levels of lead in it. Lead is a poison. These lead levels would be illegal in other meats. The most overwhelmingly likely explanation for such very high lead levels is contamination by fragments of lead shot. There is no Lead Fairy sprinkling lead into Waitrose game meat.

    Waitrose have not apologised for, or explained, their failure.  Why is a small organisation like Wild Justice having to test the levels of poison in meat sold by a major retailer? These tests cost a few hundred quid – why didn’t Waitrose test their own game meat? 

    Waitrose have agreed to meet Wild Justice for a chat about lead in game meat.

    DEFRA received an expert report in 2015 that recommended the phasing out of lead ammunition for environmental and food safety reasons. DEFRA is still thinking about banning the use of lead ammunition some time in the future. It is long past the time when government, retailers and the shooting industry should have got rid of lead from game meat in the human food chain and from contaminating the environment through the use of lead shot.

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  65. Wild Justice Raptor Forensics Fund helps secure gamekeeper conviction

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    We’re delighted to learn that our Raptor Forensics Fund, established last year to help support police investigations into alleged raptor persecution crime, has played a part in the conviction of a criminal gamekeeper in Cheshire.

    Our fund was utilised by Cheshire Police this year to undertake a post mortem of a sparrowhawk that had been found dead inside an illegally-operated trap in February 2021. A veterinary pathologist confirmed the sparrowhawk had died of starvation and would have experienced considerable unnecessary suffering inside the trap.

    At Manchester Magistrates’ court today (16 December 2021), gamekeeper Hilton Prest pleaded guilty to unlawfully using a trap on or before 10/2/21 contrary to Sec 5(1)(b) of the Wildlife and Countryside Act. He was fined £800 (plus £85 costs and £80 victim surcharge).

    For more details of this case please see here.

    Thank you to all those who contributed to our Raptor Forensics Fund and thanks also to the PAW Forensic Working Group (a sub-group of the Partnership for Action Against Wildlife Crime) who administer our fund and ensure that police officers can access it without delay to help progress their investigations into raptor persecution crimes.

  66. Our Northern Ireland victory – some more thoughts

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    The news that Wild Justice has toppled three Northern Ireland general licences is good for wildlife, good for those who respect the rule of law and bad news for the Northern Ireland administration. It is also a case study in the failure of UK authorities to do their jobs properly even when it comes to sticking to the law.

    • Wild Justice has been in regular contact with DAERA pointing out the unlawfulness, and biological error, of their general licences. Our first contact with them was in Spring 2019 but from March 2021 we pointed out the legal flaws in the licences which would expire in September 2021 and made very clear the certainty of a legal challenge if they persisted with them. But they did. So we took a legal challenge which DAERA largely brushed aside with evasion until the very last minute thus costing the taxpayer money and probably causing general licence users unnecessary confusion. DAERA have acted in an unprofessional way, in our opinion.
    • This is the latest reform of general licences that Wild Justice has achieved in the UK. Since our first and successful legal challenge of the Natural England general licences which applied in England in 2019, and a further challenge to the Welsh general licences, we have seen considerable reform of these long-standing licences which allow unlimited widespread killing of a small number of species that would otherwise be fully protected by law. We note that general licences in England and Scotland will be published in the New Year – we’ll be taking a close look at them.
    • The changes that have come about since our first legal challenge are important. The necessity to comply with the circumstances in which the licences are valid, and the necessity for non-lethal methods to be the first approach have been accompanied by stricter measures being introduced for wildlife sites and a big reduction in the list of species for which the general licences can be relied on as cover for lethal control. Our campaigns and legal challenges haven’t changed the laws – they are forcing statutory agancies to implement existing laws properly. There is more progress to be made on this issue.
    • It comes to something when statutory agencies who have the responsibility for implementing the law of the land in their policies are found to be acting unlawfully.
    • And it comes to something when protracted and expensive legal challenges are needed to force public bodies to act lawfully and sensibly. But Wild Justice is happy to take on that task given the high level of public support that we are receiving and the fact that this area has been neglected by other wildlife organsisations.
    • There is an argument that the whole process of using general licences to authorise killing of wild birds, which can only be legal under quite specific conditions and circumstances, is a hopeless way of allowing properly authorised and lawful limited control of some species. Unless statutory agencies can show that the effect of their general licences is to limit lethal killing of so-called pests only to what is necessary and legal then the whole system of general licences should be replaced by users having to apply for specific licences as is the case with all other wild bird species.

    We look forward to a speedy revocation of these licences, the publication of lawful interim licences which are fit for purpose and news of a renewed consultation on this matter.

  67. DAERA concedes unlawfulness of Northern Ireland general licences – another Wild Justice win.

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    Wild Justice, represented by Leigh Day acting through their agent Phoenix Law, has secured a landmark victory in a legal challenge to Northern Ireland’s general licences for the killing of wild birds.

    The Department of Agriculture, Environment and Rural Affairs (DAERA) yesterday conceded Wild Justice’s claim that the decision to issue three general licences on 10 September 2021 that permit the killing of birds in the province is unlawful.

    DAERA has now provided written assurance that its flawed general licences will be replaced by interim licences and that a full consultation will be launched in due course.

    In our pre-action letter, Wild Justice set out that the 2021 General Licences were unlawful and breached the Wildlife (Northern Ireland) Order 1985 for these reasons:

    • DAERA had not satisfied itself that there was no other satisfactory solution in relation to the killing being authorised for the respective purposes for which the 2021 General licences were issued.
    • DAERA did not comply with Section 18(6) of the 1985 Order in that it failed to specify the circumstances and conditions subject to which birds may be killed or the “Area of Use” for the 2021 General Licences.
    • There was no evidence to justify the inclusion of certain species in the 2021 General Licences.
    • DAERA failed to seek out the relevant information required to make a decision to grant the 2021 General Licences at all.
    • DAERA failed to complete any consultation prior to issuing the 2021 General Licences.

    In response to this further Wild Justice legal victory, which reforms general licences and reduces the scale of casual licensing of casual killing of wild birds:

    Wild Justice said:

    “The DAERA General Licences we challenged were not fit for purpose and were unlawful to boot. DAERA seemed to think that Woodpigeons and Feral Pigeons threatened conservation interests in Northern Ireland – a totally bizarre idea. And yet it took a tiny organisation, supported by thousands of people, to raise the money and to hire brilliant lawyers to bring these flawed licences down. We look forward to seeing lawful replacement licences in the very near future. DAERA must do better and Wild Justice remains ready, willing and able to take further legal challenges on behalf of wildlife in the UK.”

    Leigh Day Associate Tom Short said:

    Our client welcomes DAERA’s belated concession that its 2021 general licences are not fit for purpose. DAERA had blatantly, as in previous years, failed to follow the process it is required to, and had issued the licences absent any evidence to support them. That is not how a licensing system permitting the killing of otherwise protected wild birds should operate, and it is astonishing that DAERA has failed to engage with the problem since it was first raised by Wild Justice in May 2019. Our client welcomes DAERA’s commitment to now reform its licensing and move to full consultation on the issue.”

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  68. Lead-contaminated game meat found for sale on Sainsbury’s shelves

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    British supermarket shelves are still stocked with potentially toxic game meat in the run up to Christmas, recent research by Wild Justice has found.

    · Tests on packets of pheasant breast and mixed game meat from Sainsbury’s found lead levels at up to 76 times higher than the legal limit set for beef, pork, chicken etc.

    · 100% of samples of mixed game meat tested positive for potentially dangerous amounts of lead.

    · Findings indicate the voluntary phasing out of lead shot by the shooting industry hasn’t prevented lead contamination of meat nearly two years after its announcement.

    Wild Justice, a not-for-profit organisation campaigning on British wildlife issues, bought 32 samples of pheasant breast and mixed game meat from Sainsbury’s stores (supplied by game dealer Holme Farmed Venison in Yorkshire) and had them tested for lead levels in November 2021. Ten samples of chicken meat were purchased and tested as controls.

    Out of 16 samples of pheasant breast, 11 contained lead levels over the legal limit set for livestock meat. All 16 portions of the ‘Diced Game Casserole Mix’, containing venison, pheasant and partridge, exceeded the same level.

    Currently (and inexplicably) there is no legal limit for lead levels in wild game meat such as pheasant, partridges, grouse and venison. The Maximum Level (ML) of lead for most types of farmed meat, such as chicken and beef, is set at 0.1 milligram per kilogram of wet weight of meat. The portions of mixed game meat sold by Sainsbury’s exceeded these by an average of 17 times, with some samples testing as high as 4.7mg/kg. Of the 11 pheasant breast samples that exceeded the threshold for other meats, the average was 32.5 times higher at 3.25mg/kg WW. The samples of chicken had uniformly low levels of lead, as expected, which were all well below the ML set for such meat.

    Consumption of lead is detrimental to human health, being especially harmful to developing brains and the nervous system. Children, pregnant women and those trying to become pregnant are advised by the Food Standards Agency and NHS England against eating game shot with lead.

    Although warnings about lead shot have been added to some of the packaging at Sainsbury’s this year, it was often not displayed clearly. Statements to the opposite effect, such as ‘Ideal for a healthy casserole or game pie’, are placed prominently on the products’ front. Wild Justice says this raises the question of how informed consumers of these products are about the risks of lead contamination. Both products were ‘kite-marked’ by the British Game Alliance which claims to be the ‘official marketing board for the UK game industry’ offering ‘traceability and credibility’, although this has been questioned repeatedly.

    Lead shot is a type of ammunition normally used for shooting pheasants, partridges and grouse. The small lead pellets are malleable and when shot into an animal they fragment, dispersing tiny pieces of lead through the animal’s flesh. It’s impossible to remove all of these tiny fragments, leading to lead contamination of the meat. Lead bullets used for shooting deer cause similar problems, with fragmentation of the bullet distributing small pieces of lead in the venison meat. Non-toxic ammunition such as steel is widely available at comparable prices to lead ammunition.

    Wild Justice said:The presence of lead-contaminated meat on supermarket shelves is disgraceful. It’s a clear failure of the regulatory system that government allows the sale of lead-contaminated meat, without prominent health warnings, when the FSA and NHS England warn of the dangers of eating such food. Sainsbury’s know their game meat has high lead levels but appear to be putting profit ahead of safety because of a regulatory loophole.

    In the run up to Christmas, when people are thinking about festive dishes for the family table, it’s outrageous that products like this can be sold under the guise of being healthy due to failures of government and retailers to act in the public interest.”

    In 2020 a voluntary five-year phase out of lead shot was announced by prominent organisations within the shooting industry. Wild Justice says this move is ineffective and calls for an outright ban on use of lead shot. “There’s no point leaving this matter to the shooting industry – they have failed to act for years“, said Wild Justice.

    Wild Justice analysed similar samples of game meat from Sainsbury’s stores shot in the 2020/21 shooting season and found high levels of lead in them; Sainsbury’s appears to have done nothing to reduce the levels of lead in game meat sold in its stores in the interim.

    Waitrose is the leading supermarket which has recognised the need for change, and introduced labelling of game meat, warning of lead levels, in 2019/20 and is aiming to source lead-free game meat as soon as possible. Wild Justice has collected samples from Waitrose stores this year (and a number of other shops) and these are currently undergoing analysis.

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

  69. We lost our renewal application

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    Photo: Sarah Hanson

    Today Wild Justice lawyers were arguing for a renewal of our claim for judicial review of DEFRA’s feeble burning regulations.

    Unfortunately we did not persuade the judge.

    We are considering an appeal.

    We’d like to thank our legal team who have worked very hard on this case. We’d also like to thank our supporters whose generosity made it possible for us to take the case this far without a specific fundraising appeal.

    We will go away and consider options – for one thing, there are other possible legal challenges in the pipeline.

  70. Rising reports of wildlife crimes during the pandemic

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    Wild Justice is a member of Wildlife & Countryside LINK and today the consortium has published its latest annual report on wildlife crime (covering 2020).

    Here is the press release:

    Rising reports of wildlife crimes during the pandemic spark fresh fears for beloved species

    new report published today (25 Nov) by nature experts has revealed a worrying increase in reporting of wildlife crimes against badgers, fish, birds of prey, and marine mammals during the pandemic. While a sharp decline in convictions for wildlife crimes including hunting, illegal wildlife trade, and fishing crime was also seen in 2020.

    Reports of likely crimes against badgers rose by 36% in 2020, compared to 2019, with reports of potential fishing crimes up by more than a third (35%) and marine mammal incident reports (in Cornwall alone) rising 90%, according to data gathered by the NGOs. The number of confirmed raptor crimes in England & Wales in 2020 was almost double that in 2019, rising from 54 to 104 (the worst year for bird-crime ever as detailed by the RSPB in October).

    At the same time fishing crime convictions fell by almost two-thirds from 2037 in 2019 to 679 in 2020, and illegal wildlife trade convictions halved to just 4 convictions. Hunting prosecutions also more than halved, from 49 in 2019 to 22 in 2020, with only 8 convictions. Hunting conviction rates have in fact steadily decreased for the last five years, falling from 54% of prosecutions being successful in 2016 to less than a third (32%) of prosecutions achieving conviction in 2020.

    Martin Sims, Director of Investigations at the League Against Cruel Sports and Chair of Wildlife and Countryside Link’s Wildlife Crime group, said: ‘‘Wildlife crime is something that should concern everyone – it inflicts pain, harm and loss for much-loved wildlife and fuels wider criminality against people and property. Despite this the police still don’t gather centralised data on these serious crimes, leaving an incomplete picture from charities, which could be just a drop in the ocean of wildlife crimes. It is high time the Government steps in to treat wildlife crime with the seriousness it deserves. Making key crimes notifiable would enable police forces to better target resources, and track repeat offenders. While better police and prosecutor training and resources would help raise the pitiful 32% conviction rate for hunting prosecutions alone. The system must change to crack down on offences against nature once and for all.”

    Dawn Varley, Acting CEO of the Badger Trust, said: “Badger crime has been a UK Wildlife Crime Priority for more than a decade, due to the scale of persecution – but sadly this persecution shows no sign of letting up. 2020 saw reports of badger crime rise, driven in large part by a shocking 220% increase in reports of developers interfering with badger setts. A small minority seem to see badger habitat protections as an inconvenience to be quietly bulldozed over, rather than a legal requirement to conserve an iconic British mammal. 2022 must see renewed work by police forces and the Crown Prosecution Service to bring offenders to justice. This must be supported by better monitoring, new training to enable officers and prosecutors to demonstrate criminal intent, and consistently tougher sentencing to deter these crimes.”

    Mark Thomas, RSPB Head of Investigations UK, said: “In the wake of an emergency climate conference and with all life on earth facing an uncertain future, there has never been a more important time for urgent action to end the illegal killing of wildlife. Wildlife declines are already being felt, and species can ill afford to face the additional pressure of being brutally shot, trapped or poisoned; nor should the public have to put up with these crimes taking place in the wild places they go to for refuge.

    “Bird of prey persecution reached unprecedented heights in 2020, particularly where land was managed for gamebird shooting. And it is certain that more crimes will have been committed and simply gone undetected and unreported. We urge the public to report dead or injured birds of prey in suspicious circumstances to the police and the RSPB, or pass on any information which may help lead to a conviction.”

    One of two illegally poisoned peregrines found near Tadcaster, North Yorkshire, in 2020. Photo by RSPB:

    The lockdowns and restrictions of 2020 appear to have contributed to rises in reporting of wildlife crimes and falls in convictions in several ways. Opportunistic offenders may have felt that with the police busy enforcing social restrictions that wildlife could be harmed with relative impunity. With increased use of the countryside in the pandemic more members of the public were also present to witness and report incidents of concern. COVID-19 pressures around social restrictions and staff absences appear also to have unfortunately reduced the capacity of police forces and the Crown Prosecution Service, and their ability to both bring hunting and fishing cases to trial and achieve convictions.

    While today’s report reveals worrying figures, with impacts for treasured species like badgers, buzzards, kestrels, seals, dolphins and bluebells, it gives an incomplete picture. These organisations all collect data in different ways, with many only holding figures on reporting and convictions for incidents where members of the public have directly contacted them. There is a huge lack of information on wildlife crimes due to police not being required to officially record wildlife offences. Most wildlife crimes are recorded as ‘miscellaneous’ offences and are therefore invisible in police records, with no duty to be reported upon. The scale of wildlife crime is therefore likely to be far greater than the data collected by NGOs suggests.

    • The 16 wildlife organisations behind today’s report are warning that the way wildlife crimes are handled by both the police and Crown Prosecution Service must be reviewed and improved, if offences against treasured British wildlife are to be tackled. In particular, the new report highlights that the continued absence of dedicated recording for wildlife crimes means that resources cannot be effectively assessed and targeted. A lack of expertise and resource for police and prosecutors, and deficiency of sentencing guidelines, is also leading to failures in convicting criminals and inadequate penalties for crimes.

      Nature experts and conservationists are calling for several key actions to better tackle wildlife crimes:
    • Make wildlife crimes recordable – A shortlist of wildlife offences (compiled by the National Wildlife Crime Unit) is being considered by the Home Office for notifiable status. This must be approved in 2022 to bridge the crippling wildlife crime data gap and help target resources effectively.
    • Ensure effective police & prosecutor action – Staff with expert training on wildlife crimes are critical to effectively building and prosecuting a case against these criminals. Also key is early coordination between the CPS and police on cases, and ensuring prosecutors have adequate preparation time for cases. Ensuring police and CPS training and process reflects this is vital.
    • Produce sentencing guidelines – Unlike most other crimes, the Sentencing Council provides no sentencing guidelines for wildlife crimes. This must be rectified to ensure sentencing consistently reflects the seriousness of these crimes and acts as a deterrent to criminal activity.

      ENDS
  71. DEFRA under increasing pressure to stop burning on peatlands

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    Photo: Sarah Hanson

    Remember COP26 – it was only 10 days ago. Nations were castigated for not doing enough to combat climate change.

    We have a classic example of government being weak in the face of intransigence from vested interests in England. Whereas some nations can argue that they have to cause pollution for the benefit of their population, it seems that DEFRA is allowing damaging burning on peatland soils simply for the recreation of shooting Red Grouse. DEFRA is allowing burning of vegetation on peatland soils, despite saying themselves that ‘There is a consensus that burning of vegetation on blanket bog is damaging to peatland formation and habitat condition. It makes it more difficult or impossible to restore these habitats to their natural state and to restore their hydrology‘. And yet the measures DEFRA introduced in the end protect less than half of the peatlands from such damage.

    Local councils in the uplands are calling on DEFRA to clamp down on the damaging practice of moorland burning. Wild Moors say that 13 councils including Calderdale, Sheffield, Redcar and Cleveland and High Peak have called for greater restrictions on burning of moorlands.

    Wild Justice challenged the lawfulness of the DEFRA regulations on burning and we were refused permission for judicial review – but our renewal hearing will take place on 1 December and we hope that we will then be able to go to judicial review.

    To donate to Wild Justice’s work by bank transfer, PayPal or a cheque in the post – click here

  72. Waitrose – are you having problems sourcing lead-free game meat?

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    Wild Justice has been scouring the game meat shelves of supermarkets for shot birds to get analysed for lead content.

    Last spring, we published analyses of game meat collected from Sainsbury‘s and Waitrose and showed that both stores were selling game meat with high lead levels – the lead comes from fragments of lead shot with which the birds were killed and which spread through the carcasse of the bird.

    Rightly, Wild Justice supporters were shocked that supermarkets were selling meat with high levels of a poison in them – and levels of lead are high enough for the Food Standards Agency to recommend that young children, pregnant women and women trying to get pregnant should avoid eating lead shot game meat.

    We said that we’d be testing meat samples again this winter. We already have Sainsbury’s game meat collected and being analysed for their lead levels – watch this space for the results in the next few weeks. We are also collecting samples from other high profile vendors.

    Waitrose is the only supermarket, in our view, to have taken a more responsible approach. Waitrose have said that they are phasing out all game meat shot with lead and will only sell game meat shot with non-toxic ammunition. We will monitor their progress with this promise – and we wish them well.

    However, we wonder whether Waitrose is finding it tough to live up to its promise. Many Waitrose stores have little game meat in them. We have visited over a dozen supermarkets where the stores have no whole Pheasants for sale. Online, Waitrose claim to be selling Pheasants but we know of several customers who have ordered Pheasants from Waitrose, been told that they would be ready for collection from stores and then, at the last moment, have been told that they are unavailable. This is a phenomenon which has occurred in several parts of the UK and seems the norm.

    Go into a store, like the one pictured above, and many of the game meat options are ‘temporarily unavailable’ – even though the labels claiming this don’t look very temporary. In chats with Waitrose staff in stores, Wild Justice supporters have been told that there are big problems in supply this year.

    We will be asking Waitrose what their problems are and when they think that they will be able to supply lead-free game meat as promised. You could ask your local supermarket what is their policy on selling game meat shot with lead ammunition – we’d like to know what a range of supermarkets are saying. And remember, we are collecting more samples for analysis from several supermarkets.

    We wish Waitrose well with their responsible move to lead-free game meat, and look forward to being able to report that their gamemeat is low-lead or, hopefully, lead-free in due course. We wonder whether they are being let down by the shooting industry? At the moment it seems that Waitrose is struggling to fill its shelves with gamemeat – that’s one way to seel less lead to the public.

  73. Ecological illiteracy from BASC

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    An article in this week’s The ENDS Report highlights the ecological illiteracy of the British Association for Shooting & Conservation (BASC).

    The ENDS Report article is based around the contents of a BASC blog attributed to BASC’s new Head of Environmental Research, Dr Marnie Lovejoy. It’s apparent from the blog that BASC is pushing for a review of the Habitats Regulations to allow more shooting on protected sites.

    The ENDS Report highlights a section of the BASC blog as follows, and then goes on to include Wild Justice’s response to it:

    Lovejoy gives the example of curlews being in decline in large part because of increased pressures from generalist predators, such as corvids, writing that “the regulator prefers that precious curlew eggs are being devoured by a rook [rather] than allowing landowners the legal ability to prevent attacks before they happen or to act immediately to shoot or trap rooks as problems arise”.

    However, BASC’s position has been slammed by Wild Justice, a campaign group founded by TV presenter Chris Packham, and environmentalists Mark Avery and Ruth Tingay. A spokesperson for the group told ENDS that BASC was “confusing rooks with carrion crows”, adding that “with gross errors like this, BASC show themselves to be ecologically illiterate”.

    Continuing, the spokesperson said: “Brexit was the preferred option for many who wanted environmental protection to be weakened. Single issue pressure groups like BASC want conservation to be shot to pieces. You won’t find a real nature conservation organisation in the UK who wants the protection of the Birds and Habitats directives to be dismantled in the way that shooters, grouse moor owners, and some farmers do.”

    While rooks do predate curlew eggs in small numbers, they are considered by regulatory bodies and conservation groups to be a significantly smaller threat than carrion crows. 

    To read the full article in the ENDS Report click here (but beware, it sits behind a paywall so you’ll need to subscribe to read it).

    Here are more comments we made that didn’t make it into the published ENDS Report article. The journalist asked us:

    In what exact sense are they confusing rooks and carrion crows – do rooks not eat curlew eggs/predate curlews at all, or just not to the same extent as crows?‘ 

    Our response:

    ‘Hardly at all. The RSPB kills zero Rooks a year to protect waders, they kill scores of Carrion Crows. The Wildlife Trusts kill zero Rooks a year to protect wildlife, they kill some Carrion Crows.

    DEFRA does not list Rook on its conservation licence (species that can be killed for conservation purposes)  https://www.gov.uk/government/publications/wild-birds-licence-to-kill-or-take-for-conservation-purposes-gl40/gl40-general-licence-to-kill-or-take-certain-species-of-wild-birds-to-conserve-endangered-wild-birds-or-flora-and-fauna

    Natural Resources Wales does not list the Rook on its general conservation licence https://cdn.cyfoethnaturiol.cymru/media/693912/general-licence-004-english-2021.pdf

    NatureScot took Rook off its general licence in 2020 https://www.nature.scot/renewed-general-licence-increases-protection-scotlands-wild-birds

    Is it likely that real conservation organisations and the statutory nature conservation agencies for England, Wales and Scotland are wrong whilst BASC is right? With gross errors like this, BASC show themselves to be ecologically illiterate’.

  74. Have Pheasant releases decreased in England?

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

    Last autumn, just over a year ago, Wild Justice won a very significant victory by challenging the lawfulness of the massive scale of releases of non-native Pheasants and Red-legged Partridges for the purpose of recreational shooting. Our challenge caused DEFRA to list the two species on Schedule 9 of the WildlIfe and Countryside Act which makes it an offence to release these birds into the wild in England without a licence, but at the same time they issued a general licence that exempted all areas away from designated wildlife sites from these restrictions. We criticised the new regulations as being too weak, although they are a start. The regulations currently apply to England but not to Wales, Northern Ireland or Scotland.

    How have the new regulations affected the number of non-native gamebirds released into the countryside? It’s very difficult to tell. We know that Natural England has refused permission to release gamebirds on many SSSIs and we hear from some people (but not from all) that gamebird numbers were noticeably lower in the fields and running about on the roads in the run-up to the opening of the Pheasant-shooting season just over a month ago. But it’s very hard to tell.

    So we decided to do a simple piece of analysis using birdwatchers’ data submitted to a scheme called BirdTrack .

    We examined the reporting rates of Pheasants (the proportion of full lists of birds seen by birdwatchers which include Pheasants) in England, Scotland and Wales, derived as weekly measures of overall national reporting rate from the BirdTrack scheme. Data from Northern Ireland were obtained but samples sizes were too small to be included. We didn’t include Red-legged Partridges in this analysis.

    Analysis focussed on the period between the first week of June (week 23) and the third week of October (week 42), since the regulations came into force in week 23 of 2021 and the data ran to week 42 in 2021. This encompasses the main period of gamebirds releases.

    Because mean weekly reporting rates differed systematically between the three countries, the percentage difference in weekly reporting rates between years was assessed, comparing the mean values for weeks 23 to 42 for 2015 to 2020 inclusive (pre-regulation) with the equivalent values for the same weeks in 2021 (post-regulation).

    Reporting rates in England were generally lower post-regulation than the average over the years 2015-20 pre-regulation, whereas in Scotland and Wales they were generally higher (Fig. 1). In England, most weekly reporting rates post-regulation fell between the pre-regulation average (a value of zero in Fig. 1) and 20% below it. In Scotland and Wales, weekly reporting rates were generally, but not quite always, higher in 2021 than the 2015-2020 average

    Figure 1. Percentage differences between weekly reporting rates in June – October (weeks 23 to 42) in 2021 and the average for the same weeks in 2015-2020.

    The same pattern was apparent when post-regulation reporting rates were compared with pre-regulation reporting rates using ranks (to account for the fact the pre-regulation average might have been unduly influenced by extreme values). Fig. 2 shows that for England, weekly reporting rates post-regulation were generally among the lowest recorded in the period 2015-2021 (mean rank = 2.0), whereas in Scotland and Wales they tended to be above the median rank (mean ranks of 4.4 and 4.9 respectively). 

    Figure 2. 2021 weekly reporting rates as rank of reporting rates in 2015-2021. A value of 1 indicates that the 2021 reporting rate was the lowest reporting rate for that week across the six years, a value of 6 indicates that it was the highest.

    Formal statistical tests of differences are problematic due to the non-independence of reporting rates across consecutive weeks (serial autocorrelation – a low reporting rate in one week is likely to be followed by a low reporting rate the following week). This means that the effective sample size is likely to be closer to 18 (6 years * 3 countries), than to 360 (6 years * 3 countries * 20 weeks).

    Conclusions

    There was a strong indication from the data that in the 20 weeks following the introduction of the new regulations in England, reporting rates of Pheasants in England were lower than the recent average, whereas in Scotland and Wales they were higher. This is consistent with, but not conclusive evidence for, an impact of the new regulations in reducing Pheasant releases in England. The higher than average reporting rates in Scotland and Wales in autumn 2021 suggest that the lower rates in England are unlikely to be explained by a systematic effect that applies across the whole of the UK (e.g. related to weather, Brexit, Covid etc). However, whether the lower reporting rates in England can be explained by a new regulation that applies to only a small part of the country is questionable.

    This analysis is a bit more than a quick-and-dirty analysis but it’s not ideal. There are more complicated and expensive analyses that could be carried out and we’ll keep them in mind for the future. We plan to repeat this analysis next year to see whether the indications for the first year of regulation are replicated in a second year.

    What do you, Natural England and DEFRA think has happened?

    We’d be interested to hear of your observations of Pheasants and Red-legged Partridges and whether you think their numbers are higher or lower than in previous years. Our email address is at the foot of this page.

    We’ll make this simple analysis available to Natural England and ask them what they think lie behind the apparent findings.

    We’ll make these results available to DEFRA and ask them what impacts they think their new regulatory regime may have had.

    Acknowledgements

    We thank the BTO for providing the data for this analysis.

  75. Glyphosate use by local authorities

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    Since we asked you to contact your local authority about their use of glyphosate, Wild Justice supporters have contacted over 200 local authorities across the UK.

    This is the template letter that many of you have used – click here.

    And here is the list of the first 200.

    Aberdeen City Council  

    Aberdeenshire Council  

    Allerdale Borough Council  

    Angus Council  

    Argyll and Bute Council  

    Arun District Council  

    Babergh District Council  
    Mid Suffolk District Council  

    Barnsley Metropolitan Borough Council  

    Basildon Council  

    Basingstoke and Deane Borough Council  

    Bassetlaw District Council  

    Bedford Borough Council  

    Bedfordshire Borough Council  

    Blaby District Council  

    Blackpool Council  

    Bolton Council  

    Bolton Metropolitan Borough Council  

    Bournemouth, Christchurch and Poole Council  

    Bracknell Forest Council  

    Bradford Council  

    Breckland Council  

    Bristol City Council  

    Broadland District Council  

    Bromley Council  

    Buckinghamshire County Council  

    Bury Council  

    Caerphilly County Borough Council

    Calderdale Council  

    Cardiff Council  

    Carlisle City Council  

    Carmarthenshire County Council  

    Charnwood Borough Council  

    Cheshire East Council  

    Cheshire West and Chester Council  

    City of Edinburgh Council  

    Colchester Council  

    Conwy County Council  

    Cornwall Council  

    Cotswold District Council  

    Craven District Council  

    Crowborough Town Council  

    Croydon Council  

    Cumbria County Council  

    Dacorum Borough Council  

    Dartford Borough Council  

    Derby City Council  

    Derbyshire County Council  

    Derbyshire Dales District Council  

    Devizes Town Council  

    Devon County Council  

    Doncaster Council  

    Dorset Council  

    Dumfries and Galloway Council  

    Durham County Council  

    East Cambridgeshire District Council

    East Devon District Council  

    East Dunbartonshire Council  

    East Hampshire District Council  

    East Hertfordshire Council  

    East Riding of Yorkshire  

    East Staffordshire Borough Council  

    East Sussex County Council  

    Elmbridge Borough Council  

    Essex County Council  

    Exeter City Council  

    Exmouth Town Council  

    Fareham Borough Council  

    Fife Council  

    Filton Town Council  

    Gateshead Council  

    Glasgow City Council  

    Goudhurst Parish Council  

    Great Yarmouth Borough Council  

    Hackney Council  

    Harborough District Council

    Harrogate Borough Council

    Havant Borough Council  

    Herefordshire Council  

    High Peak Borough Council  

    Isle of Anglesey County Council

    Isle of Wight Council

    Kings Llyn and West Norfolk Borough Council  

    Lambeth Council  

    Lancashire County Council  

    Lancaster City Council  

    Leeds City Council  

    Leicester City Council  

    Lincolnshire County Council  

    Liverpool City Council  

    London Borough of Barnet  

    London Borough of Bexley  

    London Borough of Camden  

    London Borough of Greenwich  

    London Borough of Hammersmith  

    London Borough of Islington  

    London Borough of Redbridge

    London Borough of Richmond upon Thames  

    London Borough of Tower Hamlets  

    Malvern Hills District Council  

    Medway Council  

    Mendip District Council

    Mid Devon District Council  

    Milton Keynes Council  

    Mole Valley District Council  

    Monmouthshire County Council  

    New Forest District Council  

    Newark & Sherwood District Council  

    Newcastle – Under Lyme Borough Council

    Newcastle City Council  

    Newry, Mourne & Down District Council  

    North Ayrshire Council  

    North Devon County Council  

    North East Derbyshire District Council  

    North Hertfordshire District Council  

    North Lincolnshire Council  

    North Tyneside Local Council  

    North Yorkshire County Council  

    Northumberland Council  

    Norwich City Council  

    Nottinghamshire County Council  

    Orkney Islands Council

    Oxfordshire County Council  

    Pembrokeshire County Council  

    Pendle Borough Council  

    Perth and Kinross Council  

    Powys County Council  

    Reading Borough Council  

    Redbridge Council  

    Rhondda-Cynon-Taf County Borough Council  

    Ribble Valley Borough Council  

    Richmond Council  

    Rochdale Borough Council  

    Rossendale Borough Council  

    Rother District Council  

    Rotherham Metropolitan Borough Council  

    Royal Borough of Greenwich  

    Rushcliffe Borough Council  

    Rushmoor Borough Council,

    Rutland County Council  

    Scarborough Borough Council  

    Scottish Borders Council  

    Selby District Council  

    Sevenoaks District Council  

    Sheffield City Council  

    Shepton Mallet Town Council  

    Skipton Town Council

    South Cambridgeshire District Council  

    South Derbyshire District Council  

    South Gloucestershire Council  

    South Hams District Council  

    South Kesteven District Council  

    South Lakeland District Council  

    South Norfolk Council  

    South Ribble Borough Council  

    South Somerset District Council  

    South Staffordshire Council

    Southampton City Council  

    St Albans District Council  

    Staffordshire County Council  

    Stockport Council  

    Stratford-upon-Avon District Council  

    Stroud District Council

    Suffolk County Council  

    Sunderland City Council  

    Surrey County Council  

    Swale Borough Council  

    Teignbridge District Council  

    Telford and Wrekin Council  

    Telford Town Council  

    Tendring District Council  

    Tewkesbury Borough Council  

    Thurrock Council  

    Torbay Council  

    Trafford Council  

    Trending District Council  

    Uttlesford District Council  

    Vale of White Horse and South Oxfordshire District Council  

    Wakefield City Council  

    Wakefield Metropolitan District Council  

    Waltham Forest  

    Warwick District Council  

    Waverley Borough Council  

    Wealden District Council  

    Welwyn Hatfield Borough Council  

    West Berkshire Council

    West Devon Borough Council  

    West Lindsey District Council  

    West Lothian Council  

    West Norfolk  

    West Oxfordshire District Council  

    West Sussex County Council  

    Westminster City Council  

    Whitehall Town Council  

    Wiltshire Council  

    Wirral Council  

    Wokingham Borough Council  

    Wolverhampton City Council  

    Worcestershire County Council  

    Wyre Forest District Council  

    That’s an amazing response from Wild Justice supporters – thank you! We are working our way through these replies, and more are coming in all the time, so it may take quite a while before we can classify authorities as being good, bad or ugly…

  76. Please respond to the NRW consultation on general licences

    Comments Off on Please respond to the NRW consultation on general licences

    Our guidance on responding to the NRW consultation on general licences.  

    We welcome the NRW consultation on general licences.

    Wild Justice’s legal challenge to the previous Welsh general licences was clearly a major factor in shaping the proposals that are now on offer in this consultation. But the places where we have moved NRW are not yet secure – that’s where you can help. We need hundreds of responses to the consultation to flood in to NRW. You should make whatever points you wish to, but here we give you suggestions. The consultation closes this coming Thursday – 11 November. 

    Here are our thoughts which cover most, but not all, of the consultation questions;  

    Questions 1-6 – only you can fill these in, they are about you.

    7. Do you agree with the principles we are proposing to apply for deciding whether to grant a general licence?

    YES

    Yes and No. You have set out 7 principles – how likely is it that anyone will agree 100% with all of them?

    Principle 1: There is an apparent and genuine need to allow the killing or taking of the species of wild bird in question, or to take or destroy their eggs or nests, in order to further one or more of the purposes outlined in section 16 of the Act.

    ‘Apparent and genuine’ should be ‘genuine and scientifically proven’. It is clear from the current NRW general licences that this is not always true and therefore that NRW is licensing unlimited, unnecessary and unlawful killing.

    Principle 2: Allowing the lethal control of birds of the species concerned under general licence can reasonably be expected to contribute to resolving the problem or meeting the need.

    Insert ‘on the basis of the science’ between ‘be expected’ and ‘to contribute’.

    Principle 3: There are no satisfactory solutions that would resolve that problem or address the need in question, other than to grant a general licence allowing the killing or taking of the wild bird species concerned.

    There is always the option of issuing specific licences rather than general licences.

    Principle 4: Allowing lethal control of the species in question under general licence, rather than only under specific licences subject to individual applications, is a proportionate response, given the frequency, scale and severity of the problem or need.

    This is not so much a principle as a craven lack of principle. NRW is not fulfilling its duties as a regulator by allowing such casual killing of birds in Wales. There are many things that lots of people want to do, not all of them should be allowed. NRW has allowed rural myths to be the basis for general licences and it’s time to change.

    Principle 5: Allowing lethal control of a ‘target’ species under a general licence will not risk putting it into an unfavourable conservation status.

    Unlimited general licences will always risk putting species into unfavourable conservation status because NRW hasn’t a clue how the licences are used, geographically, temporally or on what scale.

    Principle 6: No action authorised by a general licence will adversely affect the conservation status of any species other than the target species.

    That seems good to me.

    Principle 7: The general licence can be framed in terms which are clear to all users, compliant with all relevant legal requirements, and enforceable.

    Seems sensible, but the consequence is that there should be separate general licences for each target species – the general licence for the Jay (which I don’t think should be on a general licence anyway) cannot have the same details as that for a Carrion Crow.

    8.  Skip this question

    9. Do you think that magpie is suitable for inclusion on general licences in Wales in light of evidence of decline in their population in Wales?

    NO

    I don’t think that the Magpie is suitable for inclusion on the conservation general licence because the science does not back up the case for such a wide-ranging reduction in species protection.

    SELECT option ‘Not include magpie…’

    Because this is what NRW should have been doing for years. You can still consider specific licences.

    10. Do you think there are other species which may be suitable for inclusion on a general licence?

    NO

    11. Do you agree that general licences should be subject to regular review?

    YES

    Because they apparently authorise (unlawfully, I reckon) the large-scale and widespread killing of birds across Wales. Of course they should be regularly reviewed and should have to justify their details every year.

    12. Do you agree with the way in which we propose to carry out a regular review of general licences?

    NO

    Reviews should be annual, unless you implement all my suggestions, in which case every few years would be OK.

    13. Do you agree that general licences should continue to be issued for one year, and run from January to December?

    YES

    Yes for one year; No to January-December.  The licences should be valid only at the time of need. For conservation purposes (there are few examples) this should be in the spring/summer when species are nesting.

    14. Skip this question

    15. Do you have any comments on the format of general licences or any suggestions on how we could improve them in terms of presentation?

    YES

    If you persist with general licences then they ought to be very lengthy in order properly to specify the circumstances and conditions of lawful use.

    16. Do you agree that a person authorised by a land owner or occupier to carry out actions under a general licence, should be authorised in writing by the land owner or occupier?

    YES

    17. Do you agree that general licences should include a condition requiring users to first try to address the problem using alternative non-lethal methods, and to continue to make reasonable efforts to do so?

    YES

    I believe this is a legal requirement.

    18. Do you agree that general licence users should be advised to keep records of the actions they have taken under the licences?

    NO

    No, they should be required to keep records.  NRW hasn’t a clue how many birds are killed in Wales under these licences and has no way of finding out.

    19. Do you agree with our proposed approach to addressing protected site requirements when granting general licences?

    YES

    NRW is just catching up with DEFRA/NE here.

    20. Do you agree with the list of sites and buffer zones where we are proposing that general licences should not apply?

    Skip this question unless you have specific knowledge of the sites.

    Questions 21-27 – skip all of these.

    28. Do you agree that NRW general and specific licences should specify the types of cage trap that may be used?

    YES

    This will restrict the use of traps that may otherwise be unsuitable for the welfare of any trapped birds.

    29. Do you agree with the types and specifications of cage trap which we propose to authorise for use under any general licences we grant?

    YES

    It is particularly important to include a requirement that Larsen Mate & Larsen Pod traps are secured to mitigate the risk of them being dragged away and also that the closing edges are sufficiently rounded so as not to trap/damage the raised wings of a non-target raptor.

    30. Do you agree with the proposal not to allow the use of meat-based baits under any general licences granted by NRW?

    YES

    Research in Scotland, commissioned by SNH, has demonstrated that the use of meat baits encourages birds of prey (non-target species) to enter traps.

    31. Do you agree that continuing to allow the use of diced meat as feed for decoy birds achieves the right balance between mitigating the risk of catching non-target species and the welfare of decoy birds?

    YES

    Although would like to see evidence-based research on the use of diced meat for decoy birds. If it is shown that this still encourages raptors to enter the trap then the use of diced meat should not be permitted.

    32. Do you agree that licences should include a condition requiring captured birds of the target species to be killed out of sight of other captured birds and decoys, except in relation to multi-catch traps?

    YES

    Although this provision needs to be considered alongside consultation question #34 (should trap users be required to kill trapped birds (of the target species) as soon as reasonably practicable after discovery?). For example, it would not be acceptable for a trap user to take trapped birds to a distant location (far from the original trap) and hold them for several hours before killing them.

    33. Do you agree with the proposal to allow users of multi-catch traps discretion to kill trapped birds within sight of other birds where they consider that the additional delay and handling caused by moving out of sight to kill each bird would cause more distress?

    NEITHER YES OR NO

    There needs to be much more thought about the method of killing multiple birds from one trap. For example, covert footage in Scotland has shown a trap operator swinging wildly with a baseball bat inside a cage trap full of crows, wounding some and then battering them to death in a corner, causing considerable distress to the other birds in the cage.

    34. Do you agree that trap users should be required to kill trapped birds (of the target species) as soon as reasonably practicable after discovery?

    YES

    35. Do you agree that NRW licences should specify, as a licence condition, the matters that must be addressed at each cage trap inspection?

    YES

    There is evidence that some trap operators ‘check’ their cage traps from a distance (e.g. with binoculars from a vehicle) rather than physically attending the trap. There is also at least one company promoting the use of a ‘remote’ trap checking system, whereby a camera installed at the trap sends pictures to a mobile phone in lieu of the trap operator physically visiting the trap. Neither of these systems is satisfactory, especially when the trap operator needs to assess the welfare of the decoy and any trapped birds, e.g. any evidence, physical or behavioural, of injury and/or distress.

    36. Do you agree with our proposal to specify a maximum interval between inspections of 25 hours?

    YES and NO

    The proposal to specify a maximum interval between inspections is essential but the justification for choosing this interval to be 25 hours is unacceptable. It has not been selected with the decoy/trapped birds’ welfare to the fore; rather it has been chosen to streamline various licence conditions. NRW should undertake some research on the welfare impacts of checking live traps at 6, 12, 18 and 24 hour intervals so that the timing of trap checks can be based on evidence of welfare impacts. Large multi-catch traps may be suitable to hold a bird for up to 25 hours (if there is adequate and suitable food, water, perches and shelter) but the same cannot be said for most clam traps, which are considerably smaller.

    37. Do you agree with our proposal to include a condition prohibiting the use of wing-clipped birds as cage trap decoys?

    YES

    The condition should go further and specify that decoy birds may not be wing-clipped, blinded, tethered or maimed in any way.

    38. Do you agree that we should introduce a dedicated general licence containing standard terms and conditions for the use of cage traps?

    YES

    39. Do you have any views on whether a mandatory scheme of trap registration and tagging in Wales would be beneficial?

    YES

    NRW says that previously there has been ‘very little demand’ for trap registration by trap users – of course there hasn’t! Trap operators are not going to request more regulatory hoops to jump through, are they?! It is a massive missed opportunity for NRW not to impose a mandatory trap registration scheme. Without trap registration, which identifies the actual trap operator, enforcement of the trap regulations becomes virtually impossible on land where more than one potential trap operator is employed. For example, if a cage trap offence has been discovered (e.g. a trapped raptor that has not been released within 24hrs and has died of its injuries), any attending police officer will be met with ‘no comment’ answers from the potential trap operators and therefore the police officer will be unable to identify the actual trap operator, and thus charges cannot be laid. This has happened time and time again on large shooting estates in Scotland, where multiple gamekeepers are employed, which is why SNH (now NatureScot) introduced the trap registration scheme, to enable the enforcement authorities to identify the individual trap operator. And it must be registered to the individual operator, not to an estate for example, for exactly the same reasons as above.

    40. Do you have any additional views on the approach that NRW should take towards regulating the use of cage traps for lethal control of wild birds?

    YES

    Although the proposed licences permit actions that are sometimes justified and necessary, NRW needs to introduce far more accountability into the use of cage traps to kill birds. The new proposals still do not include any requirement for licence returns, e.g. how many birds are killed or what species they are. NRW is effectively still licensing the ‘casual killing’ of potentially millions of birds with absolutely no idea of the numbers involved or the impact on local populations. NRW also needs to consider the seasonal use of cage traps. For example, at present they are operational year-round, but what justification is there for running a multi-capture trap during the summer, autumn and winter? NRW also needs to consider the type of habitat in which cage traps are set. For example, at present they can be deployed in every habitat, but what justification is there for setting a multi-catch trap in woodland or on open moorland, where the risk of trapping birds of prey is highest? NRW should also be considering restrictions to the entrance sizes on funnel and ladder traps. Some of these entrances are disproportionately large, some might argue deliberately so to allow large raptors to enter the traps. NRW should also introduce a competency test for trap operators. Given the rigorous and robust licensing requirements for those who handle birds for scientific monitoring (e.g. ringing), it is inexplicable that those handling birds with a responsibility for the humane destruction of a sentient animal are not individually qualified and repeatedly-re-tested and licensed.

    47. Do you agree with our proposed principles for licensing the lethal control of wild birds for conservation purposes?

    NO

    You’ve done it again – listed 5 complicated principles and asked for a yes or no answer – that’s silly.

    48 – skip this question

    49. Do you think we should: (1) retain a general licence for conservation of wild birds where the evidence indicates that a general licence is appropriate; (2) not grant a general licence for conservation of wild birds; (3) gather evidence on the extent to which GL004 is used before making that decision; (4) adopt another approach?

    Not grant a general licence for conservation purposes

    Jays eating Blackbird eggs is a very different circumstance to Carrion Crows eating Curlew eggs.  The current licences are spectacularly unclear and give the impression that anything goes – exactly what the law does not allow.

    50. Do you agree that the most appropriate basis for identifying the beneficiary species of a general licence for conservation of wild birds is: red or amber listed species which regularly breed in Wales and which are considered vulnerable to predation by one or more of the corvid species concerned?

    YES

    But that consideration of vulnerability to predation must be science based and not on the basis of rural myths or prejudice.

    51.  Do you agree that a general licence for the purpose of conserving wild birds should continue to be limited to conserving only the chicks or eggs of the beneficiary species?

    YES

    The species listed are not predators of adult birds to any important degree.

    52. Do you think that a general licence for the purpose of conserving wild birds should include restrictions on the time of year when the licence can be relied upon?

    YES

    Breeding season only.

    53. Do you agree that carrion crow should continue to be included on a general licence for the purpose of conserving wild birds?

    NO

    Well, perhaps. But only a general licence which specifies the species being protected, the months in which killing is authorised and the geographic location in which it applies – not walking down a street in Cardiff in the autumn for a vague unspecified purpose.

    54. Do you agree that jay should continue be included on a general licence for the purpose of conserving wild birds, but only in relation to the conservation of woodland bird species?

    NO.

    No serious conservation organisation is calling for this – it’s casual unjustified killing.

    55. Do you agree that jackdaw should no longer be included on a general licence for the purpose of conserving wild birds?

    YES

    I agree with NRW – no need for it.

    56. Do you think that Magpie is suitable for inclusion on a general licence for the purpose of conserving wild birds in light of the evidence of its impact?

    NO

    Which species does NRW claim will be protected by this?  You don’t name any – probably because there aren’t any.

  77. Northern Ireland general licences – crowdfunder target reached

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    A massive thank you to everyone who has helped us reach our crowdfunder target this evening!

    What wonderful supporters you all are.

    £45,000 raised in under a week is remarkable, and allows us to prepare for our legal challenge against the Northern Ireland general licences.

  78. E-action – 38,008 emails sent

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    As the #COP26 meeting starts in Glasgow, Wild Justice supporters have sent messages to all elected UK parliamentarians, at Westminster, Holyrood, Cardiff and Belfast, asking for Uplands for people, for the climate and for wildlife. Thank you for raising your voices with 38,000+ messages being sent to decision-makers.

  79. Challenging the Northern Ireland general licences

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    Rook. Photo: Tim Melling

    Today we launch a legal challenge to Northern Ireland’s general licences and we’re asking for your financial support, please.

    We need to raise £45,000 to take this case all the way through the courts and we are more than half way there already.

    We’re very determined to make a difference.

    See our crowdfunder for more details of the case and for an easy way to donate. Please help if you can.

    Aren’t Rooks rather haughty looking birds? Why should DAERA have put them on a general licence where they can be killed in unlimited numbers for ‘conservation purposes’ – when there is no need to kill any at all as a conservation measure?

  80. Three years ago…

    Comments Off on Three years ago…

    Three years ago today, Wild Justice was incorporated as a not-for-profit company limited by guarantee. We think of 13 February 2019 as our day of birth, because that was when we launched ourselves to the public, we’re not sure what that makes today…

    It’s only three years, but we’ve come a long way. What have we achieved? Here are some examples;

    • We’ve done the dull but important things of setting ourselves up, having a website (with content), having a bank account (with some money in it), having a newsletter with c50,000 subscribers (slightly fewer right now, the number fluctuates), doing our accounts, paying our taxes etc.
    • We’ve got involved in issues such as general licences, release of non-native gamebirds, Badger culls, Beaver reintroductions, illegal persecution of Hen Harriers and other raptors, the Environment Bill in England, lead ammunition, glyphosate use by local authorities and a few more. In all cases we’ve made a difference – sometimes a small difference and sometimes a bigger difference. We are often told that our presence has created an atmosphere where governments and agencies are more careful about what they do because, for the first time for ages, they may face legal challenges from a determined group.
    • We’ve stayed friends, the three of us, and we’ve made more friends in the outside world, and we’ve irked some people too. We think that all the irked people are people we don’t mind irking. We’ve worked with other organisations in joint campaigns, often through Wildlife and Countryside Link, and we’re happy to muck in with others if we can make a real difference.
    • We’ve attracted a lot of public support from those who want non-governmental organisations to take a more active and robust approach. We think we’ve identified a niche and helped to fill it.

    It’s a start, but what of the future? Here are some things we’ve decided and some things we are thinking about:

    • we’re going to employ our first staff member fairly soon – a part-time post helping us with the mundane running of things but also with setting up new campaigns and new legal cases.
    • we’re not going to move from being a not-for-profit company to a charity in the near future – there would be some financial benefits, but not huge ones, and there would be higher administrative costs and restrictions on the types of things we could say.
    • we’re not going to sell you merchandise – the world is full of stuff, and that’s one of the problems with it. We retain the right to change our minds on this in the future!
    • we’re going to continue with a mixture of campaigning and legal challenge – bringing them together to help nature is what we’re about.

    Why Wild Justice is different:

    • we don’t have members who pay us a subscription – we depend on public donations exclusively. If you don’t like what we are doing then you won’t donate, and then we’ll fizzle out. It’s a very pure funding strategy.
    • we promote the work and campaigns of other organisations – you don’t see that very often in the world of wildlife non-governmental organisations
    • we are robust – we’ll take anyone on, and we’re not that bothered what the Establishment thinks of us
    • we’re making challenges that wildlife would make if they had a voice
    …from a supporter recently – very appropriate
  81. Burning bogs – we have appealed

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    We told you last week that we had been refused permission for judicial review of the DEFRA regulations on burning on peatlands. Today we can tell you that we have appealed this judgment – it’s actually called a renewal. It’s quite a short document, see below, and basically says that the judge got it wrong and can another judge have another think about it please.

    At the foot of the renewal is the short phrase ‘…the claimant will, by 29 October 2021, serve notice of objection as to the Interested parties’ costs‘. We are not arguing that we should pay lower costs, we are quite happy to pay the £10k that the process demands under the Aarhus Convention for an environmental case. In such cases, costs are capped, it’s a very sensible system to allow proper challenge of the decisions of statutory bodies where the claimant is acting for the public good and will make no personal gain from the case. We are objecting because we think that the Interested Parties (BASC, Countryside Alliance, National Gamekeepers’ Organisation and the Moorland Association) 1) added nothing to the legal argument 2) want to give the money away anyway and 3) we would much rather the taxpayer were reimbursed when we lose. Basically, the Interested Parties butted in and are now collaring some of DEFRA’s cost entitlement (in our view).

    The statement by the Interested Parties is classic grandstanding. It cannot possibly be maintained that our legal challenge sought to disrupt the DEFRA regulations – it seeks to improve them because, as DEFRA themselves said when they were introduced;

    There is a consensus that burning of vegetation on blanket bog is damaging to peatland formation and habitat condition. It makes it more difficult or impossible to restore these habitats to their natural state and to restore their hydrology.

    https://www.gov.uk/government/news/englands-national-rainforests-to-be-protected-by-new-rules

    We do not think that the Interested Parties are part of the consensus to which DEFRA referred whereas Wild Justice clearly is.

    DEFRA, despte its word, did not go anywhere far enough and left more than half of the relevant area unprotected. Pointing that out is not ‘disrupting’ the regulations, it is attempting to ‘make them fit for purpose’ (see here and here).

    The Interested Parties in this case are vested interested parties outside of the consensus of the need for habitat protection and climate protection. they are, look at them, a bunch of recreational shooters who are defending a worthless hobby which involves shooting birds for fun, and causing environmental damage as a consequence.

    We wonder why DEFRA came up with such bizarrely worded and ineffective regulations – perhaps they were influenced by the Interested Parties. Let’s be clear, we believe that the Interested Parties want burning on peatlands and on protected blanket bogs to continue as much as possible for as long as possible. That’s what they are interested in.

  82. Beavers – just saying…

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    This letter was sent on behalf of Wild Justice in response to the DEFRA consultation on Beaver reintroduction.


    In para 73 of the consultation DEFRA says ‘We intend to make beavers a European Protected Species by listing them in Schedule 2 of the Conservation of Habitats and Species Regulations 2017. This change is to implement legal obligations under the Bern Convention and does not form part of the proposed approach that is being consulted upon.‘.
    Wild Justice wishes to comment on those two sentences even though they are not part of the consultation.

    1. We welcome DEFRA’s intention to make Beaver a European Protected Species by listing this species in Schedule 2 of the Conservation of Habitats and Species regulations 2017. This is long overdue – more than a decade overdue – and is now a matter of urgency. England needs to catch up with Scotland in this regard.
    2. We believe it is accepted that Beavers were resident in England, Wales and Scotland until 1790, and perhaps later. 
    3. We believe it is accepted that Beavers have been reintroduced in England for at least 19 years: starting at Ham Fen in 2002. Beavers now live unenclosed in the wild in numerous river catchments, particularly in the south west of England. Beavers are also present in Scotland with populations resulting both from an official trial reintroduction and unlicensed introductions.
    4. In England the Beaver is still listed as an animal ‘no longer normally present’ on Schedule 9 (Part 1B) of the Wildlife & Countryside Act 1981 despite it living in the wild in numerous river catchments across the UK and in England.
    5. As DEFRA must be aware, changes to Schedule 9 Part 1 of the WCA were made by the Infrastructure Act 2015 (“IA 2015”). Section 24 IA 2015 removed a number of species from Part 1 and inserted them into a new Part 1A (“Native animals”). Section 24 IA 2015 also created a new Part 1B (“Animals no longer normally present”) into which the Wild Boar was inserted, along with the Beaver (which had not previously been listed in Part 1) as the only two species listed.
    6. And as DEFRA should be aware, during the passage of the Infrastructure Bill, the Minister for Transport, Baroness Kramer confirmed that the purpose of the creation of Part 1B Schedule 9 was to “clarify that former native species—species which were once present in this country but which are or have been absent for a period—should be categorised differently from non-native species for the purposes of these provisions … We recognise that in some circumstances reintroductions can be merited and desirable. Our amendments will mean that where these animals have been reintroduced lawfully following full consideration of their likely impacts by the licensing authority, those animals are out of scope of these powers”.
    7. The Secretary of State has the power to add species to, or remove species from, Schedule 9 as the need arises under section 22(5) WCA 1981.
    8. The inclusion of the Beaver in Part 1B was vigorously opposed by a number of MPs and NGOs, including Friends of the Earth, on the grounds that the Beaver was even by that time reestablished in the wild and therefore ‘normally present’ in part due to deliberate and planned reintroductions.
    9. We welcome the fact that the Secretary of State will review the legal status of the Beaver and intends to recognise Beavers as a European Protected Species.  The Secretary of State should also review the listing of this species on Schedule 9 Part 1B of WCA.  Should he fail to review the legal status of the Beaver or decide not to amend its status following a review, that decision may be subject to a challenge by way of judicial review. The potential grounds for such a challenge could include the argument that the Secretary of State has failed to have regard to a relevant matter (the existence of healthy wild populations in England). 
    10. We thought we ought to mention our views at this stage to encourage the Secretary of State to make an overdue decision as rapidly as possible.
    11. We’re pretty sure we could put the Secretary of State in touch with some people who could show him some wild Beavers in England if he remains of the view that they are ‘animals no longer normally present’. 

    Wild Justice

  83. Congratulations to Trees for Life and Scottish Beavers

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    Beaver Photo: scotlandbigpicture

    We were delighted to hear yesterday that the excellent Scottish-based group, Trees for Life, have won their legal challenge against NatureScot on the issuing of licences to kill Beavers. In her judgment, Lady Carmichael said the killing of Beavers authorised by NatureScot had been unlawful and the agency must in future set out its reasons for approving lethal control of this protected species. This is an important decision for Beavers, and may have implications for other licensing action by this agency.

    Wild Justice was contacted directly by Trees for Life yesterday with the news as we contributed £5000 to the costs of the legal challenge and publicised their crowdfunder to our supporters through our newsletter. We were very happy to help in this way, win or lose, but this result is very welcome indeed. Congratulations to Trees for Life, their legal team and to Scottish Beavers!

    We can reveal now that Wild Justice started a legal challenge on this subject back in 2019 and then, for various reasons, called a halt to it. We’ve heard that NatureScot staff have boasted that they saw off Wild Justice, and to some extent they did. We’ve always somewhat regretted that outcome. This is a very significant success for Trees for Life, we are glad to have played a very small part in the outcome and we take great pleasure in seeing this result.

    Trees for Life press release:

    Legal win offers hope of new era for beavers and farmers

    Licensed beaver killings must halt and all previous beaver killings authorised by NatureScot have been unlawful, judge rules

    Trees for Life’s successful court challenge to the Scottish Government’s beaver killing policy offers hope for a new era that benefits nature, climate action and farmers, says the rewilding charity.

    As Scotland prepares to host the UN’s COP26 climate summit in 10 days time, today’s ruling by Lady Carmichael confirms that all previous licensed killings of beavers authorised by the Scottish Government’s nature agency NatureScot have been unlawful and have been revoked, and that all official beaver culling must halt until NatureScot has rebuilt its approach.

    The ruling confirms that from now on NatureScot must set out openly and fully the reasons why it believes any future licence to kill beavers should be granted.

    “With Scotland hosting what could be the most important summit on climate breakdown in our lifetimes, this result offers a better future for Scotland’s beavers. The Scottish Government must take this ruling seriously, and it means that from here on in there can be no more rubber-stamping of licensed killing of beavers,” said Alan McDonnell, Trees for Life Conservation Manager.

    “This is an important victory for accountability and transparency, which will benefit everyone including conservationists and farmers.”

    Lady Carmichael’s ruling applies to all European protected species in the UK, and so has wide-ranging implications for wildlife.

    Now that beavers cannot be killed under license without a full explanation of the reasons, NatureScot needs to rethink its approach to beaver management. Trees for Life says the killing of beavers should only ever a last resort, and is calling for beavers to be relocated to areas of Scotland where they have been missing for centuries, instead of being shot.

    “By moving rather than shooting beavers, we can help them get to work boosting biodiversity, tackling climate breakdown and creating wildlife tourism opportunities,’ said Alan McDonnell.

    “The Scottish Government has been blocking relocation of beavers to areas of Scotland where they belong but are missing, but today’s ruling creates hope that this will change so that farmers will no longer be put in a position where they have no choice but to shoot much-loved animals.”

    Beavers create wetlands that benefit other wildlife, soak up carbon dioxide, purify water and reduce flooding, but the animals sometimes need managing if they cause damage to farmland.

    Since the Government legally protected beavers in 2019, its nature agency NatureScot has allowed over 200 beavers to be killed under license – despite laws under which beavers are a protected species which should not be killed unless there is no satisfactory alternative. 

    The Government’s refusal to allow beavers to be relocated to new areas of Scotland, even though NatureScot has identified over 100,000 hectares of habitat, had left Tayside farmers whose crops are damaged by beavers with little option but to apply for a culling licence. Today’sruling means that from now on, more suitable management alternatives can be considered.

    NatureScot’s failure to make the licensed killing of beavers a last resort was challenged by Trees for Life’s judicial review heard by the Court of Session in June. The charity’s crowdfunder for the case was supported by more than 1,500 people and raised over £60,000. 

    In 2020, Trees for Life’s petition to the Scottish Parliament – calling for the Scottish Government to relocate rather than shoot beavers – was signed by almost 17,000 people in what was the most successful petition to the Parliament in over a decade. 

    Trees for Life says NatureScot must now ensure beaver management is farmer-friendly and within the law. The Government should ensure practical and financial support for farmers – including a beaver relocation service, and access to timely and efficient advice and resources.

    Adam Eagle, Chief Executive Officer of legal specialist rewilding charity The Lifescape Project, which spearheaded the litigation with Trees for Life, said: “This judgment means that all licences for killing beavers which had been in force are unlawful and killing must stop today. It also means that all killing to date has been illegal. 

    “This decision is wonderful news for Scotland’s biodiversity. But why it took a legal challenge to ensure NatureScot follow its legal obligations to protect beavers, remains a worrying question.”

    Trees for Life is dedicated to rewilding the Scottish Highlands. See treesforlife.org.uk.

    To read Lady Carmichael’s ruling see www.scotcourts.gov.uk/docs/default-source/cos-general-docs/2021csoh108.pdf?sfvrsn=9ea84440_1.

    Ends

  84. Natural England – let’s call the whole thing off!

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    Photo: Gordon Yates

    You may remember that Natural England has been thinking about reintroducing Hen Harriers into southern England for years – huge amounts of time have been spent on this controversial project.

    Wild Justice wrote to Natural England in mid June questioning the scientific basis for their plans for a reintroduction project – see here. Tomorrow, Natural England’s Scientific Advisory Committee will consider this project and our comments. But Natural England has told us that tomorrow’s meeting ‘…will help inform the next steps for the Project, including timescales for importing and releasing birds and communications about that.’.

    Natural England has told Wild Justice that it ‘… intends to transfer rescued young hen harriers from France later in 2021 or early 2022’ and that it ‘ … is negotiating the transfer of rehabilitated adult hen harriers from Spain later
    in 2021 or early 2022.’.

    This project is controversial for five main reasons:

    • Natural England has struggled to find a release site that will welcome Hen harriers – this isn’t a very promising situation for a bird that will wander widely in its early years.
    • Many, not all, UK conservationists regard this project as a distraction from Natural England’s real duties to solve the in situ conservation problems facing Hen Harriers in their current English range ie illegal persecution on grouse moors
    • Many, not all, UK conservationists don’t think the reintroduction has a high enough chance of success to make the risks and effort worthwhile
    • Natural England has struggled to find collaborators abroad, in the wide range of the Hen Harrier in continental Europe, who are willing to be associated with this project.
    • The Secretary of Ste for DEFRA, Mr Eustice,announced in May that an England Reintroduction Taskforce is to be set up to set standards and priorities for reintroduction projects – Naural England should not jump the gun.

    Natural England has many more important things to do than continue to pursue this vanity project. We hope they’ll just call the whole thing off (and why not call off their equally controversial brood-meddling trial too?).

  85. Update on our e-action – 37,000 emails sent

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    You have sent 37,000 emails to UK parliamentarians through our e-action, Uplands for people, for the climate and for wildlife. Thank you!

    All elected parliamentarian in England (MPs), Scotland (MSPs), Wales (MSs) and Northern Ireland (MLAs) has received an email from at least one of their constituents calling for action on Uplands for people, for the climate and for wildlife.

    The top-ranking English constituencies

    All constituencies across England have supported our e-action, but the MPs receiving the highest number of emails are Conservative MPs, in rural constituencies, many of them with grouse moors:

    High Peak, Robert Largan MP, 128 emails

    Skipton and Ripon, Julian Smith MP, 119 emails

    Sheffield Hallam, Olivia Blake MP, 108 emails

    Derbyshire Dales, Sarah Dines MP, 107 emails

    Totnes, Anthony Mangnall MP, 104 emails

    Calder Valley, Craig Whittaker MP, 99 emails

    Hexham, Guy Opperman MP, 99 emails

    Stroud, Siobhan Baillie MP, 91 emails

    Westmorland and Lonsdale, Tim Farron MP, 91 emails

    Suffolk Coastal, Therese Coffey MP, 83 emails

    Somerton and Frome, David Warburton MP, 83 emails

    West Dorset, Chris Loder MP, 82 emails

    Wealden, Nus Ghani MP, 82 emails

    The Cotswolds, Geoffrey Clifton-Brown MP, 80 emails

    North Devon, Selaine Saxby MP, 79 emails

    Torridge and West Devon, Geoffrey Cox MP, 78 emails

    St Ives, Derek Thomas MP, 78 emails

    Wells, James Heappey MP, 78 emails

    Arundel and South Downs, Andrew Griffith MP, 78 emails

    Bexhill and Battle, Huw Merriman MP, 77 emails

    The top-ranking Scottish constituencies

    iParl

    MSPs representing all Holyrood constituencies have been sent emails – the number received by individual MSPs in each constituency and region varies, but the five strongest-supporting constituencies all have upland areas within their boundaries:

    1. Skye, Lochaber and Badenoch

    2. Perthshire North

    3. East Lothian

    4. Midlothian South, Tweeddale and Lauderdale

    5. Inverness and Nairn

    The constituencies with the least support are all in the lowland and urban central belt of Scotland: Hamilton, Larkhall and Stonehouse; Cumbernauld and Kilsyth; Glasgow Anniesland; Airdrie and Shotts; Glasgow Provan.

    If you have signed the e-action and sent a message to your elected representative(s) – thank you! Now please ask your friends to do the same. This e-action closes on 28 October.

    If you haven’t yet participated then please have a look at https://wildjustice.eaction.org.uk/saveourskydancers2021/ and see whether you can take part. Many thanks!

  86. A setback – permission refused

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    Photo: Sarah Hanson

    We heard yesterday, Friday, afternoon that we have been refused permission for judicial review of the much criticised and frankly grossly inadequate regulations brought in by DEFRA to limit vegetation burning on peatland soils in the uplands of England. This is disappointing but we remain of the view that the case is arguable and the reasoning behind it is correct. We shall be conferring with our lawyers on this matter later this week.

    Wild Justice believes that the DEFRA measures are inadequate; they do not protect all peatland areas, only those with peat above a certain depth and which are notified as SSSIs and designated as SPAs and/or SACs. It is accepted by all that this protection amounts to less than half of the area of upland peat that could have been protected with better, tighter, more appropriate, wording. The Hon Justice Dove has decided that we cannot go to court to argue these points and states that DEFRA has considerable latitude in framing such regulations. We wonder how little DEFRA could do and get away with it. We shall consider an appeal.

    In the run up to the COP26 meeting, the Westminster government is allowing damaging climate-harming activities in the English uplands. It is not taking the steps that are needed, even easy ones like limiting burning of vegetation (usually for the largely irrelevant hobby of grouse shooting), when it is hosting a hugely important international climate change meeting.

    In this case, so far, the law has not come to the aid of the environment.

    We need a better future for the uplands across the UK. Thank you for sending 35,000 messages to your elected parliamentarians across the UK asking for a better future for uplands for people, for the climate and for wildlife. If you haven’t sent that message yet then please click here to participate. The e-action will close in 12 days time.

    To donate to Wild Justice’s work by bank transfer, PayPal or a cheque in the post – click here

  87. Our letter on the start of the pheasant-shooting season

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    We were delighted to see our letter published in various regional newspapers in the north of England at the beginning of October.

    Here is an example from the Ripley & Heanor News (2nd Oct 2021):

    We will monitor how best to protect our native wildlife

    Pheasant shooting started on October 1. Did you know that 51 million pheasants are captive-bred and released to provide targets for people to shoot at for recreation?

    Pheasants are not native to the UK and, thanks to legal challenges from Wild Justice, the Department for Environment, Food and Rural Affairs has, this year, introduced some restrictions on release numbers in order to protect native wildlife. We’ll be monitoring how that goes.

    Some pheasants end up in the human food chain and most are shot with lead ammunition. Lead is a poison and the Food Standards Agency recommends that pregnant women and young children avoid eating game meat shot with lead.

    Wild Justice is pressing the FSA to introduce proper health warnings on game meat and proper testing of lead levels in such meat.

    Chris Packham, Ruth Tingay & Mark Avery (Wild Justice)

  88. Update on our e-action – 25,000 emails sent

    Comments Off on Update on our e-action – 25,000 emails sent

    Our e-action, Uplands for people, for the climate and for wildlife has passed the 25,000 emails milestone.

    Almost every elected parliamentarian in England (MPs), Scotland (MSPs), Wales (MSs) and Northern Ireland (MLAs) has received an email from at least one of their constituents calling for action on Uplands for people, for the climate and for wildlife.

    The national breakdown

    Wales 40 of 60 MSs have been contacted (67%)

    Northern Ireland 85 of 90 MLAs have been contacted (94%)

    Scotland all 129 MSPs have been contacted (100%)

    England 530 of 533 MPs have been contacted (99%)

    UK parliamentarians 97%!!

    The top-ranking English constituencies

    The seven top English constituencies in responding to our e-action are, or are immediately adjacent to, upland areas:

    High Peak, Robert Largan MP, 91 emails

    Skipton and Ripon, Julian Smith MP, 90 emails

    Sheffield Hallam, Olivia Blake MP, 82 emails

    Derbyshire Dales, Sarah Dines MP, 76 emails

    Hexham, Guy Opperman MP, 74 emails

    Calder Valley, Craig Whitaker MP, 70 emails

    Westmorland and Lonsdale, Tim Farron MP, 66 emails

    Stroud, Siobhan Baillie MP, 62 emails

    Arundel and South Downs, Andrew Griffith MP, 59 emails

    Suffolk Coastal, Therese Coffey MP, 59 emails

    The missing English constituencies

    There are just three English constituency MPs who have not yet had an email asking for Uplands for people, for the climate and for wildlife. One of them is easy – it is Chris Packham’s MP, Julian Lewis, who won’t accept email correspondence! The others are in London; Erith and Thamesmead, and West Ham.

    The top-ranking Scottish constituencies

    MSPs representing all Holyrood constituencies have been sent emails – the number received by individual MSPs in each constituency and region varies, but the five strongest-supporting constituencies all have upland areas within their boundaries:

    1. Skye, Lochaber and Badenoch

    2. Perthshire North

    3. East Lothian

    4. Inverness and Nairn

    5. Midlothian South, Tweeddale and Lauderdale

    The constituencies with the least support are all in the lowland and urban central belt of Scotland: Hamilton, Larkhall and Stonehouse; Cumbernauld and Kilsyth; Glasgow Anniesland; Airdrie and Shotts; Glasgow Provan.

    From now we will bring you occasional updates on progress but if you have signed the e-action and sent a message to your elected representative(s) – thank you! Now please ask your friends to do the same.

    If you haven’t yet participated then please have a look at https://wildjustice.eaction.org.uk/saveourskydancers2021/ and see whether you can take part. Many thanks!

  89. Today is the opening day of the Pheasant-shooting season

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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

    Today is the first day of the Pheasant-shooting season.

    Pheasants are not native to the UK, they were brought here by the Romans, but the Romans didn’t breed 50 million Pheasants in captivity and release them into the countryside for recreational shooting, did they?

    Legal action by Wild Justice, which started in summer 2019, led to DEFRA agreeing (in autumn 2020) to introduce restrictions on the release of Pheasants (and Red-legged Partridges – 12 million of them are released for shooting too).  Pheasants have been added to Schedule 9 of the Wildlife and Countryside Act in England which means that it is illegal to release them into the countryside except under licence. DEFRA have issued licences which will allow many of the previous releases to go ahead but not all of them. In particular, sites of nature conservation importance should be better protected from the direct impacts of gamebirds eating invertebrates, vegetation, reptiles and scratching around and pooing in such vast numbers.

    We’re unconvinced that these regulations are tight enough and will be watching carefully what happens (and the situation is complicated by Brexit and coronavirus – isn’t everything?).

    But make no mistake about it – the changes brought in as a result of Wild Justice’s legal challenge represent a massive reform of gamebird shooting in the UK.  Pheasant and Red-legged Partridge are now listed along with Grey Squirrel, American Crayfish and Japanese Knotweed as species that cause harm and whose releases must be controlled.
    About 15 million of those 50 million Pheasants are shot for fun, and some of those find their way into the human food chain, although far too many are discarded and buried or dumped in the countryside.

    Most Pheasants which are shot in the UK are shot with lead ammunition. Lead is a poison – that’s why we’ve got rid of it from petrol, water pipes, paint, fishing weights and other sources.  And yet we shoot lead pellets into birds that enter the human food chain. The Food Standards Agency advise everyone to reduce their intake of lead in food but especially that women trying to get pregnant, pregnant women, toddlers and young children should avoid eating game meat shot with lead. Did you know that? No? Well, we don’t expect that many people do because when you buy lead-shot game in supermarkets, from butchers or at market stalls there are no warnings or labels.

    Wild Justice is pressing the FSA to bring in proper labelling of game meat with warnings about lead content, and we shall be testing supermarket game meat for lead levels again this coming autumn. So far, only Waitrose has committed to supply lead-free shot game and only Waitrose label their game meat with health warnings.

    Here are some interesting facts about Pheasants:

    • the weight of captive-bred, released non-native gamebirds is the same as all the native birds in the UK put together
    • the scientific name for Pheasant is Phasianus colchicus – the ancient land of Colchis in present-day Georgia is just about the closest to here that truly wild Pheasants live, and most of their natural range is from the Black Sea east to China and Japan
    • Pheasants are omnivores and eat everything from reptiles – including lizards and even snakes – to invertebrates and many plants.  The ecological impact, of such huge numbers, and of their droppings, is of concern to conservationists.
    • nearly half the Pheasants in the European countryside are found in the UK alone.
    • about a fifth of the Pheasants released each year for shooting are eaten by Foxes before the shooting season starts – predator populations are thought to be artificially high in the UK partly because of this ‘free meat’, and that might well have impacts on other native wildlife such as ground-nesting birds such as waders.

    Makes you think doesn’t it?

    To donate to Wild Justice’s work by bank transfer, PayPal or a cheque in the post – click here

  90. Ask your local authority questions about their pesticide use – a template

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    Photo credit: Jurgis Mankauskas/Shutterstock

    This is a template that you can use (simply copy and paste the text below, and fill in a few details) to ask your local authority about their use of the pesticide glyphosate (more information about glyphosate – click here). When you get a reply we would love to see it – please forward to admin@wild justice.org.uk and we’ll assess it and add it to the list of local authorities that have been contacted. Thank you.

    By email to information team of local authority

    Dear [Local Authority name]

    Re: Herbicide Use – Requests for information under the Environmental Information Regulations 2004 and/or the Freedom of Information Act 2000

    I am a resident of [village/town/city] in [Local Authority’s name]. I write regarding [Local Authority’s name]’s use of glyphosate-based herbicides, about which I would like to know more.

    In this letter I set out a request for environmental information, which I make in accordance with the Environmental Information Regulations 2004 (the “EIR 2004”) and/or the Freedom of Information Act 2000 (the “FOIA 2000”). Where the Information Sought is available online, I am happy to receive that information by way of link to the respective online source.

    Information Sought

    I request the following information:

    1. Which glyphosate-based herbicides[1] are currently used by or on behalf of the Council and/or on land owned by, managed by, or under the control of, the Council?
    2. For the most recent 12-month period for which information is available, please could you tell me the amount and brand of each glyphosate-based herbicide in question, as well as the size of the area over which they were used.
    3. Please could you explain the basis for (i) the Council’s choice of particular product(s), and (ii) the Council’s decision to use glyphosate-based herbicides rather than alternative methods. Please could you provide me with copies of any policy or other document which informs that decision-making.
    4. I understand that, if the Council uses, or instructs other to use, plant protection products (including glyphosate-based herbicides) then the Council is required by law[2] to ensure that[3]:
    • all reasonable precautions are taken to protect human health and the environment;
    • the application of the plant protection product is confined to the crop, land, produce, buildings, contents of buildings, materials or other areas intended to be treated;
    • and when the product is used in places of heightened concern (which includes, among others, areas used by the public or vulnerable groups[4], areas in the close vicinity of healthcare facilities, and on or along roads, railway lines, very permeable surfaces, or other infrastructure close to surface water or groundwater) that the amount used and the frequency of use are as low as reasonably practicable.

    5. Please explain how the Council ensures that it complies with the requirements set out above in paragraph 4, particularly in terms of operational decision-making by the Council?

    6. Please provide me with copies of any policy or other document which informs the Council’s decision-making in relation to compliance with the legal requirements set out in paragraph 4 above. Please also provide copies of evidence of the Council’s decision-making over the past 12 months relating to the records of decisions taken to ensure the amount of plant protection products used and the frequency of use are as low as reasonably practicable. 

    Time for a response

    I should be grateful for a response as soon as possible and no later than 20 working days in accordance with section 5(2) of the EIR 2004, or, if the information is not environmental information, promptly and no later than 20 working days in accordance with section 10 of the FOIA 2000.

    Yours faithfully

    [Signature]

    [Name]


    [1] Defined to include products containing glyphosate

    [2] Plant Protection Products (Sustainable Use) Regulations 2012, Regulation 10

    [3] Regulation 10(1)

    [4] Defined to include “persons needing specific consideration when assessing the acute and chronic health effects of plant protection products. These include pregnant and nursing women, the unborn, infants and children, the elderly and workers and residents subject to high pesticide exposure over the long term”.

  91. Northern Ireland General Licences expire today

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    The three Northern Ireland general licences, TPG1, TPG2 and TPG3 which purport to authorise the killing of specific listed bird species to protect human health, to prevent serious damage to crops and for alleged conservation purposes expire today. The Northern Ireland Department of Agriculture, Environment and Rural Affairs (DAERA) seems to have no plan to reissue them any time soon and has got itself into a mess.

    The wording of the three ‘current’ licences is explicit:

    As things stand, as from darkness tonight it will be illegal to kill Magpies, House Sparrows, Woodpigeons and a range of other species in Northern Ireland because these licences will have expired.

    What are General Licences? All wild birds are protected by law – that is the very sensible starting point for wild bird protection. There are two relatively small classes of bird for which there are legally defined exceptions to that rule. One exception relates to gamebirds (yes, an ugly term) meaning those species that society has deemed suitable for killing for recreational purposes, and sometimes for consumption as food, such as Pheasants, many ducks, and some waders such as Snipe. the other exception is a range of species that cause us, people, problems and which can be killed under specific circumstances and conditions. Those are the species covered by these three licences until darkness today.

    Wild Justice and General Licences. Wild Justice has, since our launch in February 2019, challenged the rationality and legality of the general licences which exist in their slightly different forms in all four UK nations. We have been successful in reducing the species covered and tightening up the conditions of their use. These licences exist on government websites – you don’t have to apply for them and you aren’t sent a bit of paper that shows you can use them – they are generally available to all and sundry, but they do have conditions of use which are widely ignored or simply aren’t understood well enough by people with guns in the countryside.

    Wild Justice and the Northern Ireland General Licences. Wild Justice first wrote to DAERA in May 2019 pointing out our success in getting the general licences in England temporarily revoked. This year we have been in regular correspondence with DAERA pointing out that their General Licences TPG1, TPG2 and TPG3, which expire today, are not fit for purpose. We have told DAERA that their general licences are the worst of those in place in the four UK nations and that they would face a legal challenge from us if they persisted with issuing seriously flawed general licences. Earlier this year DAERA issued a consultation on their general licences, which they then withdrew. We welcomed the consultation and would have supported many of the measures it contained. But now we have reached the point when the current licences expire.

    What happens next? The three general licences expire today. Tomorrow, our understanding is that there is no legal cover for anyone killing the species listed on those expired licences in Northern Ireland. Saturday 11 September will mark the beginning of a period of unprecedented protection for the species listed on the general licences. The roof will not fall in on rural life in Northern Ireland.

    It is possible that DAERA may seek to extend their general licences but if so they have not told Wild Justice that is the case. And if they do, and if the licences are as error-strewn and have the same legal flaws as the expiring licences Wild Justice will mount a legal challenge to them – of that DAERA can be in no doubt given our correspondence with them over the recent months.

    Wild Justice calls on DAERA to announce that the species covered by their general licences are now protected, like almost all other wild birds, and that killing them will be unlawful until new general licences are issued. DAERA should make clear, immediately, how they intend to proceed. Wild Justice would welcome a public consultation on the terms and details of new general licences for Northern Ireland.

    Wild Justice depends on donations to carry out our campaigning and legal work (and to pay our running costs). If you like what we do then please consider making a donation through PayPal, bank transfer or a cheque in the post – see details here

  92. Update on e-action – for people, for the climate and for wildlife

    Comments Off on Update on e-action – for people, for the climate and for wildlife

    Our e-action, Uplands for people, for the climate and for wildlife was launched over a month ago. Almost every MP in England, MSP in Scotland, MS in Wales and MLA in Northern Ireland has received an email from at least one of their constituents calling for action on Uplands for people, for the climate and for wildlife. We have plans to make the e-action whizz along now that parliamentarians are back in their parliaments after the summer break. Watch this space.

    The headline number

    Over 16,500 emails have been sent to elected parliamentarians across the UK already – asking them to deliver Uplands for people, for the climate and for wildlife. That equates to over 20 emails to the average elected parliamentarian across each of the four UK parliaments. Thank you!

    A national breakdown

    Wales 40 of 60 MSs have been contacted (67%)

    Northern Ireland 85 of 90 MLAs have been contacted (94%)

    Scotland 127 of 129 MSPs have been contacted (98%)

    England 529 of 533 MPs have been contacted (99%)

    The top-ranking English constituencies

    All of the 10 top English constituencies in responding to our e-action are, or are immediately adjacent to, upland areas:

    Skipton and Ripon, Julian Smith MP, 71 emails

    High Peak, Robert Largan MP, 71 emails

    Sheffield Hallam, Olivia Blake MP, 65 emails

    Derbyshire Dales, Sarah Dines MP, 62 emails

    Hexham, Guy Opperman MP, 58 emails

    Sheffield Central, Paul Blomfield MP, 47 emails

    Thirsk and Malton, Kevin Hollinrake MP, 45 emails

    Westmorland and Lonsdale, Tim Farron MP, 44 emails

    Richmond, Rishi Sunak MP, 44 emails

    Berwick upon Tweed, Ann-Marie Trevelyan MP, 43 emails

    The missing English constituencies

    There are just four English constituency MPs who have not yet had a single email asking for Uplands for people, for the climate and for wildlife. One of them is easy – it is Chris Packham’s MP, Julian Lewis, who won’t accept email correspondence! The others are all in London; Erith and Thamesmead, Harrow East and West Ham.

    The missing Scottish constituencies

    The two Holyrood constituencies from which emails have not been sent to their MSPs are: Aidrie and Shotts and Glasgow Provan. If you live in either of those constituencies, or have a friend you can nudge, we’d be pleased to see the full set achieved as soon as possible – thanks!

    Wales and Northern Ireland

    The software system we use for this e-action has some wrinkles in it and it’s less good at providing us with fine-scale information about Wales and Northern Ireland. However, it’s clear, particularly in Wales, that support for the e-action is especially high in upland areas themselves.

    We will continue to bring you occasional updates on progress throughout September and October.

    If you have signed the e-action and sent a message to your elected representative(s) – thank you! Now please ask your friends to do the same.

    If you haven’t yet participated, then please have a look at https://bit.ly/3CAzFQJ and see whether you can take part. Many thanks!

  93. Response to e-action from Westminster Liberal Party

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    Thank you for email. I appreciate you taking the time to share your further thoughts.

    I recognise that grouse shooting is an issue on which strong views are held on both sides, and I am aware that we have corresponded previously on this issue. I still believe that a tightening of the rules is needed and that partnership working between conservationists and the shooting industry should be explored and encouraged. I appreciate, however, that we may have to agree to disagree on this issue. 

    I would like to assure you that both my Liberal Democrat colleagues and I take the twin crises of the Climate and Ecological Emergencies extremely seriously and are committed to taking the immediate action which you rightly say is needed. Never has this been more urgent and necessary, with the stark warnings issued in the IPPC report this week, and extreme weather events that we have seen causing widespread destruction and devastation to so many, from the wildfires in Greece and Turkey to the severe flooding in Germany.

    This includes a commitment to introduce a Nature Act to restore the natural environment through large scale restorations of peatlands, woodlands and marshlands, and setting legally binding near-term and long-term targets for improving water, air, soil and biodiversity, and supported by funding streams of at least £18 billion over five years.

    We are living in one of the most nature-depleted countries in the world and are currently only meeting 3 out of 20 of our UN biodiversity targets. We need a strategy to double nature, which I believe is best done by devolving powers to local authorities. 

    The Liberal Democrats are campaigning to expand the Local Nature Resource Strategies to all local authorities. These strategies map the most valuable sites and habitats for wildlife in their area and identify where nature can be restored. We would then ensure that these areas were included in all planning decisions and that destruction of the natural environment in these areas would be an offence under the Wildlife and Countryside Act 1981.

    In my view, the current government is missing many opportunities for real change to address the Climate and Nature Emergencies and merely paying lip service to these issues, and I have been holding the Government to account on this through my work in Parliament. I have always said that climate action delay is just as bad as climate change denial, and I very much share your deep concerns and frustration that the Government is not treating the Climate and Nature Emergencies with seriousness that they require. I set out some of the actions that I feel that the Government should be taking now in the Queen’s Speech in May: https://hansard.parliament.uk/Commons/2021-05-13/debates/3C945343-3504-4311-B086-EFF86920C0E0/ABrighterFutureForTheNextGeneration?highlight=green%20homes%20grant#contribution-AB8DC466-4B35-47FC-90AF-72438977003A

    Earlier this year, I called on the Government to giving the Office of Environmental Protection the powers and resources to hold public authorities to account on environmental standards, after the Government gave permission for a neonicotinoid pesticide to be used: https://hansard.parliament.uk/Commons/2021-04-22/debates/1935A51C-BEFF-4724-97DE-F28838AEE723/NeonicotinoidAlternatives#contribution-4EBAE0CE-9E10-4E51-A53C-484FCAD2C722

    I secured and led a debate on Global Human Security to promote an honest discussion about the threats that put all our lives at risk, which are becoming more complex and diverse. The Climate and Nature Emergencies are the most serious crises that we face and affect all of us, and this begs the question whether the way that we currently look at security policy limits the extent to which Government can keep us safe. You can read the full debate, here, should this be of interest: https://hansard.parliament.uk/Commons/2021-04-13/debates/10C5F578-2289-4E2E-85DD-0BD5D75EA7A2/GlobalHumanSecurity?highlight=nature#contribution-959498F7-08F1-4677-B456-C8F31BD7144C

    Most recently, I co-sponsored a debate in July regarding COP26 which, if the government gets its house in order, provides the greatest opportunity for climate action since the 2015 Paris Agreement. As I said last month, “COP26 must be a COP of global solidarity. It is time for the Government to put their money where their mouth is. The world is watching to see whether the UK will step up to the plate.”

    Should you be interested in reading the full debate, you can do so here: https://hansard.parliament.uk/Commons/2021-07-22/debates/5F6AF58F-A792-413D-9DF5-704C07E6E5A5/COP26ConferencePriorities

    I appreciate that we may not agree on all of these issues, but I hope that this has helped to demonstrate my and my party’s commitment to tackling the Climate and Nature Emergencies. 

  94. Response to e-action from Scottish Conservative Party

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    Thank you for your email in relation to Scotland’s uplands.

    My party and I believe that our natural environment is Scotland’s greatest asset, and we must do everything we can to protect and nurture it.

    However, in recent decades we have experienced catastrophic loss of species and their habitats, accelerated by climate change. We have heard warm words from the SNP Government on climate change, but that must be backed up by urgent action. They have failed to meet their own critical emission reduction targets for the last three years running, which is simply unacceptable.

    In our recent manifesto we proposed a Nature Bill to strengthen environmental protections on land, in our rivers and at sea – so that we can reverse the decline in native species.

    This included a commitment to ending the extraction of peat for use in compost and increasing peatland restoration to 20,000 hectares annually by 2024. As you know, peatland is a vital carbon sink, sequestering more tonnes of CO2 a year than all other types of vegetation in the world combined.

    Also included was a commitment to increase new tree planting in Scotland to 18,000 hectares annually by 2024. We believe that trees are nature’s carbon capture technology and the basis of many natural habitats, however quality and biodiversity are also important, so we would increase the proportion of new planting that are of native species, while ensuring that Scotland’s forests are productive.

    We also put forward plans to create Scotland’s third national park in Galloway, which would protect the environment, encourage tourism and provide benefits for health and wellbeing, as a beautiful place to relax and enjoy the scenery and wildlife, as you suggest.

    The Scottish Conservatives want to see Scotland’s natural ecosystem thrive, so it can be enjoyed by future generations.

  95. Response to e-action from Westminster Labour Party

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    Thank you for contacting me about the protection of uplands.

    I support investment in the restoration of a variety of habitats. The Conservatives have said uplands are precious, but I am concerned they are not doing enough to protect native species and wildlife and that they lack a serious plan to deliver a recovery for nature.

    Protecting biodiversity, halting the decline of nature and restoring habitats and wildlife should be priorities as the keys to tackling the climate emergency through rapid carbon storage and biodiversity gain. It is intrinsically important to protect species and ensure that wildlife can be enjoyed by everyone.

    We need ambitious biodiversity targets. The Government plans to introduce a target for halting the decline of nature in England by 2030 to the Environment Bill. However, I do not think it is acting quickly enough and should set this target urgently and ahead of COP26 to meet the significant challenge of the nature emergency. It should also seek to reverse the decline in nature with a dramatic incline in species abundance.

    I am also concerned about the continued persecution of birds. Species conservation plays a vital role in restoring biodiversity and enabling nature’s recovery and, in my view, the Conservative Government is lacking a strategic approach to conservation through the protection, restoration and creation of habitats over a wide area to meet the needs of individual species under protection.

    We also need ambition on reforesting and rewilding. I supported a Labour amendment to the Environment Bill for a bold, ambitious tree planting strategy in England, as we need more trees and better protections to restore our most vulnerable habitats. However, the Conservatives voted this down.

    More widely, there is an urgent need for a coherent response to the climate and ecological emergency at COP26 in November. Worldwide, unusual weather events show dystopia is here today. The collective ambition to limit the rise in global temperature to 1.5C above pre-industrial levels must be translated into concrete action with an unequivocal promise to deliver. The world is looking to Britain, as host of the summit, to deliver, but I am concerned the Government lacks sufficient action to meet this ambition.

    Rest assured that myself and Labour colleagues will continue to battle for nature and environmental protection.

    I hope this is helpful, but if you have any further concerns or queries then please do not hesitate to get back in touch.

  96. Response to e-action from Northern Ireland Alliance Party

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    Thank you for your e-mail and for raising your concerns with me.

    I totally agree that we face a climate and ecological crisis, and Northern Ireland’s unique natural environment is under significant threat.

    The Alliance Party firmly believe that the upcoming UN Climate Change Conference of the Parties (COP26) must be a turning point in our efforts to tackle this crisis. We urgently need ambitious, long term plans and concrete actions to restore our damaged ecosystems.

    The Alliance Party is committed to playing our part in relation to this challenge. We have developed our own Green New Deal tailored to Northern Ireland. The policies in this document show how we plan to simultaneously combat the climate emergency and inequality through investment, radical change and breaking down the barriers of division. The document also includes our detailed plans for protecting and enhancing our natural environment, and can be accessed via the following link: www.allianceparty.org/greennewdeal.  

    I can assure you that landscape management and the restoration of our natural resources will remain at the forefront of the Alliance Party’s agenda and we will continue to advocate for further governance and regulation to protect our environment for generations to come.

    On the particular issue of Hen Harriers, I raised this issue with the AERA Minister last year. I am attaching his response for your perusal.

    If you have any queries on any of the above or in relation to any other matter, please do not hesitate to come back to me.

  97. Response to e-action from Welsh Conservative Party

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    Thank you for contacting **** **** regarding your concerns about the Welsh uplands.

    I strongly believe in the importance of using Wales’s natural resources in a responsible manner, and believe that we all have a vital part to play in the protection of the Welsh countryside, as well as supporting our rural economy.  Welsh Conservatives therefore support better education on the Countryside Code, so that all visitors to our rural areas are respectful and well-informed. 

    As tourism and agriculture are the main sources of income for Wales’s rural economy, we believe that, not only is diversification key through better infrastructure such as broadband, but those who tend and live in rural Wales should be given more support.  However, after 22 years of Labour and Labour-led Governments, our rural communities’ needs have been routinely neglected.  Rest assured, my colleagues and I in the Welsh Conservatives will continue to stand up for Welsh rural communities and custodians of our land at every opportunity.

    I also wholeheartedly agree that Wales’s uplands must be protected, well-managed and enhanced.  Where upland peatlands are left undisturbed, I know they play an important role in storing carbon, maintaining biodiversity and protecting against flooding. Sadly, many of Wales’s uplands and peatlands are also not in good condition, with some bogs even releasing CO2.  Welsh Conservatives have therefore welcomed the National Peatlands Action programme in Wales, which is intended to help lock in carbon and reinvigorate vital habitats.  However, I am concerned that the funding provided by the Welsh Labour Government – £5.75m over five years – lacks ambition.  By comparison, in England, the UK Conservative Government is investing £640m to restore 35,000 hectares by 2025.  I assure you that my colleagues and I in the Welsh Conservatives will press the Welsh Government to take similar action.

    Finally, I also believe that it is vital to strengthen enforcement against the killing of raptors, as these birds play a crucial role in Wales’s ecosystem and must therefore be protected. While all wild birds are protected under the Wildlife and Countryside Act 1981 and there are strong penalties already in place, raptor persecution should be identified as a wildlife crime priority. Therefore, my colleagues and I will continue to push the Welsh Government to work with the Home Office and establish a National Rural Crime Taskforce for Wales, which would support the reduction in wildlife crime.


    I hope this reassures you and thank you again for taking the time to contact me.

  98. Response to e-action from Scottish National Party

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    Thank you for your email – I share your concerns regarding preservation and biodiversification of uplands in Scotland.
     
    In regard to this autumns international meetings on climate and biodiversity, at COP 26 in Glasgow the UK Government Prime Minister Boris Johnson will be representing the whole of the UK on this matter. I understand that the First Minister, Nicola Sturgeon MSP has expressed her wish to represent Scotland at such a crucial international meeting on a devolved matter. 
     
    However, I understand the Prime Minister has made comments to suggest that he does not want the First Minister of Scotland in attendance. It is disappointing as the Scottish Government have pioneered world leading climate change legislation that has set a target date for net zero emissions by 2045.
     
    Irrespective of this, I understand that the Minister for Environment, Biodiversity and Land Reform Mairi McAllan MSP has been working hard to ensure that uplands are a top priority for the Scottish Government. 
     
    This includes guidance from the Scottish Forestry that will use less disruptive techniques when preparing ground for woodland creation. It will ensure that approval for new applications will no longer be given on any peat soils over 10cm in depth after 1st  October. It will only be less intensive cultivation techniques that are approved. This will help preserve peatlands which are a rich natural resource for promoting biodiversity and achieving net zero targets through its natural carbon capture. 
     
    Additionally, I understand that the Minister is supporting restoration of peatlands across Scotland in an aim to prevent flooding, promote safe habitat for wildlife and catching carbon from the atmosphere. 
     
    I hope this helps.

  99. NRW consults on general licences in Wales

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    https://ymgynghori.cyfoethnaturiol.cymru/evidence-policy-and-permitting-tystiolaeth-polisi-a-thrwyddedu/nrw-s-approach-to-regulating-the-shooting-and-trap/consultation/

    Yesterday, Natural Resources Wales launched a consultation on their general licences. The consultation is lengthy but that is because it is asking a wide range of sensible questions and seeking answers. We will review the consultation carefully and consult with others but Wild Justice welcomes the existence of this consultation. The consultation closes on 11 November, so there is plenty of time to think about the answers. We will provide advice to our supporters on points that it would be useful to make, on this blog but also through our free newsletter – subscribe here.

    Wild Justice is not the only conservation organisation that has been seeking reform to these licences but we are the only one to have taken a legal challenge against them, and that challenge, and those we have taken against similar licences in England, have driven reform. Our legal challenge to NRW’s general licences (see here, here, here) made NRW clarify and consider its position in the face of legal scrutiny, and the outcome of our challenge feeds directly into some of the more helpful parts of this consultation.

    Our subsequent letter to NRW on general licences and their duties as a regulator, coupled with enquiries from Wild Justice’s supporters have clearly had an impact on NRW’s position. Thank you for your support – you have made a difference already.

    Wild Justice has always been concerned with the principle of wide-ranging general licences and with the details of their application. Our main concern has been the badly operated so-called ‘conservation’ licences but we shall be carefully scrutinising NRW’s proposals for all their general licences. NRW’s ‘conservation’ licence GL004 does not reflect the current state of knowledge of impacts of predation by corvids and do not reflect the actions of conservation organisations in Wales or eleswhere in the UK. So we are pleased to see that NRW is consulting on:

    • removing Jackdaw, Jay and Magpie from their ‘conservation’ licence – we called for this to happen
    • the value of their Red/Amber list approach – we think this should be greatly improved
    • the very necessity of general licences (which they call a light-touch approach – we would call them a heavy-handed approach) when the alternative of specific licences is available – we made this pont strongly in our legal challenge
    • the temporal restrictions that should apply to any such killing if they are designed to protect eggs and chicks of specific species – we made this point in our legal challenge

    It’s one thing to consult on these matters, but it’s another thing entirely to act. We welcome the consultation and we hope that NRW will act – we think they will on some of these measures. But there is more likely to be action if NRW receives many responses to its consultation. We will provide advice to our supporters on points that it would be useful to make, on this blog but also through our free newsletter – subscribe here.

    We’d like to thank Wild Justice’s supporters for their help in getting this promising-looking consultation to happen. You funded our legal challenge that has been influential in framing the issues and you wrote in your hundreds to NRW asking them to act. You are a part of this growing climate of reform.

  100. Glyphosate use by local authorities

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    Last summer we wrote to 43 local authorities in England and Wales about their use of glyphosate-based herbicides. Although herbicide use is in theory regulated, we found a very wide and worrying range of approaches by local authorities, all of whom were acting under the very same regulatory regime. Some appeared to be paying scant attention to their legal responsibilities.

    Here we describe what we have done so far, we highlight some local authorities who have taken good action, and highlight some progress we have made in persuading others to move in the right direction. We also will be giving you the information on which you can act with your own local authority in due course.

    We aren’t telling you here and now about the local authorities who need to up their game as we are still in correspondence with some of them, but we will certainly be prepared to shine a light on those authorites who are doing the least on this matter.

    Glyphosate – why are we concerned?

    Glyphosate (you may know it as Roundup) is one of the most-used individual pesticides in the world. It is used in agriculture, in public spaces (such as parks but also in the streets) and in private spaces such as gardens.

    This is of course an issue about which others raised concerns, and organisations such as Pesticides Action Network have documented the problem over time. In March 2015, the International Agency for Research on Cancer classified glyphosate as “probably carcinogenic to humans. There is a live debate about glyphosate’s environmental impacts and use in gardens (eg see here). Some countries and many cities across the world have banned or strongly regulated the use of glyphosate. Prof Dave Goulson’s new book Silent Earth highlights this issue and his petition, which Wild Justice supports, aims to limit use of glyphosate in built up areas – click here.

    Wild Justice is not an expert in pesticides, but we recognise that there are concerns about the use of such products which include human health and environmental issues. Does the law recognise these issues too?

    The law – what are local authorities required to do?

    The regulatory regime in the UK arises from the Sustainable Use of Pesticides Directive 2009/128/EC, and Regulation (EC) No 1107/2009 on the sustainable use of pesticides sets out the requirements of public bodies using (or permitting the use of) Plant Protection Products, which include glyphosate-based herbicides. Article 14 of the Directive requires Member States to:

    take all necessary measures to promote low pesticide-input pest management, giving wherever possible priority to non-chemical methods, so that professional users of pesticides switch to practices and products with the lowest risk to human health and the environment among those available for the same pest problem. Low pesticide-input pest management includes integrated pest management.”

    The Directive was transposed into UK law by the Plant Protection Products (Sustainable Use) Regulations 2012 which came into force from 18 July 2012. The transposed domestic regime requires public bodies using (or causing or permitting other to use) plant protection products, including glyphosate-based herbicides, to ensure that:

    • all reasonable precautions are taken to protect human health and the environment
    • the application of the plant protection product is confined to the crop, land, produce, buildings, contents of buildings, materials or other areas intended to be treated
    • when the product is used in places of heightened concern (which includes, among others, areas used by the public or vulnerable groups, areas in the close vicinity of healthcare facilities, and on or along roads, railway lines, very permeable surfaces, or other infrastructure close to surface water or groundwater) that the amount used and the frequency of use are as low as reasonably practicable.

    It is clear that the regulatory regime in place in the UK recognises that there are risks to the use of herbicides such as glyphosate and has set in place, for nearly a decade, measures which should limit use of such products. But are local authorities paying attention to the regulations?

    The EIR responses

    Wild Justice is accustomed to working in areas where the authorities will say that ‘There are laws that cover this – don’t you worry about it’ and where the relevant industry, interest group or government agency will say ‘It’s not really a problem, but if it is, it is well regulated anyway’. Our experience, for example in raptor persecution, welfare issues in the Badger cull and compliance with general licences, is that regulations are poorly enforced, and advice on best practice rarely heeded, therefore the existing laws do not really work anything well enough. We wondered whether pesticide use would be another such issue.

    We wanted to get an up-to-date detailed picture of how much glyphosate-based herbicides local authorities are using, what steps are they taking to ensure the adverse impact on nature and people is reduced, and what have they done to reduce use of glyphosate and develop the use of alternatives? We set out these questions and others in a series of requests made under the Environmental Information Regulations 2004 (EIR).

    After much to-ing and fro-ing we received the local authorities’ responses and our lawyers set about assessing them against what the law requires. There was significant and startling variation in how local authorities approach the issue in practice. There were several local authorities who are taking commendable approaches to reduce their use of glyphosate and who have thorough and coherent policies in place. And then there are those who appear to have given the issue no thought, do not have in place any policies, or who hide behind the facts that glyphosate use per se is not banned outright and they contract its use on their land out to third parties. So who are the good and who could do better?

    Good local authorities

    We’d like to give a shout-out to five local authorities who seem to us to be doing a very good job, and a much better job than most others. They are:

    • Glastonbury – banned use of glyphosate in 2015
    • Frome – banned use of glyphosate in 2016
    • Croydon – no glyphosate used on Council-owned or -managed land
    • Brighton-Hove – good pesticide reduction plan and decided top phase out glyphosate use from 2019
    • Lewes-Eastbourne – no glyphosate used on Council-owned land

    Reforming authorities

    For a number of other authorities, the responses were much less promising, and so we wrote again, highlighting what the law requires and asking for a more detailed response. We can report that several authorities have now agreed to look again at their use of glyphosate, and we commend them for that approach.

    • Denbighshire County Council – “will imminently be seeking approval of an overarching policy which will seek to set out the information set out above on a corporate level for the whole of the council”. That’s good news and we’re looking forward to reviewing the policy when ready.
    • Milton Keynes Council –  has managed a significant reduction in glyphosate in the period 2015 to 2021 and has a pesticides position statement. But in practice, the use remains high. They have offered to meet with us to discuss how they can improve, and that is an offer we are keen to take up.
    • Norfolk County Council – At more than 5300 litres/12 months, NCCs use of glyphosate-based herbicide is among the highest of any local authority. Norfolk has agreed to put in place an overarching policy which is being prepared and we have asked to be shared with us.
    • Redcar & Cleveland Borough Council – Redcar & Cleveland reported to us that they’ve used 2120 litres of glyphosate-based herbicide over a 12 month period. but has, however, pledged to factor Wild Justice’s concerns into a current review of its Biodiversity Strategy. We look forward to considering that in detail, and hope that Redcar & Cleveland will now take steps to develop a coherent policy to phase out its use of glyphosate.

    Too many other authorities

    Many local authorities simply don’t have a pesticide reduction strategy nor any active policies to minimise use. They tend to say that glyphosate use is legal (which it is) and that that is an end to it (which it isn’t).

    For more details of the good guys and the reforming authorities and a list of the authorities contactedsee this more detailed blog.

    Next steps

    Follow-up

    Having considered the responses, there are many local authorities that appear not to be doing enough to make sure their use of glyphosate-based products is safe and/or to reduce the amount of glyphosate they are using. So, Wild Justice is now writing to them to set out in detail the ways in which they are not complying with the relevant legislative scheme and how their use of glyphosate-based herbicides may be unlawful.

    To give a flavour of the problems we’ll be looking at, one local authority has a strikingly high use of three products at over 6500 litres over 12 months, but does not appear to have any written policy on their use. Another local authority recognises the efficacy of alternatives but has not explored the viability of adopting them, or taken any steps in that direction. Others have tried to offload all responsibility for the issue out to third party contractors, relying on contractual assurances and certifications, but saying nothing about taking steps towards minimising use in the longer-term.

    Scotland and Northern Ireland

    We’ll be writing to more local authorities in these nations – who do you suggest might be good authorities to contact, either because they are particularly good or particularly bad?

    What you can do

    If your local authority has not already been contacted (see list here) then you may wish to contact them yourself. We have produced a template that you can use to get the type of information we have collected – click here. We’d like to hear how you are getting on and we’ll publicise good and bad practice.

    Glyphosate testing

    We’re planning glyphosate testing of food – a bit like we tested lead levels in supermarket game meat (see here – and we will be doing more of this in the autumn). Watch this space and sign up to our free newsletter to get the news first – click here.

    Conclusion

    As we outlined above, glyphosate-based products have the potential to cause significant damage to human health and to the environment and, in theory, their use is regulated because of those risks.

    Our guess was right – in many local authorities the regulations have very little impact at all – the regulations are not enforced by the authorities whose job it is to enforce them and to comply with them in their own activities.

    Wild Justice wants to work with those local authorities who are willing to improve, but, after years of complacency by some authorities, will now begin the next steps to take action against those who are turning a blind eye to the issue. 

    To donate to Wild Justice’s work by bank transfer, PayPal or a cheque in the post – click here

  101. Glyphosate – recognition for local authority action

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    Wild Justice has contacted a range of local authorities to quiz them about their use of, and policies on, the herbicide glyphosate (list updated on 27 September);

    1. Brighton
    2. Bristol
    3. Camden
    4. Carmarthenshire CC
    5. Ceredigion CC
    6. City of London
    7. Conwy County Borough Council
    8. Cornwall CC
    9. Croydon
    10. Denbighshire CC
    11. Dudley
    12. Eastbourne
    13. Erewash
    14. Frome
    15. Glastonbury
    16. Hackney
    17. Hammersmith & Fulham
    18. Hampshire CC
    19. Ipswich
    20. Lewes
    21. Manchester
    22. Medway
    23. Merthyr Tydfil
    24. Milton Keynes
    25. Monmouthshire CC
    26. New Forest
    27. Norfolk CC
    28. Northamptonshire CC
    29. Redcar & Cleveland
    30. Rother
    31. Rushmoor
    32. Saffron Walden
    33. South Tyneside
    34. Southwark
    35. Surrey CC
    36. Teignbridge
    37. Telford & Wrekin
    38. Torfaen County Borough Council
    39. Vale of Glamorgan
    40. Wandsworth
    41. Wirral
    42. Mendip District Council
    43. Somerset CC

    We are following up with several of these councils, particularly those whom we feel are failing in their duties to protect the public and the environment.

    Here we will list local authorites who are doing well in our opinion, those who are undertaking substantial action to reform and those who aren’t doing nearly enough. This list will be updated as new information is collected.

    The good local authorities: Frome, Glastonbury, Croydon, Lewes-Eastbourne, Brighton and Hove

    Making some progress: Denbighshire, Milton Keynes, Norfolk, Redcar and Cleveland

    Not doing nearly enough: to be updated

    More details

    The good local authorities:

    • Glastonbury – In Glastonbury a Motion was agreed in 2015 to cease the use of glyphosate as a means of treating any weeds. Glastonbury have been particularly progressive in their weed management approach by using alternatives such as Foamstream, power washers and hand-picking.
    • Frome – In Frome, the town council passed a Motion to ban the use of glyphosate in 2016 and they are aiming to push this ban further by way of discussions with Mendip District Council and Somerset County Council.
    • Croydon – Croydon don’t use glyphosate on any Council-owned or -managed land.
    • Lewes-Eastbourne – Lewes-Eastbourne Council doesn’t use glyphosate on its own land, except on rare occasions for certain species such as Japanese Knotweed. Their policy on pesticides was impressive, with a whole section dedicated to the use of glyphosate and alternatives, and they plan to have all public parks largely or completely free of pesticides.
    • Brighton-Hove – Brighton and Hove Council have implemented a Pesticide Reduction Plan and decided to phase out glyphosate back in November 2019

    If you live in any of the five council areas above then why not contact your local council and say ‘Well done!’ – they won’t get many communications like that.

    The reforming councils:

    • Denbighshire – Denbighshire uses 3 products at what we consider moderately high volume, some 940 litres over 12 months. Like some other authorities, Denbighshire places significant emphasis on its compliance with certifications and health & safety standards (such as COSHH), and, like some others, notes that glyphosate-based herbicides are approved for use in UK, and that there is therefore nothing unlawful per se about using them in Wales. It is encouraging to learn that the use of pesticides, including the herbicide glyphosate, has been called-in annually over the previous two years by Denbighshire’s Partnerships Scrutiny Committee. But the absence of an overarching policy and an absence of effort to reduce use and consider alternatives is concerning. So it is heartening to be told that Denbighshire has introduced a new Weed Spraying Policy and a Corporate Health, Safety and Welfare policy, and “will imminently be seeking approval of an overarching policy which will seek to set out the information set out above on a corporate level for the whole of the council”. That’s good news and we’re looking forward to reviewing the policy when ready.
    • Milton Keynes – From Milton Keynes response, it appears they have no real policy on the use of glyphosate. They instead rely significantly on their third party contractors doing the right thing. Their response revealed a lack of proper consideration of alternatives or reduction of use. We recognise that Milton Keynes has managed a significant reduction in glyphosate in the period 2015 to 2021 and that they have a pesticides position statement. But in practice, their use remains high. They have offered to meet with us to discuss how they can improve, and that is an offer we are keen to take up.
    • Norfolk – At more than 5300 litres/12 months, Norfolk County Council’s use of glyphosate-based herbicide is among the highest of any local authority. Unfortunately, Norfolk also lacks adequate policies for use of the 3 products they have opted for – there is no consistent policy across 7 departments that use glyphosate, no specific consideration of vulnerable groups, and, it appears, no thought has been given to the use of alternatives. Despite all this, Norfolk has agreed to put in place an overarching policy which is being prepared and we have asked to be shared with us.
    • Redcar and Cleveland – Another authority with a fairly high use of glyphosate, Redcar & Cleveland reported to us that they’ve used 2120 litres of glyphosate-based herbicide over a 12 month period. Redcar & Cleveland referred extensively to their reliance on certifications and licence compliance in their use of glyphosate, but that of course is to comply with the basic requires for the use of these dangerous products; it says nothing about what policy the local authority has adopted to work towards minimising use and exploring alternatives. Redcar & Cleveland has however pledged to factor Wild Justice’s concerns into a current review of its Biodiversity Strategy. We look forward to considering that in detail, and hope that Redcar & Cleveland will now take steps to develop a coherent policy to phase out its use of glyphosate.

    If you live in any of the four council areas above then why not contact your local council and say ‘Please do more – I see you’re doing something’ – they won’t get many communications like that.

  102. Response to e-action from Westminster Conservative Party

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    Thank you for your email  about our upland areas. I would like to assure you that I am committed to protecting our uplands, the wildlife that thrives there, and the people who live there too. I agree that restoring nature is crucial and I am pleased that the Prime Minister has committed to protecting 30 per cent of the UK’s land by 2030 and will be making nature a key focus of COP26. As well as this, the Environment Bill has been amended in the House of Lords to require a historic, new legally binding target on species abundance for 2030 with the aim of halting the decline of nature in England.

    As you may know, the UK is moving to a new agricultural system which will reward farmers and land managers for the work that they do to enhance the environment. The environmental land management schemes being introduced will pay for sustainable farming practices, the creation and restoration of habitats, natural flood management, species management, and making landscape-scale environmental changes, among other things. I know that the uplands provide rich opportunities for the provision of environmental public goods and will be well placed to participate in these schemes.

    Peatlands are our biggest terrestrial carbon store and it is welcome that ministers have published an England Peat Plan which provides an ambitious framework to improve the management of these areas. Alongside this, a Trees Action Plan sets out the long-term vision for the planting and management of woodlands and trees. These plans are underpinned by the £640 million Nature for Climate Fund which will support a trebling of tree planting across England by the end of this Parliament and help to restore 35,000ha of peatland by the end of this Parliament.

    Finally, I would like to assure you that raptor persecution is one of six national wildlife crime priorities. The Raptor Persecution Priority Delivery Group considers what action should be taken to prevent crime, gather intelligence on offences and enforce against. The National Wildlife Crime Unit also gathers intelligence on illegal activities and provides assistance to police forces when required.

    Thank you again for taking the time to contact me.

    Yours sincerely

  103. Response to e-action from Scottish Labour Party

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    Thank you for your email highlighting your concerns over the climate and nature emergency we face and the importance of Scotland’s uplands.

    As someone who represents a rural area and as Scottish Labour’s spokesperson on Rural Affairs, the future of Scotland’s uplands is incredibly important to me. Around half of Scotland is upland, and although they remain renowned for their wildness, there is no doubt that they have borne the often adverse impact of centuries of increasing human activity. More than ever they need our support to protect and restore them.

    One of the most important actions we need to take is better protection of raptors as you highlight. This is an issue I’ve raised in Parliament in the past and will continue to do so. We need to see more effective monitoring of raptor conservation, tougher penalties for those who persecute our raptors and crimes that impact on raptors being more vigorously investigated and given a higher priority. There have been too many cases in our South Scotland region where it’s clear there has been raptor persecutions, but such crimes have not been as vigorously pursued as they should be.

    We also need to see a far fairer distribution of our land including more community ownership. I have supported a number of community land buyouts locally and I am confident they will be as successful as previous ones in the region. But to really achieve that fairer distribution of land ownership we need more resources for community buyouts including increased funding for the Scottish Land Fund and direct intervention when land is not used in ways that serve the public interest.

    In our manifesto for the recent Scottish Parliament election, Scottish Labour also called for legislation to ensure that no one individual can acquire large swathes of Scotland’s land and prevent land ownership via offshore tax-havens.

    We also argued that public sector organisations should be allowed to participate in land markets with the aim of transferring the land into local sustainable ownership, as a basis for wealth building and income retention in communities.

    I also very much agree with you about the importance that needs to be placed on the return of natural woodlands and bogs. Scottish Labour supports planting at least 15,000 hectares of trees a year and increasing peatland restoration to 20,000 hectares each year, alongside measures to end commercial peat extraction. We also fully support at least 50% of all woodland expansion being planted with native species and at least 10% delivered through natural regeneration, issues that I have pursued in Parliament. We cannot afford to see a repeat of the same mistakes made in the past, especially in our area, where huge sways of our land are planted with repetitive non-native species.

    These actions would help create employment in our area in a sector which does provide good opportunities in our area. That’s one of the reasons Scottish Labour has also called for the establishment of a Scottish Conservation Corps, modelled on the Civilian Conservation Corps of the New Deal, dedicated to restoring Scotland’s natural environment and we estimate this could create up to 10,000 jobs across Scotland.

    There is no doubt that much needs to be done to restore and enhance Scotland’s uplands but with the right policies and leadership, we can ensure we not only begin to tackle the climate and nature emergency we face, but do so in a way that creates sustainable employment and that is what I will continue to a argue for as one of your local MSPs.

    In the meantime, thank you once again for your email and please do get in touch if you would like to discuss this or any other matters further.

    Kind Regards

  104. Response to e-action from Scottish Green Party

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    Many thanks for writing to me on the protection of Scotland’s uplands for people, climate, and wildlife. 

    The Scottish Greens manifesto for the recent election contained the commitment to delivering the system change needed to tackle the climate and nature emergencies, as well as the bold and urgent measures we need to protect and enhance our uplands now and for future generations. Our manifesto includes strengthening and establishing new protected areas, introducing legally binding nature-recovery targets, supporting community-led rewilding, creating a nature network for Scotland, and creating more woodland for people, climate, and wildlife. You can read the full manifesto chapter on Restoring Scotland’s Environment here.

    We recognise the impacts of the twin emergencies of climate breakdown and a collapse in biodiversity on our uplands. As valuable carbon sinks and homes to a wealth of important wildlife and ecosystems, our uplands are a crucial part of our response to the climate and nature emergencies. We want to see our upland communities thrive and will take the bold action needed to protect, restore, and manage our uplands while stopping unsustainable land management and ending the persecution of raptors. 

    We are currently exploring ways to take forward our manifesto commitments in the coming parliamentary session, and pursuing protection for Scotland’s uplands will be a high priority. The Scottish Greens’ Spokesperson for the Environment, Climate, and Transport, Mark Ruskell MSP, has already been in contact with organisations working toward tackling raptor persecution and reforming our uplands (incl. Revive , Scottish Raptor Study Group, Scottish Environment LINK, and RSPB Scotland) to deliver rapid action on these issues. The Scottish Greens have created a £10m Nature Restoration Fund in the previous session, and are planning to invest a further £150m in the fund over the next five years. Mark Ruskell MSP alongside fellow Scottish Greens, are committed to scrutinising the government’s responses to unsustainable land management and raptor persecution, while putting pressure on Ministers to make faster progress toward extending the powers of the SSPCA to investigate wildlife crime.

    This is an extremely important issue and I would like to thank you for continuing to bring it to the attention of politicians and keeping the pressure on. 

    Many thanks,

  105. Response to e-action from Welsh Labour Party

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    The Welsh Government is committed to accelerating work on the National Forest for Wales in this Senedd term. This includes improving existing woodland and supporting communities across Wales, including in our uplands, to create 30 new woodlands and to connect habitat areas.

    Current guidance around the planting of trees is too complicated; it is not easy for those who want to create new woodland to navigate regulatory and funding systems. The Welsh Government will therefore soon publish new, simpler guidance written from a citizen’s perspective and is exploring how the employment of new woodland officers can help communities across Wales to navigate interactions with local authorities and Natural Resources Wales (NRW).

    The Welsh Government will also introduce a new woodland creation funding offer. This will include separate funding for creating new woodland, to develop a regular stream of new projects and enable more agile decision-making in allocating funding to tree planting. A pilot of this system will be launched later this year, making support available for at least 500 hectares of future woodland plans. Further detail will be set out in a new Woodland for Wales Action Plan which will be published later this year.

    Like woodlands, peatlands play an important dual role in absorbing vast quantities of carbon emissions and supporting a rich suite of habitats and species. And as you will be aware, peat is most extensive in the uplands where there is widespread blanket bog. Last year the Welsh Government launched Wales’ first National Peatlands Action Program with the ambition to restore 5,000 hectares of the most modified areas of peatland and to bring all peatlands with semi-natural vegetation, a further 30,000 hectares, into favourable management. £1m was invested in 2020-21 to deliver the first year of the restoration program leading to more than 1,000 hectares being restored. You can find out more about the scope of coordinated actions over the next few years to re-wet and restore our peatlands by going to https://cdn.cyfoethnaturiol.cymru/media/692535/national-peatlands-action-programme-annexb-accessible.pdf.

    The Welsh Government is serious about addressing biodiversity loss across Wales. It has put significant new resources into maintaining and enhancing biodiversity in its budget for this year and has also refreshed its national Nature Recovery Action Plan (NRAP) to take into account the growing evidence around the scale of biodiversity loss and ecosystem damage. The aim of the NRAP is to build resilient ecological networks across our landscapes and sea to safeguard species and habitats and the benefits they provide, address the root causes of biodiversity loss, and target interventions to help species recovery.

    As part of the effort to support the creation of more habitats rich in biodiversity, the Welsh Government is committed to creating or significantly enhancing green spaces which will be accessible to and valued by local communities. This includes 2,000 pollinator habitat sites, 100 ‘Tiny Forests’ (small but dense and diverse woodlands) and a number of habitat creation schemes at rail stations and transport interchanges.

    NRW also has a major part to play to halting and reversing the decline in nature. NRW are expected to make strides to restore its own Natura 2000 sites and to take forward the planned programme for restoration of woodland and degraded peatlands to create healthy functioning wet bogs. This will be an important component of wider efforts to bring wildlife back into the uplands.

    On the issue of flood prevention, this year in Wales over £65 million is being invested in flood risk management in Wales – the largest amount invested in Wales in a single year. What’s more, the Welsh Government’s Programme for Government commits to delivering nature-based flood management in all major river catchments which will not only reduce flood risk to homes but also help to reduce pollution and restore natural habitats. The Welsh Government is also committed to expanding wetland and woodland habitats and to improving their resilience at the same time as relieving pressure on hard flood defences. Welsh Labour in government will also legislate in this Senedd term to strengthen the requirements for the use of sustainable drainage systems that provide wildlife habitat.

    I fully agree that the decline in populations of raptors such as hen harriers is deeply alarming and that we need to do everything possible to clamp down on wildlife crime, and raptor persecution in particular. Tackling raptor persecution is a priority for the Welsh Government. Together with the RSPB, it has jointly funded a new Raptor Fieldworker in Wales who started work in April of last year to establish the extent of illegal killing of birds of prey in key areas of Wales through proactive presence in areas of risk. The fieldworkers is also supporting the police and Welsh Government officers in following up reports of persecution incidents from the public. 

    In terms of the specific concerns around hen harriers, the Welsh Government has fully funded the continuation of the RSPB Hen Harrier tagging, which started in 2015 as part of an EU LIFE project. This is enabling the RSPB to continue to fit satellite tags to Welsh hen harrier chicks to understand more about their post-fledging dispersal, to aid with management plans for the Special Protection Areas and implement further protection measures for this species.

    Partnership working between the Welsh Government, Natural Resources Wales (NRW), the Police, Fire Service, Government Agency Intelligence Network and the Crown Prosecution Service plays a fundamental role in detecting, preventing, investigating and enforcing wildlife and rural crime, both at a national strategic level and a regional operational level. Welsh Government officials work closely with the four Welsh Police Forces, NRW and other enforcement bodies through the Wales Wildlife and Rural Crime Group. The Group identifies regional wildlife and rural crime priorities as well as ensuring Welsh interests are represented at UK Priority Delivery Groups, including the Raptor Persecution Priority Delivery Group. 

    I hope that my response demonstrates both my and the Welsh Labour Government’s strong commitment to speaking up for our uplands and for nature, and tackling the climate and nature emergencies.  I will continue to take an active interest in developments in this area and will raise the points you have made in all relevant discussions.

    Yours sincerely,

  106. Response to e-action from Plaid Cymru

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    Thank you for getting in touch to raise awareness for such an important issue.

    Wales is often defined by its uplands- a country marked by mountains, moorlands, and upland heaths. Uplands play a crucial societal role in Wales: as noted by the 2020 State of Natural Resources Report, our uplands provide us with food and fibre, soil carbon storage, climate change mitigation, drinking water, water regulation, flood alleviation, energy production, recreation and tourism opportunities, along with scientific, educational, historical and archaeological services- the list goes on.

    Despite the importance of upland habitats in Wales, they are indeed under threat, but this need not be the case. In advance of COP26 and COP15- this autumn’s international meetings on climate and biodiversity- Wales has an opportunity to lead the way in the sustainable management of its uplands, for nature, for climate, and of course, for people.

    Rest assured, Plaid Cymru is absolutely committed to ensuring the Senedd and Welsh Government play their role in protecting and improving our natural environments. Indeed, following a Plaid Cymru motion and the ensuing debate, the Senedd and the Welsh Government voted to declare a nature emergency, to introduce legally-binding nature recovery targets, for habitats and for species, and to establish an environmental governance body to police environmental crime.

    As your elected representative, I’d be glad to commit to this new vision for the uplands of Wales: for people, for the climate and for wildlife. This vision must be an absolute priority for the Welsh Government and for the Senedd, and I will do my upmost to ensure this vision is realised.

    Yours sincerely,

  107. Update on e-action – do you live in Redcar?

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    Our e-action, Uplands for people, for the climate and for wildlife was launched a week ago and already almost every MP in England, MSP in Scotland, MS in Wales and MLA in Northern Ireland has received an email from at least one of their constituents calling for action on Uplands for people, for the climate and for wildlife.

    The headline number

    Over 14,000 emails have been sent to elected parliamentarians across the UK since last Saturday – asking for them to deliver Uplands for people, for the climate and for wildlife. Thank you!

    A national breakdown

    Wales 40 of 60 MSs have been contacted (67%)

    Northern Ireland 85 of 90 MLAs have been contacted (94%)

    Scotland 126 of 129 MSPs have been contacted (98%)

    England 526 of 533 MPs have been contacted (99%)

    The top-ranking English constituencies

    Nine of the 10 top English constituencies in responding to our e-action are, or are immediately adjacent to, upland areas:

    Skipton and Ripon, Julian Smith MP, 67 emails

    High Peak, Robert Largan MP, 62 emails

    Sheffield Hallam, Olivia Blake MP, 60 emails

    Derbyshire Dales, Sarah Dines MP, 54 emails

    Hexham, Guy Opperman MP, 47 emails

    Westmorland and Lonsdale, Tim Farron MP, 44 emails

    Thirsk and Malton, Kevin Hollinrake MP, 42 emails

    Richmond, Rishi Sunak MP, 39 emails

    Sheffield Central, Paul Blomfield MP, 39 emails

    Cotswolds, Geoffrey Clifton-Brown MP, 38 emails

    Berwick upon Tweed, Ann-Marie Trevelyan MP, 37 emails

    The missing English constituencies

    There are just seven English constituency MPs who have not yet had a single email asking for Uplands for people, for the climate and for wildlife. One of them is easy – it is Chris Packham’s MP, Julian Lewis, who won’t accept email correspondence! The others are: five in London (Edmonton, Erith and Thamesmead, Harrow East, Old Bexley and Sidcup and West Ham) and Redcar.

    The missing Scottish constituencies

    The three Holyrood constituencies from which emails have not been sent to their MSPs are: Aidrie and Shotts, Glasgow Provan and Linlithgow. It you live in any of those constituencies, or have a friend you can nudge, we’d be pleased to see the full set achieved as soon as possible – thanks!

    From now we will bring you occasional updates on progress but if you have signed the e-action and sent a message to your elected representative(s) – thank you! Now please ask your friends to do the same.

    If you haven’t yet participated then please have a look at https://wildjustice.eaction.org.uk/saveourskydancers2021/ and see whether you can take part. Many thanks!

  108. Some recent messages

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    Someone sent us a Postal Order – haven’t seen one for years. Thank you – it made us feel quite nostalgic.

    Our beautiful birds of prey deserve all the help they can get

    Having just watched Hen Harrier Day, we were compelled to send you this to help with the fight. Thank you for all the information, imparted so well. We understood parts of the story, but weren’t aware of the whole picture. Now we are.

    A big thank you and a small contribution. HHDay broadcast was excellent, we were riveted. So much info and so much relevance to our climate emergency.

    Thanks for the Hen Harrier 21 morning. The size of the problems facing the uplands & moors is daunting but we mustn’t give up as you so comprehensively showed us.

    To watch the Wild Justice Hen Harrier Day broadcast – click here for the running order and a link to the video.

    To sign our e-action asking your elected parliamentarian to enable Uplands for people, for the climate and for wildlife (over 12,000 emails sent so far) – click here

    To sign up to our free newsletter – click here

    To donate to Wild Justice’s work by bank transfer, PayPal or a cheque in the post – click here

  109. Update on e-action – Uplands for people, for the climate and for wildlife

    Comments Off on Update on e-action – Uplands for people, for the climate and for wildlife

    Our e-action, Uplands for people, for the climate and for wildlife was launched on Saturday.

    The headline number

    According to our records over 8000 emails have been sent to elected parliamentarians across the UK since Saturday morning – asking for them to deliver Uplands for people, for the climate and for wildlife. Thank you! (The counter on our webpage says just over 7000 but we think that there is a slight glitch there which we will try to fix).

    A national breakdown

    Wales 38 of 60 MSs have been contacted (63%)

    Northern Ireland 50 of 90 MLAs have been contacted (55%)

    Scotland 120 of 129 MSPs have been contacted (93%)

    England 513 of 533 MPs have been contacted (96%)

    The top-ranking English constituences

    The top-10 English constituencies in responding to our e-action are all, or are immediately adjacent to, upland areas:

    Derbyshire Dales, Sarah Dines MP, 45 emails

    Skipton and Ripon, Julian Smith MP, 44 emails

    Sheffield Hallam, Olivia Blake MP, 42 emails

    High Peak, Robert Largan MP, 41 emails

    Hexham, Guy Opperman MP, 36 emails

    Westmorland and Lonsdale, Tim Farron MP, 31 emails

    Berwick upon Tweed, Ann-Marie Trevelyan MP, 31 emails

    Sheffield Central, Paul Blomfield MP, 28 emails

    Calder Valley, Craig Whittaker MP, 28 emails

    Richmond, Rishi Sunak MP, 26 emails

    The missing English constituencies

    There are 20 English MPs who have not yet had a single email asking for Uplands for people, for the climate and for wildlife and we think we know who 18 of them are (the process of locating them is trickier than you’d think!). One is easy – it is Chris Packham’s MP, Julian Lewis MP, who won’t accept email correspondence! Please tell us if you have written to him on this subject. Of the rest, 8 are London constituencies (mostly north of the river), 3 are West Midland constituencies, 2 are Liverpool constituencies, and then there are Redcar, Ashton-under-Lyne, Wigan and Gillingham and Rainham and the 2 that we haven’t spotted yet). These are mostly inner-city built up constituencies at some distance from any upland areas and so that makes some sense. But we’re sure they’ll all respond eventually.

    We will bring you regular updates on progress but if you have signed the e-action and sent a message to your elected representative(s) – thank you! Now please ask your friends to do the same.

    If you haven’t yet participated then please have a look at https://wildjustice.eaction.org.uk/saveourskydancers2021/ and see whether you can take part. Many thanks!

  110. Our e-action – uplands for people, the climate and wildlife

    Comments Off on Our e-action – uplands for people, the climate and wildlife

    We’re asking you, please, to send this message to all politicians elected in each of the four UK parliaments. Just pop your postcode and details in here and your message will be sent automatically to the right person (or persons) – click here.

    I am writing to you to ask you to speak up for our uplands. 

    In the face of a nature and climate emergency, we need uplands that work for people, for the climate and for wildlife.

    Ahead of this autumn’s international meetings on climate and biodiversity, I would like to ask you to make a new commitment to the precious upland landscapes of Britain. 

    As the person who speaks for me in parliament, can I ask you to stand up for uplands that work for:

    People:  We need a better deal for residents, workers, landowners, visitors and taxpayers. Our hills should provide benefits for all. We need to see more sustainable economic activity, reduced flood risk and responsible land ownership. They should benefit our health and wellbeing, as beautiful places to relax and enjoy the scenery and wildlife.  

    Climate: We need you to help uplands reach their potential as huge, natural carbon stores; they are key to helping us tackle climate change in a sustainable way. The return of natural woodlands and bogs in prime condition will deliver that vision and bring wildlife back. The uplands are our largest carbon bank – let’s invest in them.

    Wildlife: We need to reverse decades of de-wilding and put the wildlife back into the uplands. We need to diversify landscapes, restore a mix of habitats and shift away from over-burning, over-draining and overgrazing.

    At the heart of this, we must see an end to the persecution of our raptors. The brutal killing of Hen Harriers must stop. The killing of Golden Eagles, Peregrines, Buzzards and Goshawks must stop. Our uplands are not uplands without raptors thriving alongside a wealth of wildlife in a functioning ecosystem. 

    The absence of Hen Harriers from so many of our upland landscapes, including many of our National Parks, symbolises how wrong the current situation is. Protected wildlife is being removed by criminals engaged in unsustainable land management. We cannot be proud of the uplands whilst wildlife crime is rife. 

    I am asking you as my political representative to commit to this new vision for the uplands of Britain: for people, for the climate and for wildlife.

    Thank you! Now please spread the word and ask your friends to sign too. Here’s the link again – click here.

  111. If you missed our Hen Harrier Day broadcast…

    Comments Off on If you missed our Hen Harrier Day broadcast…

    To help you through the 2.5 hours…

    • 6mins: the countdown of 10 issues begins – Lucy Lapwing talks to Josh Styles about bogs
    • 13:43: Chris talks to Kate Hanley of the RSPB at Dovestones about trees and habitat management
    • 19 mins: Mark launches e-action – click here to see if you’d like to sign it please
    • 27 mins: Jamey Redway’s artwork – a stunning male Hen Harrier – you can buy the original
    • 29 mins: Guy Shrubsole of Rewilding Britain on land ownership
    • 37:20: Chris and Megan talk to Max Wisniewski from Revive Coalition about their approach
    • 43:30: Richard Lindsay on peatlands and burning
    • 53 mins: Chris talks to Bob Berzins from Sheffield about being nice
    • 1hr 3mins: Martin Simpson’s wonderful song, Sky Dancers
    • 1hr 10 mins: Julia Newth from WWT on lead ammunition
    • 1hr 17mins: Darren Rees’s painting of a male Hen Harrier in the New Forest – you can buy the original
    • 1hr 19min 50sec: Chris talks to Alex Lees about upland biodiversity
    • 1hr 27min 45secs: Darren Woodhead talks about Hen Harriers and drawing them
    • 1hr 33min 50secs: Mark talks to Olivia Blake MP talks about licensing of grouse shooting, which is the Labour Party’s proposal for the future
    • 1hr 38min 40secs: Gus Routledge from SCOTLAND: the Big Picture talks about their work
    • 1hr 48mins: Jim Moir (Vic Reeves) talks about his painting of a Hen Harrier food pass – you can buy the original
    • 1hr 50mins: a compilation of Matt Hagen from N. Yorks Police, Jenny Shelton from RSPB Investigations and Steve Downing from North of England Raptor Forum with their views about raptor persecution
    • 2hr 5mins: Ruth talks to Duncan Orr-Ewing and Ian Thomson from RSPB Scotland and Dave Anderson about the tale of a young Golden Eagle
    • 2hr 19min: a recap of the words of our e-action spoken by Lucy Lapwing, Lizzie Daly, Ajay Tegala, Hannah Stitfall, Jamey Redway, Gus Routledge, Mya Bambrick, Joshua Styles, Kabir Kaul, Indy Kiemel Greene, Arjun Dutta, Dara McAnulty
    • for the next few weeks – please sign our e-action – click here.

  112. Yet another ‘report’ coming from, presumably, the grouse shooting industry

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    ‘New reports’ come along every year at this time from the grouse shooting industry. In 2016 Ian Botham was using a BTO report to bolster his claim that grouse moors are fantastically rich in birds (but there was no such report). Then in 2017 there was another report, also promoted by Ian Botham, and that study has never seen the light of day either – despite one of us (in the days before Wild Justice) having asked to see the paper when it is published. Last year there was a study that apparently showed that shooting birds makes you happy – but we’ve never seen that report either.

    Today we’ve been asked, by a newspaper, to comment on the findings of ‘a report’ that we aren’t allowed to see, with an authorship we aren’t allowed to know and a title we aren’t allowed to be given.

    Our response was:

    Our answers to your questions are:

    • your first question is so unspecific that we can’t really answer it
    • yes we recognise that grouse shooting brings some economic benefits but these are wiped out by the costs it imposes through increased flooding, damage to protected habitats, water treatment costs, greenhouse gas emissions and, of course, the illegal persecution of protected wildlife especially birds of prey.

    (Hint, it wasn’t a journalist from The Guardian).

  113. Natural England’s controversial biodiversity metric

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    You may have seen that there is controversy over what might appear to be a dull technical document issued recently by Natural England (see this story in The Guardian from 21 July). The document is about the idea, an attractive idea, of net gain for wildlife to be achieved through the planning sytem (in England). If you get permission to build say, a supermarket, on a greenfield site, then how can the loss of wildlife value be measured and compensated?

    There is some confusion, as usual. over what DEFRA and Natural England are doing, and the implications could be serious, so Wild Justice is keeping an eye on things, along with lots of other concerned parties.

    We have written to DEFRA and Natural England today to see whether they will tell us what they think they are doing, and how it fits in with the legal requirements.

    Our letter to DEFRA is below and the letter which has gone to Natural England covers the same ground.

    The Wild Justice Hen Harrier Day broadcast will occur on Saturday 7 August – click here to register your interest and to receive updates ahead of the event.

  114. BASC or the Climate Change Committee – who would you believe?

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    ‘… burning of vegetation on blanket bog is damaging to peatland formation and habitat condition. It makes it more difficult or impossible to restore these habitats to their natural state and to restore their hydrology.‘ DEFRA https://www.gov.uk/government/news/englands-national-rainforests-to-be-protected-by-new-rules Photo: Sarah Hanson

    Wild Justice issued papers last week challenging DEFRA’s feeble new Burning Regulations.

    Predictably, BASC, a pro-shooting organisation which is always jumping up and down shouting about something or other, is desperate to get involved too. BASC is hoping to be recognised by the court as an interested party in the case. We’ll see. Will we see a range of other shooting organisations jostling for some publicity too?

    BASC’s intervention in Wild Justice’s challenge of the Welsh general licences was very helpful to our case and resulted in Justice Jarman contrasting the agreement on the legal position between Wild Justice and Natural Resources Wales with the different position of BASC. BASC couldn’t have beeen more helpful in getting that judgment and the precedent it sets in law, had they been trying. We’re not sure that BASC, and their members, actually realise that yet…

    Our challenge of DEFRA’s burning regulations is based on their inability to deal well enough with the damage caused by vegetation burning on upland peatlands, largely on grouse moors, to protected blanket bog habitat and to greenhouse gas emissions. The regulations are very badly framed.

    Wild Justice says:

    There’s a climate crisis and a biodiversity crisis, and this type of burning adds to both.  Instead of acting decisively, DEFRA is fiddling while the uplands burn.

    … and DEFRA says…

    There is a consensus that burning of vegetation on blanket bog is damaging to peatland formation and habitat condition. It makes it more difficult or impossible to restore these habitats to their natural state and to restore their hydrology.

    Restoring England’s peatlands is a priority for the government. It will help achieve net zero carbon emissions by 2050 as well as protecting our valuable habitats, and the biodiversity those habitats support.

    https://www.gov.uk/government/news/englands-national-rainforests-to-be-protected-by-new-rules

    …although their action to back that up is inadequate. However, BASC quips;

    As a conservation organisation we believe Wild Justice’s challenge will directly impact on the sustainable management of land in the uplands.

    https://basc.org.uk/basc-to-challenge-wild-justice-action-2/

    That’s very witty! BASC’s a conservation organisation, is it? And yes, we hope that our legal challenge will affect the sustainable management of the uplands, that’s why we are taking it with great support from real conservation organisations. BASC, not really being an environmental organisation, may have missed the report to Parliament of the Climate Change Committee which recently said;

    Introduce legislation to … [e]xtend the ban on rotational burning of peat
    from certain protected upland bog sites to all peatland before the start of
    the burn season in 2021.

    https://www.theccc.org.uk/wp-content/uploads/2021/06/Progress-in-reducing-emissions-2021-Report-to-Parliament.pdf

    That’s pretty clear isn’t it? And urgent, too!

    BASC, and maybe the rest of the shooting industry, are way out on a limb with this. The narrow interests of shooting are distanced from DEFRA, and DEFRA is lagging behind what the environment and conservation movement believes is needed. Wild Justice is happy to be walking in step with the Committee on Climate Change on this issue. Compare the credentials of the Climate Change Committee with those of BASC – well, who would you believe?

    The Wild Justice Hen Harrier Day broadcast will occur on Saturday 7 August – click here to register your interest and to receive updates ahead of the event.

  115. Press release from Leigh Day and Wild Justice

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    Photo: Sarah Hanson

    Wild Justice issues legal challenge to new rules on burning of peatlands  

    A legal challenge to new rules governing the burning of heather and grass on peatlands in England has been issued, claiming they are unlawful and unenforceable.  

    Environmental group Wild Justice, represented by law firm Leigh Day, has applied for a judicial review of The Heather and Grass etc Burning (England) Regulations 2021, arguing that they are not only unenforceable, but create a façade of effectiveness, preventing urgent and far-reaching legislation addressing climate change and biodiversity loss from being introduced.  

    Wild Justice, led by Chris Packham CBE, Dr Ruth Tingay and Dr Mark Avery, say the Regulations introduced in May this year need to be much stricter to ensure they can be enforced effectively. The Regulations were introduced after previous voluntary measures aimed at halting the burning of blanket bogs failed. The Government has a responsibility to protect blanket bog under the Conservation and Species Regulations 2017, which require the restoration of the habitat to “favourable conservation status”.  

    The Burning Regulations 2021 are fatally flawed in two ways. They only prohibit the burning of heather, rough grass, bracken and gorse on peat deeper than 40cms – but there is no map to identify where such peat exists and therefore no means of properly enforcing the new rules. The new Regulations also only prevent the burning on Sites of Special Scientific Interest (SSSI) that are also designated as Special Areas of Conservation and Special Protection Areas, which amounts to a ban on only 40 per cent of all blanket bog in England.  

    The UK’s peat habitats are wetland landscapes where it is estimated there are over three billion tonnes of carbon stored. They have a unique biodiversity recognised as habitats of national and international significance. The UK’s upland blanket bogs are a globally rare habitat.  

    However, vegetation on upland peat soils is set alight at regular intervals, to promote the growth of young heather shoots to feed Red Grouse for the shooting industry. The practice damages the habitat, reduces peat accumulation, and releases around 260,000 tonnes of CO2 every year. 

    On 24 June 2021, the Climate Change Committee’s latest progress reports were laid before Parliament. The Report criticised the Burning Regulations for only preventing rotational burning on protected peatlands, highlighting that a partial ban was less ambitious than it had recommended. The Report includes a priority recommendation that this be “addressed quickly as delayed action now puts future targets at risk given the time profile of carbon sequestration” and that the Government: “Introduce legislation to … [e]xtend the ban on rotational burning of peat from certain protected upland bog sites to all peatland before the start of the burn season in 2021.”   Wild Justice’s grounds for claim are:  

    • Unlawfulness arising from the Burning Regulations frustrating their own purpose: The Regulations do not include a map, without which they are unenforceable. The failure to publish or refer to a map is unlawful;
    • Demonstrable flaw in the reasoning or serious logical error in the reasoning leading to the making of the Burning Regulations: there is no rationale for limiting the location of areas affected by the Regulations;
    • Breaches of the Conservation of Habitats and Species Regulations 2017: failure to take appropriate steps to avoid deterioration of natural habitats and disturbance of species;
    • Failure to take into account a material consideration, namely the imperative for early and swift action under the Climate Change Act 2008 (“CCA”) and the Paris Agreement.

    Wild Justice said: ‘There’s a climate crisis and a biodiversity crisis, and this type of burning adds to both.  Instead of acting decisively, DEFRA is fiddling while the uplands burn.‘.

    Leigh Day solicitor Carol Day said:   “Our client strongly supports effective action by the Secretary of State to protect peatland, including through enforceable legislation regulating the burning of blanket bogs, given their crucial importance as a habitat and in sequestering carbon. But in falling so far short of what is needed, these Regulations create a façade of effectiveness preventing real progress from being made. Wild Justice hopes that bringing this challenge, along with the call from the Climate Change Committee for urgent action, will prompt the Government to plug the gaps in these Regulations.”  

    Not exactly natural is it? Photo: Duncan Andison/Shutterstock

    ENDS

    Wild Justice depends on donations to carry out our campaigning and legal work (and to pay our running costs). If you like what we do then please consider making a donation through PayPal, bank transfer or a cheque in the post – see details here

  116. Shooting Times and the imperfect 8

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    See four previous blogs to catch up on this story: 28 May, Alleged breach of general licences; 2 July, The Shooting Times and the general licences; 2 July, A letter to the Shooting Times; 4 July, What that Shooting Times article might have said.

    This week’s Shooting Times published this lame and inadequate correction;

    It made us laugh that Mark was described as a ‘regular reader’ – regular as in ‘once in a blue moon’!

    But this correction is inadequate, and we have written to Shooting Times to tell them so, as follows:

    Dear Shooting Times

    Wild Justice notes the correction you have published in this week’s magazine. We were amused to be described as regular readers – we read the Shooting Times about as regularly as England wins penalty shoot-outs.  Don’t kid yourselves!

    Your ‘correction’ is inadequate in that it does not attempt to remedy the damage done by the original false account that you published. As you know, but as you have not informed your readers, the account you published described behaviour that, had it actually occurred, would make anyone behaving in the same way liable to a police investigation concerning a potential breach of the general licences.  You have not corrected that consequence of your publication in any way by your feeble and minimalist correction.

    Whilst we appreciate the good humour in which this exchange of emails has taken place, this is your last chance to remedy the situation. Failing you responding adequately to us by noon on Friday 23 July we will forward this correspondence, which shows we have given you every opportunity to act responsibly, and full details of your breach of the Editors’ Code, to the Independent Press Standards Organisation. 

    yours, very occasional and disappointed readers of the Shooting Times,

    Wild Justice

    We’ll let you know what happens. And, we haven’t heard from DEFRA yet.

  117. Wild Justice’s second year accounts and corporation tax

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    Wild Justice is a not-for-profit company limited by guarantee and so we file our accounts with Companies House and pay corporation tax on our ‘profits’. When setting up Wild Justice we decided to go this route, rather than the ‘full charity’ route, at least to start with. If we decide to do an ‘upgrade’ to a charity then we will be able to claim Gift Aid on donations but we will have more onerous and costly reporting requirements and our freedom to say what we want would be reduced. At the moment we aren’t planning to convert to being a charity but it’s something we discuss quite regularly.

    Our financial year runs from 1 November to 31 October. Our rather unilluminating company accounts for our second financial year (up to 31 October 2020) have recently been posted on the Companies House website and the gist of them is reproduced below;

    We have paid nearly £7,000 in corporation tax as a result.

    Thank you to all our supporters for their generosity of spirit and their donations that support all the work we do.

  118. Thank you!

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    We get some lovely letters and notes and cards and emails. This note was one of many which arrived this week, accompanying a cheque. Thank you to all our supporters.

    Wild Justice depends on donations to carry out our campaigning and legal work (and to pay our running costs). If you like what we do then please consider making a donation through PayPal, bank transfer or a cheque in the post – see details here

  119. Progress on Northern Ireland general licences

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    Woodpigeon. Photo: Tim Melling

    The current Northern Ireland general licences are shockingly bad – as we wrote and told the Northern Ireland authorities back in the spring (click here for details). There are three licences which deal with public health, serious agricultural damage and nature conservation. The Northern Ireland general licence dealing with killing birds for nature conservation purposes lists Wood Pigeon (see above – isn’t it a very beautiful bird?) as a conservation threat! None of the other UK nations agree with that. There are some other howlers, both legal and biological, in the licences too.

    But the Northern Ireland government has decided to issue a consultation on the licences which is open now and closes on the Inglorious 12th August so that comments can be taken on board before new licences are issued when the current ones expire towards the end of September. We’re sure this consultation and its proposed changes would not have occurred without our intervention.

    The proposed changes are fairly modest but we welcome them. They are to remove Herring Gull, Lesser Black-backed Gull, Great Black-backed Gull and Rook entirely from all of the general licences in Northern Ireland – this brings them more in line with those elsewhere in the UK. And also to remove Wood Pigeon from both the public health and conservation licences, and Feral Pigeon from the conservation licence.

    Removing species from the general licences does not mean that they cannot be killed, they can, but only if an individual applies for and is granted an individual licence with strict conditions, limits and reporting procedures. That is a step forward towards eliminating casual killing of species.

    Responding to the consultation is very quick (less than 5 minutes) and is open to all. You may want to respond now which will simply involve filling in a few necessary details about yourself and ticking all the boxes that say you agree with the removal of these species from the relevant licences (if you do agree, we do). We will be giving it a bit more thought because there is a box for ‘other comments’ and we’ll have some! To learn about our further thoughts on this matter, and to get a reminder to respond to the consultation, and also to hear our news across the board, then subscribe to our free newsleter – along with over 50,000 other supporters – click here.

    Wild Justice depends on donations to carry out our campaigning and legal work (and to pay our running costs). If you like what we do then please consider making a donation through PayPal, bank transfer or a cheque in the post – see details here

  120. Thank you Gill!

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    Gill Lewis is a children’s author who has written many books about issues in nature conservation. Her books Sky Dancer and Eagle Warrior are very specifically about illegal killing of raptors, but she has written about bear farms, dolphin strandings and a wide range of other issues as ways of introducing young people of various ages and reading abilities to the natural world.

    Her latest book, Willow Wildthing and the Magic Spell, is about rewilding and it is a great tale of magic and uplifting action for nature. The illustrations by Rebecca Bagley are wonderful too.

    Gill has been a generous supporter, in lots of helpful ways, to Wild Justice over the few years we have been in existence and we’re touched that this book has a dedication to us.

    Thank you Gill, thank you very much!

  121. What that Shooting Times article might have said

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    In the Shooting Times of 10 February there was an article entitled Shooting for a Perfect Ten which purported to be an account of a day’s shooting where the aim was to shoot as many different species as possible in a day. That account is now said to be partly fictional by the article’s author and Wild Justice is waiting for a response from the Shooting Times to our request for a detailed and prominent correction to be published.

    We thought we’d give a more detailed critique of the article, purely in terms of factual corrections.

    The title: not so much the Perfect Ten as the Far From Perfect Eight.

    The caption above: should read ‘The day’s bag comprised fox, rabbit, a crow that I got out of the freezer, red-legged partridge, woodcock, mallard, teal, pheasant, pigeon and a jay that also came out of my freezer, so, only eight species really‘.

    The original passage that read ‘I surprised myself with a very high crow that wheeled overhead 50 yards out. It turned away from us, exposing its vulnerable underside, and folded like a fist to the top barrel. It wouldn’t be troubling the yellow wagtails and corn buntings this spring. three species in the bag before breakfast. Spirits were high.’ should now surely read ‘I got a frozen crow out of the freezer where it wasn’t troubling anything, certainly not yellow wagtails which were in Africa, south of the Sahara, at the time. But it’ll make a nice addition to the row of quarry I hope to assemble for a staged photo..

    The original passage that read ‘It was already 9am and we already had five species in the bag‘ should now read ‘It was already 9am and although we only had four species in the bag I was going to claim a good shot at the crow to bring the total to five species‘.

    The original passage that read ‘I made the naive error of proposing we might be on for 10 before 10‘ may be closer to something like ‘I was trying to remember how many other useful corpses were in the freezer and what I might be able to claim that we shot in the day‘.

    The original passage which read ‘Between us we had eight species in the bag. Ordinarily, I too would have hung up the game bag. However, in more than 30 years of shooting I have never been part of a day which ended with 10 species. These chances don’t come that often and I wanted to see if it could be done.‘ might more accurately be rendered as ‘Between us we had seven species in the bag and a frozen crow. Ordinarily, I too would have hung up the game bag. However, in more than 30 years of shooting I have never been part of a day which ended with 10 species. These chances don’t come that often and I wanted to see if it could be done with maybe one more shot bird and that jay that I think is in the freezer.

    The original passage which read ‘But surely I could manage another two species before the weather proved too much‘ might be closer to the truth if it read ‘But surely I could manage one more species and add in the frozen crow and I’m pretty sure there is a jay in the freezer‘.

    The long triumphant finale to the article reads ‘Darkness was falling without any hint of a sunset. The weather had been unremitting from dawn until dusk. The jackdaws had disappeared and nothing seemed to be moving. A pigeon settled out of range.

    Then from the other side of the wood, a jay screamed out its woodland alarm. I can’t say for certain at what it was aiming its bile but I assumed that it couldn’t be me. A stalk might be on. If I stayed in the wood, I might have the chance to account for it and therefore help the nightingales and turtle doves when they return in spring. I ignored a second pigeon behind me.

    With a stealth I hadn’t mustered since jungle-tracking days I moved as cautiously as frozen limbs would allow, glad that I now had steady Tess instead of headstrong Scout. When we were a little under 100 yards from the edge of the wood, we both stopped and listened intently. The wind had dropped, I could hear the sounds of the estuary in the distance.

    Silhouetted as it rose and fell between two huge chestnuts, the jay didn’t look quite right. I hesitated. Might it have been a woodpecker? Or a blackbird? It settled. Darkness continued to fall. Then it turned and flew back. This time I was sure. It needed only the slightest of lead. Ignore the branches. Squeeze, don’t jerk. Keep moving.

    The jay slumped and toppled with the lightest of landings into the leaf litter. The glorious turquoise flashes and white rump were still visible in the gloom. I had my 10th species. It was just after 3:30pm. Ten species in 10 hours.’

    … shouldn’t all that be ‘I jacked it in and went home. Eight species shot for fun and two taken out of the freezer to make an article for the Shooting Times. The Imperfect Eight!’?

    Our main point though is that two of the species that the author of this piece claimed to have shot, to see if he could get the ‘perfect 10’, are covered by general licences which set out conditions and circumstances under which the licences can be relied upon. When faced with the prospect of a police interview the author repudiated his own published account and said that he had not shot the crow, a Carrion Crow, and the Jay. The original article gave an account of behaviour which may well attract the attention of the police because, if anything like that were ever to happen (we accept that it didn’t in this case and that the article was a false account) it may be illegal. How much of such behaviour, which we would call casual killing, does happen? And what steps should shooting organisations take to stop it? And what steps should a wide variety of shooting magazines take to educate their readers?

  122. A letter to the Shooting Times

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    Dear Shooting Times,

    We write to you to draw to your attention the inaccuracy of an article published in your magazine of 10 February 2021 entitled ‘Shooting for a Perfect Ten‘ where your columnist describes, in detail, a day’s shooting, whose aim was to kill as many different species as possible, which includes an account of bringing down a Carrion Crow and then stalking a Jay. 

    Your columnist wrote that he ‘surprised himself’ with a ‘very high crow’ which ‘folded like a fist’ when a barrel was emptied into it, and that it ‘wouldn’t be troubling the yellow wagtails or corn buntings this spring’.

    Your columnist writes nearly 200 words on stalking the Jay at the end of the day, bringing it down with a single shot and how its glorious turquoise flashes and white rump were still visible in the gloom. He seemed to think that he was helping Nightingales and Turtle Doves by doing this.

    Essex Police investigated this case after we reported it to DEFRA as a potential breach of the general licences. DEFRA asked Wild Justice to forward to Essex Police the legal and biological dossiers we had sent to DEFRA.

    Essex Police inform us that ‘With regards to the Carrion Crow and Jay he [ie your columnist] has stated that, he did not shoot these birds on this day and has a number of frozen/prop birds that he uses in his articles, if he needs to and bases the events on previous incidents or other incidents which have similarities.‘.

    So all that stuff about a very high crow was actually a very frozen crow and the lyrical account of the killing of the Jay was also, we must assume, false. If those elements of the fictional account published by you had been true then your columnist might have faced criminal action.

    We are writing to you, now that the police investigation has concluded, to point out to you that by publishing a false and inaccurate story, the Shooting Times has broken the Independent Press Standards Organisation’s Editors’ Code of Practice to which we see you are signed up. You have, in our opinion broken, Clause 1(i) which refers to publishing inaccurate, misleading or distorted information since you have published an account which the author now says was untrue.

    In any case, we believe that the original article could encourage others to take similar action and for them to believe that such action would be lawful when we believe that it would not be.

    We ask that you publish a full and detailed retraction of the original article and make clear that had it actually been true, such behaviour might open up the shooter to criminal prosecution and that the Shooting Times would never condone firearms users breaking the law. We ask that you send us the retraction that you propose to publish for our review and approval.

    We look forward to your response. We have not made a complaint to IPSO as we wish to give you the opportunity to make amends for your publication voluntarily, but we remain cognisant of the possibility of referring this to IPSO for adjudication.

  123. The Shooting Times and the general licences

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    Some time ago we told our newsletter subscribers, and wrote a blog (see here), about an article in the Shooting Times where a regular columnist of theirs wrote an account of going out to shoot 10 species in a day, actually on the 30 January this year, which was published in the Shooting Times on 10 February.

    We regarded the behaviour described as a potential breach of the terms of the current general licences in operation in England, and in particular the need, articulated by Justice Jarman, that there is a present danger that the killing is seeking to avert. Wild Justice compiled a legal dossier and sent it to DEFRA along with a biological document which pointed out that Yellow Wagtails and Nightingales are not present in the UK in January and so were not suffering any present danger at all.

    We reported this matter to DEFRA, as the Secretary of State has the power to act on such matters. We are still waiting for the result of DEFRA’s cogitations.

    Wild Justice suggested to DEFRA that they might want to forward our dossier to the police but DEFRA requested that we did so, and we did.

    The police took the case extremely seriously and we are grateful to them for that. The Essex Police have now informed us that they cannot take the case any further as the Shooting Times columnist denies having shot either a Jay or a Carrion Crow despite having described the shots that led to the deaths of these two birds in some detail in his published article.

    The Essex Police tell us that ‘With regards to the Carrion Crow and Jay he has stated that, he did not shoot these birds on this day and has a number of frozen/prop birds that he uses in his articles, if he needs to and bases the events on previous incidents or other incidents which have similarities.‘.

    So, assuming, as we will, that this statement is true, the article was not true.  If it had been true then perhaps the court would have been asked to rule on the legality of the action – an action that we would state is unlawful (but since it did not happen in this particular case that is the end of this matter).

    We intend to ask DEFRA for their view on these matters in general, in case such circumstances arise in future. We have also written to the Shooting Times (see here).

  124. Wilful blindness over grouse shooting

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    The Wild Justice petition, signed by many readers of this blog and many, many others across the UK, including in grouse shooting areas (see map below) had a debate in Westminster Hall yesterday. Labour MPs were woefully thin on the ground and LibDems totally absent. The SNP spoke and made some good points about how they do things differently in Scotland and the Labour Shadow Minister, Olivia Blake, was good. Here is a link to the transcript – isn’t it amazing how quickly these appear?

    https://petitionmap.unboxedconsulting.com/?petition=266770

    But Conservatives lined up to demonstrate that wilful blindness is the name of the game. We will come back in more detail to what individual MPs said over the next days and weeks, if your MP spoke then maybe you’d like to drop them a line and we will publish our thoughts here in case they help you.

    So this is just a series of headline points for now, but we’ll be back with more detail soon.

    Conservative MPs are wilfully blind on economics – many said how important grouse shooting is to local economies but took no account of the impacts of flooding, water treatment or greenhouse gases on the wider economy. Tom Hunt MP (Ipswich) said that he ‘did not come across any evidence that said that an alternative use would promote better natural capital than the unique environment that we are dealing with here‘ which must mean that he hasn’t read the book of the former Chair of the Natural Capital Committee, a highly respected academic economist, Prof Dieter Helm, where he writes (amongst other things – see here) that ‘Responsibility for the consequences of grouse moor management lies with the owners. They are the ‘polluters’ imposing costs on the rest of us, and they should pay. A more prosperous uplands would start with the licensing of game shoots and then a levy to put right the damage.’.

    Conservative MPs are wilfully blind on raptor persecution – many MPs spoke about the skies being darkened by vast flocks of raptors as they visited the moors with friendly gamekeepers. Kevin Hollinrake (Thirsk and Malton) and Robert Goodwill (Scarborough and Whitby) both hail from the North York Moors which is a bit thin on nesting Hen Harriers, whatever the Moorland Association’s local representative’s gamekeepers say. Indeed the study using Natural England data, by Murgatroyd et al. (published since the last debate in 2016, and providing the clinching science that shows the scale of persecution on driven grouse moors – see here) shows that the North York Moors NP is the most dangerous place for Hen Harriers to go of all English upland, so-called protected, areas. If you are a Hen Harrier, your risk/day of death or sudden disappearance is higher in the North York Mors National Park than anywhere else. Maybe Mr Hollinrake and Mr Goodwill could ask their constituent gamekeepers why that would be the case? Mr Hollinrake could clearly start with the estates he named: Snilesworth, Bransdale and Spaunton. But wilful blindness is the name of the game. Only Olivia Blake mentioned the Murgatroyd et al. study which is a damning indictment of the impact of a hobby, driven grouse shooting, on wildlife crime figures in upland England.

    Conservative MPs are wildfilly blind on climate change impacts – Olivia Blake was right to point out (‘I must say that a number of colleagues who have spoken today seem to be a bit behind their own Government on this issue, as the Government have introduced a ban, although it has limitations that I will come on to later‘) that the Conservative MPs who spoke in the debate were out of step with their own government which has introduced restrictions on burning of upland vegetation (weak restrictions – subscribers to the Wild Justice free newsletter will know that we are considering a legal challenge to those feeble restrictions) on burning of upland vegetation. And she was right to mention that the Climate Change Committee regard more sustainable upland management, on driven grouse moors included, as a big issue.

    Conservative MPs are wildfully blind to the need for government to act – if you admit that there is a problem, then as a decision-maker you should act. That may be why so many Conservatives, including DEFRA itself, has to paint a picture that everything is rosy, economically rich, environmentally rich, socially rich in the uplands and on grouse moors in particular. If they removed the blinkers then they’d have to act, and that would really irk the grouse moor owners and managers who expect the Conservative Party to speak for them. It was good that the SNP, in the form of Dave Doogan (Angus) pointed out that things are different in Scotland when he said ‘...it includes the ambition for grouse moor management. By contrast, the dead slow and stop approach by the Department for Environment, Food and Rural Affairs to the challenge is unacceptable and does not benefit anybody on either side of this challenging debate‘ and ‘…the Scottish Government will look at implementing a licensing regime for grouse shooting, providing a framework to the sector that will assist it in combating illegal persecution of raptors and related wildlife crimes. Grass [I think that is meant to be grouse] moor estates found to be non-compliant—those that practise the types of behaviours that nobody wants to see—would face the prospect of not having a licence, whereas those that uphold the very best practices would be endorsed and licensed as undertaking a legal and productive activity. Those changes are designed to apply an achievable balance‘. In other words, facing the same issues and problems, and the same economics and social issues, Scotland is acting whereas England is staring out into space saying ‘Problem? I can’t see a problem’. That is wilful blindness.

    Wild Justice thanks everyone, over 111,000 of you, who signed this petition and got this debate, much-delayed, into parliament. Things have moved on since the 2016 debate – at least they have in the SNP and Labour Parties, both of whom now favour licensing. Only some of the faces have changed on the Conservative side, there is no more acceptance of a problem now than there was five years ago. But the world is moving on and will leave the wilfully blind behind.

    There’s nothing heroic or Nelsonian about ignoring the facts.

    KFFYJ6 Nelson holding a telescope to his blind eye, ignoring the order to retreat, Battle of Copenhagen, 1801. Image shot 1880. Exact date unknown. Alamy.

    Wild Justice also thanks the Petitions Committee staff with shom we have dealt on this and other petitions for their hard work.

  125. 200,000 signatures to save wildlife!

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    https://e-activist.com/page/75310/petition/1?ea.tracking.id=Wild%20Justice

    Early this morning the joint NGO #stateofnature petition passed 200,000 signatures. Wild Justice supporters played a large part in helping to reach this milestone. Thank you.

    The petition will be handed in to government some time next week and a major amendment to strengthen protection for wildlife will be discussed in the House of Lords later today.

    This is not the time to ease off – this is the time to search your address book for those friends who might well sign this petition to increase the pressure on DEFRA and Boris Johnson to do a good job for wildlife. We want a legally binding target to end wildlife declines in the Environment Bill. What DEFRA promised in May was a world-leading target, what they now bring forward in June is feeble.

    Please sign the #stateofnature petition to show that you want this government to act now to save wildlife – click here please.

  126. Badger challenge – we lost this one

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    Badger. Photo: Chris Packham

    We heard on Friday that we had lost our challenge of the legality of free shooting of Badgers. It is legal for Natural England to license shooting of badgers which does not meet the welfare recommendations of the expert committee which set out what the standards should be. Government and Natural England do not have their own criteria on the dividing line betweem cruel and not cruel and haven’t used those proposed by experts.

    We’re sorry that we didn’t win this one but we are glad that we tried. We thank our legal colleagues at Leigh Day and Matrix Law for all the time and expertise they have put in to this complex case. The moral position is clear, the legal position is very complex. We also thank many experts who know a lot more about issues such as the pain suffered when a bullet passes through a living being than we do. And also we thank our supporters for funding this challenge.

    Here is the Court Order.

    For updates on Wild Justice’s work, subscribe to our free newsletter – click here.

  127. Wild Justice questions the quality of NE’s IUCN Assessment for their lowland Hen Harrier reintroduction project

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    Yesterday Wild Justice sent the following letter to Natural England questioning the quality of their assessment of the feasibility of a reintroduction of Hen Harriers to southern England.

    We recognise that reintroduction projects can be controversial. That makes it all the more important that the analysis which may seek to justify them is of high quality. It is also essential that a regulatory body applies high standards to its own projects when they are of a similar nature to others which may need licensing. There should be no possibility that double standards apply or might be suspected to apply to a statutory body’s own projects and those of others.

    Wild Justice does not think that the Assessment carried out by Natural England is of high enough quality to form a safe basis for a reintroduction project. We are happy to concede that a proper assessment, carried out well and referring to all relevant data might (or might not) show that the proposed project might (but also might not) meet the criteria set out in the IUCN Guidelines.

    The easiest way to resolve this matter is set out in paragraph 36 below and would require NE not to go ahead with any releases in 2021 and to undertake a high quality assessment with the input of independent experts before going ahead.

    We await NE’s response before considering whether to take this matter further.

    Wild Justice is a not-for-profit company which carries out legal challenges on behalf of wildlife, and campaigns for changes to laws and policies that will favour wildlife. To subscribe to our free newsletter – click here.

  128. Ban driven grouse shooting debate rescheduled for 21st June 2021

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    After many false starts and long delays due to Covid19, the Westminster Hall debate on banning driven grouse shooting, triggered by our successful 2019 petition, has been rescheduled to take place on 21st June 2021 at 4.30pm.

    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 June 2021!

    It’s unlikely that spectators will be allowed in to watch the debate live at Westminster Hall but you can follow it live on the UK Parliament’s YouTube channel.

  129. Alleged breach of General Licences (updated)

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    Note: this blog was originally posted on 28 May, and was temporarily removed after a few days. It is now republished in its original form. There are important developments in this issue which we publish here and here and which should be read alongside this blog post.

    For a small number of species the authorities issue General Licences rather than making individuals make applications on a case by case basis. The General Licences are published on websites and list the species which can be killed and the circumstances and purposes under which killing is lawful. Under these licences, millions of birds are killed in the UK (mostly Wood Pigeons, and various crow species) without any real oversight or monitoring. Wild Justice calls this ‘casual killing’ and we have acted to tighten up the system – with some success. We are not wholly against any control of bird species but we believe that the current system amounts to casual licensing of casual killing of far too many protected birds.

    Wild Justice has been involved in legal action against the General Licences (there are different versions of the licences in each of the four UK nations) since we sprang into existence in February 2019. We have shone a light on the conditions that apply to these licences, the species that can be killed under them and the circumstances under which they are valid (see these 11 blogs: The Wild Justice legal challenge to the general licences GL04, GL05 and GL06, 10 May 2019, Mr Gove please stop the casual killing of Jays, 12 May 2019, Wild Justice response to consultation on general licences, 13 May 2019, NRW your general licences are unlawful, 4 February 2020, Our latest legal challenge – general licences in Wales, 18 March 2020, The strange case of NRW and the missing eggs, 22 March 2020, Why is NRW allowing casual killing of Jackdaws? 28 March 2020, Permission granted for judicial review of Welsh general licences – we’re going to court, 3 August 2020, General licences in England – Wild Justice legal challenges bring about significant reform, 9 November 2020, General licences in general and our challenge to the NRW general licences in particular, 20th December 2020, Further success on general licences – this time in Wales, 18 January 2021.

    The legal judgment referred to in the last of those blogs, by Justice Jarman, made it clear that the legality of the general licences was dependent on there being a present danger and that the licences should not be relied upon at times of year or in locations where there was no threat to the interest being allegedly protected.

    Imagine our surprise then, when we opened the 10 February 2021 edition of Shooting Times and read an article written by a General Licence user in Essex who described setting out to shoot, and then succeeding in shooting, ten different species in ten hours just ‘to see if it could be done’.

    As three of the thirteen animals that he described shooting that day were covered by the new General Licences GL40 (Carrion Crow and Jay) and GL42 (Wood Pigeon) and thus subject to certain licence conditions that prevent what we would describe as ‘casual killing’, e.g. killing them just ‘to see if it could be done’ within a particular time limit, on the evidence available it is our view that this licence-user breached the terms of General Licences GL40 and GL42.

    These alleged breaches were published in an article in Shooting Times, without any editorial comment about the activities described, and thus could be perceived by its readers as activity within the scope of the General Licences that may be replicated elsewhere in England. We put it to the regulator, DEFRA, that this activity amounted to alleged breaches of the General Licences and we asked DEFRA to investigate and consider imposing enforcement action.

    According to the terms of General Licences GL40 and GL42, failing to comply with the terms of the licence may result in the following consequences:

    If you do not comply with this licence’s terms and conditions you may face serious consequences.

    Failing to comply with the licence may:

    • mean you commit a criminal offence under the 1981 Act – the maximum penalty available for such an offence is, at the time of issue of this licence, an unlimited fine and a 6 month custodial sentence

    • result in your permission to use this licence being withdrawn – the Secretary of State will notify you in writing if your permission to use this licence is withdrawn and the Secretary of State may impose a similar sanction in relation to other similar licences.

    https://www.gov.uk/government/publications/wild-birds-licence-to-kill-or-take-for-conservation-purposes-gl40/gl40-general-licence-to-kill-or-take-certain-species-of-wild-birds-to-conserve-endangered-wild-birds-or-flora-and-fauna and https://www.gov.uk/government/publications/wild-birds-licence-to-kill-or-take-to-prevent-serious-damage-gl42/gl42-general-licence-to-kill-or-take-certain-species-of-wild-birds-to-prevent-serious-damage

    The shooting described in the article took place on 30 January 2021, and was published in the Shooting Times of 10 February 2021. We wrote to DEFRA on 26 March drawing this matter to the Secretary of State’s attention with a letter setting out our thoughts on the legal matters and an ecological statement which set out matters such as the fact that there was no present danger to species such as Nightingale and Yellow Wagtail on the date in question as both species were then in their African wintering grounds. DEFRA told us they would look into this matter but then on 26 April said they would not be providing any further updates, to which Wild Justice replied saying that we believe this is a matter of public interest on which the Secretary of State should act and that we would be bringing this matter to the public’s attention. This is us bringing it to your attention. We still await action from DEFRA on this matter.

  130. What you think about lead in game meat

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    In yesterday’s Wild Justice newsletter we asked our over 40,000 subscribers (you can subscribe for free here https://wildjustice.org.uk/contact/ ) six simple questions about the results that we had published revealing the lead levels in game meat sold by Sainsbury’s. There had been 2773 responses in 24 hours and the results hadn’t changed much at all in 23.5 hours so we called it a day.

    We’d like to thank the staff of pro-shooting organisations who attempted to get a surge of ‘Lead is fine, Sainsbury’s are great‘ responses to the survey but you made very little difference to the results.

    Today we have published another blog, about lead in Waitrose’s game meat – there is too much, in our opinion, but we note that Waitrose is in a much better position than Sainsbury’s.

    Here are the results from what you told us:

    Q1 Did you learn something from reading about this study?

    92% Yes

    That’s good – we hoped you would!

    Q2 Were you surprised at the high levels of lead in game meat on sale at Sainsbury’s?

    62% Yes

    Q3 Has your opinion of Sainsbury’s changed after reading about lead in the game meat they sell?

    Down, 66%; No change, 30%

    This ought to be uncomfortable reading for Sainsbury’s – at least 17,000 people have already read our newsletter and the actual total will grow over today and subsequent days and awareness will have swelled through spreading of the blog through social media and the report in today’s Times (p13). We think that this result is partly because Sainsbury’s sells high-lead game meat without health warnings but also because Sainsbury’s have not answered reasonable questions from their customers on the subject. That’s our guess at why you think this way about Sainsbury’s.

    Q4 Which of these actions would you most like government to take?

    Ban Pb ammunition, 60%; Apply same ML as for non-game meat, 24%; Mandatory health warnings, 9%

    Most of you think that government should ban lead ammunition (and so do we) and your view is, we guess, influenced by the fact that lead ammunition has environmental impacts as well as health impacts. Very few people (6%, many of them clearly shooters from their comments) think that it is OK for government to do nothing. Will DEFRA stop dragging its feet on this issue?

    Q5 Which of these actions would you most like supermarkets and other game sellers to take?

    Ensure supplies are lead-free, 76%; Prominent health warnings, 17%

    Most outlets which sell game meat, including Sainsbury’s, are in the small green sector which most people do not favour (those who do include quite a lot of shooters). To the best of our knowledge, only Waitrose occupies both the blue (they are moving in this direction) and yellow segments (they do this already) of this pie chart – that shows approval of Waitrose’s position and should be a signal to other retailers that they should catch up.

    Q6 What action do you think should be taken by those who shoot game for the human food chain?

    Supply lead-free game meat, 92%

    Overwhelmingly, you think shooters should only supply lead-free meat to go into the human food chain. We agree.

    Government received the report of the Lead Ammunition Group in 2015 which recommended the phasing out of lead ammunition – that came from an expert committee which spent five years reviewing the health and environmental evidence, and also noted that hunters in other countries had already switched to non-toxic shot. After sitting on the report (or operhaps carefully reading it over and over again) for a year DEFRA rejected the report in 2016. If they had acted then, the shocking findings we see now would be very different. This year, DEFRA have announced a 2-year review of lead ammunition to consider withdrawing it some time in the future. This is glacially slow progress on a straight forward health and environmental issue. Frankly, it’s foot-dragging of the worst possible kind.

    Wild Justice believes that DEFRA (and the devolved administrations) should act more quickly in order to start delivering better environmental and health protection. Just get on with it!

    In the continuing absence of government action then retailers should follow the example of Waitrose (and Waitrose must follow through on its promises) and supply lead-free game meat.

    Here are some of the 1240 comments that were made on this survey. They are representative in that we took every 30th comment, whatever it said;

    1. The dangers of lead in natural habitats is well known. Warning customers of high lead levels in food will not solve this wider problem, a complete ban on lead shot is the only solution.
    2. It’s blindingly obvious that if you shoot with lead one will end up eating fragments of lead! Abundantly clear health warnings should self-regulate the demand for birds that are shot and slowly reduce the public demand and appetite. Shooting wild birds should be outlawed. We are in the 21st century!
    3. I’m amazed that lead in any form, least of all pellets, is allowed anywhere near the food chain, especially after so much work went into removing lead from water pipes, paint, toys etc.
    4. Steel shot in game will cause damage to teeth. Steel shot in timber will blunt saws
    5. I would much prefer them not to sell game at all. Get lead banned now. Very difficult to police in the field though, I would imagine
    6. spreading lead into the environment is wrong.
    7. Not good, obviously. But restrictions on levels for all meats can come now – in advance of banning. And non toxic ammunition, if introduced more widely, should be plastic free, including packaging.
    8. Game shooting for pleasure should be banned completely.
    9. I am appalled that lead shot is still being used in the country given that its toxological effects are well understood. Lead in petrol was banned more than 2 decades ago and in paint nearly three decades ago!! Please carry on campaigning for lead free meat. Thank you for all your good work.
    10. I am really surprised rules are so lax. I believe lead shot and weights for fishing were banned years ago?
    11. Many tv programmes are encouraging more game will be eaten. So more lead ingested. Lead was taken out of paint as it was so dangerous.
    12. Basically ban shooting of any wild animal including game. Lead contamination would not arise then. Become vegetarian.
    13. Lead weights were banned for fishing so same should apply here.
    14. eating the occasional pheasant is not going to do you any harm. why don’t you concentrate on sugar ?
    15. I think this is quite scary and I think we put a lot of faith into supermarkets to do the right thing by their customers, but this just shows that they really are only interested in profit!
    16. This is yet another disgraceful aspect of the game meat industry.
    17. I would like to say that I am surprised that governments (of whatever political party) have not taken action before on this issue, but I regret to say that I am not. Now that this information is publicly available I would like to think that the present government will take action – and that offending retail suppliers will take immediate, voluntary action themselves pending legislation that enforces action and imposes very strict sanctions.
    18. Appalling
    19. Hard to blame Sainsbury’s as they are not breaking any laws, all supermarkets are the same. This is a great study but need to be careful not to discourage supermarkets from selling game meat, it could be a good and sustainable market if some changes happened eg banning lead shot. We all need to be eating more deer for example. Great project though. Shows the weakness of our regulation yet again.
    20. Avoid eating game anyway as it helps to fund the “shooting for fun” people.
    21. All contamination of food should be banned
    22. I was surprised it spread in the meat
    23. Should be prosecuted for selling it
    24. What about the other supermarkets and ordinary butchers?
    25. Lead shot should be banned, it’s an environmental contaminant. Humans can choose to avoid these products once they know about the problem. Animals, cannot avoid it in the wide environment. It must kill individual birds, which are then eaten by other animals. It must affect cognitive ability and therefore survival chances, at lower levels.
    26. I wouldn’t buy game meat as I don’t approve of shooting any animal in the wild because of the risk of it suffering injury or a slow painful death. I’d rather we did not artificially breed pheasant and other game for shooting.
    27. Thank you for raising this issue, and acting on it!
    28. I am vegan
    29. ######### School, Lancaster in 2019 used pheasant shot with lead in their cookery classes without any warnings to children, because the pheasant was donated free by a gamekeeper parent. When confronted about this the headteacher was pretty unconcerned.
    30. Lead is toxic and should be banned outright. Would you feed your children food containing such high levels?
    31. Not happy about eating food contaminated with lead
    32. Lead is a very toxic substance to have in food and it was very worrying to learn that people who buy game are being exposed to a higher level than allowed in other meat. I don’t buy game but I’m glad you are exposing this.
    33. There’s still a lot of lead water pipes in old houses, can you test how safe the water is to drink?
    34. I was shocked to see just how many of the samples – 80% – contained lead. And even more shocked to find out that neither the shooters nor the supermarkets are legally obliged to point this out to consumers. I am also concerned about how much of this lead ammunition finds its way into our waterways and soils.
    35. No-one should be shooting game in the first place! It’s not a sport, it’s not a business, it’s cold blooded murder of innocent creatures!
    36. The UK government should introduce legislation for an outright ban on the use of lead shot.
    37. We no longer have lead used in pipework, roof flashing, paint and so forth because we know the detriment it has on health. Therefore, why on Earth is it justifiable let alone sensible to be eating it, especially unwittingly more often than not??!
    38. Please publish the levels found, not just that you found higher levels and which part of the country it was sourced rtom
    39. I have eaten pheasant many times & have sometimes found the tiny lead pellet inside. It never occurred to me that lead contamination would occur throughout the game & cause a health risk, so I would also like to see health warnings on packaging also saying how the game was killed.
    40. I’d rather it the wild birds than chicken that is intensely farmed. The lead in the bird can be removed.
    41. Lead contamination should be highlighted in public media more often. game shooting needs much stricter controls.
    42. There needs to be more media coverage of the realities of the lead content of game based good products, The relevant food safety authorities should be proactive about this.

  131. Waitrose game meat still has lead in it – but signs of improvement

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    Introduction:

    Yesterday we described the results of tests for lead levels which we commissioned on Game Mix and Pheasant breasts sold by Sainsbury’s. There are no maximum allowable lead levels set for game meat but there are maximum levels set for other meat such as pork, beef, chicken etc. We showed that Sainsbury’s game meat was usually way above the lead levels allowable for non-game meat. This is despite the fact that lead is a poison and is the subject of health warnings, particularly aimed at pregnant women, women trying for a baby, toddlers and young children. We analysed Sainsbury’s game meat because we considered their responses to customers on this issue to be misleading and evasive.

    Are Sainsbury’s typical of other supermarkets? We don’t know except that Waitrose definitely appears to be different. Waitrose announced in July 2019 that from the 2020/21 shooting season it would only stock lead-free game birds. To do this it would source its game meat from suppliers who only used non-toxic ammunition, such as steel shot for killing Pheasants, Red-legged Partridges, Wood Pigeons etc..

    As the game shooting season approached last year Waitrose shifted its position and blamed this on the coronavirus pandemic. This is what they said, and this notice is still on the Waitrose website (at least it was yesterday) but it is quite difficult to find (follow the link below and then scroll down a very long way).

    Lead shot pledge

    Waitrose & Partners is the largest retailer of game in the UK. We sell prepared wood pigeon, partridge and pheasant during the season. We are supplied by a single game dealer who ensures all the game source is from environmentally minded British shoots and reared to the highest standards. We monitor the shoots we source from and expect them to adhere to our bespoke standards of animal welfare and shoot behaviour. 

    From the 2019-20 season we began phasing out the use of lead shot on the Estates from which we source our game. We publicly stated that all the Estates we buy from will be required to use lead alternatives such as steel or bismuth from season 2020/21. We are disappointed that the COVID-19 outbreak has set back our plans as many of the Estates that supported our pledge are not shooting this season. However, we expect that more than half of the game on our shelves will be lead free during the 2020/21 season. As a result, our game will continue to carry the FSA lead warning which states “Consuming lead is harmful, health experts advise to minimise lead consumption as much as possible. Anyone who eats lead-shot game should be aware of the risks posed by consuming large amounts of lead, especially children and pregnant women.” In agreement with our game supplier, we are now pledging that by season 2021-22 all Waitrose & Partners game will be brought to bag without the use of lead ammunition.

    https://www.waitrose.com/home/inspiration/about_waitrose/the_waitrose_way/waitrose_animal_welfarecommitments.html

    So, when we bought game meat from Sainsbury’s earlier this year and sent it off to be analysed, we also bought 20 Waitrose whole Pheasants and took samples from them to be analysed too.

    Methods:

    The details of the collection, treatment and analysis of the samples were as described for Sainsbury’s meat samples yesterday.

    Results:

    Yesterday we showed you the results of lead analyses of Sainnsbury’s chicken meat and two game products; Game Mix and Pheasant breasts. In the table below those findings are reproduced with the two types of Sainsbury’s game meat combined on one line and the Waitrose data added.

    Chicken: there were 20 samples, none had any detectable lead in them so the lead levels were below 0.04 units, and therefore 0/20 of the chicken samples were above the maximum allowable level which applies to chicken, pork, beef etc.. No problems there.

    Sainsbury’s game: there were 30 samples, and 24/30 (ie 80%) had lead levels beyond the threshold of maximum allowable level which applies to beef, pork, chicken etc..

    Waitrose game: despite having the highest single lead value of any of the meat samples we had tested, Waitrose game meat had a lower median and lower mean lead level than Sainsbury’s game meat. And 11/20 (ie 55%) of Waitrose samples were above the level allowable in non-game meat. There is evidence here that Waitrose really has tried to move towards lead-free game meat and with some success. That impression is enhanced by the fact that 0/30 of the Sainsbury’s game meat samples were below the detectable level of 0.04 units whereas 7/20 of the Waitrose samples were ‘lead-free’.

    Discussion:

    Sainsbury’s game meat has high lead levels and Waitrose game meat has lower lead levels. Both companies ought to do better and we will test their game meat and perhaps that of other game sellers next winter to see whether they are doing better.

    There are some other differences too. Waitrose game meat has a health warning (see below) which refers to lead and its effects on children, Sainsbury’s does not. Waitrose have publicly stated that they are going ‘lead-free’, Sainsbury’s have not.

    Waitrose health warning

    Wild Justice spent some time talking to journalists about this matter yesterday. Waitrose told a journalist that ‘game continues to be labelled for lead as per Food Standards Agency requirements‘ which is being unduly modest of them, since there are no FSA requirements to label game meat in that way. If there were, then Sainsbury’s and every other supermarket would be doing it, and it is, to the best of our knowledge, only Waitrose. So well done Waitrose.

    Also, Sainsbury’s told a journalist in a statment which they said could be used publicly, that ‘Although it’s rare, it’s possible small traces of shot may remain in the product and this is explained on the packaging.’. Well that’s not true – all of Sainsbury’s game meat tested by us, that’s 30/30 samples, had detectable lead levels and many of them were spectacularly high lead levels. That doesn’t seem like small traces to us, and it’s not just ‘possible’ it seems to be normal. Lead is not mentioned on the packaging that we have seen. Sainsbury’s also claimed that ‘We can reassure our customers that testing shows any traces found in the product available from Sainsbury’s are within EU legal limits.’ which is true, in a way, in a very strange way, because there are no lead levels for game meat set by the EU and so Sainsbury’s could put a lump of lead on the shelf, call it a Pheasant and it wouldn’t be above the EU lead levels for Pheasant! It has been suggested in a scientific paper last year (see here) that there should be maximum allowable lead levels set for game meat because they don’t exist at the moment. Maybe Sainsbury’s will start lobbying the FSA and DEFRA to introduce such limits in this country? Do you think they will?

    Sainsbury’s also told journalists that they are no longer selling the range of products we tested but it seems nobody thought to ask them whether they would be selling them again next season and what their plans are for selling game with or without lead in it. We will ask Sainsbury’s those questions and in any case we will test their game meat next winter.

    Yesterday, as well as publishing our blog on Sainsbury’s game meat, Wild Justice sent out a newsletter to over 40,000 subscribers (you can subscribe to future issues here – they aren’t all about game meat) asking them what they thought should happen about regulation of lead ammunition and food quality. We also asked what our supporters thought about Sainsbury’s. We’ll publish the results of over 2,500 responses later today. It will make interesting reading for the FSA, Sainsbury’s, Waitrose, other vendors of game meat and DEFRA.

  132. Sainsbury’s game meat has high lead levels

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    Introduction:

    Here we describe the results of analysis of samples of game meat purchased online or from Sainsbury’s stores.

    The context to this study is that lead is a poison and has been removed from many previous uses (water pipes, paints, petrol, fishing weights) over time.  And yet we continue to use lead ammunition in recreational shooting in vast quantities each year.  Lead shot is overwhelmingly the commonest form of ammunition used for killing ‘small game’ such as Rabbits, Wood Pigeon, Pheasants and both species of partridge.  Some of that lead-shot game is eaten privately by the shooter or enters the human food chain through game dealers, butchers and large supermarkets. 

    The Food Standards Agency warns against eating large quantities of game shot with lead ammunition and advises pregnant women and those trying to become pregnant to avoid eating such meat and that it should not be fed to young children. Ingesting lead can have a variety of physiological impacts on different parts of the body but the emphasis on children is because the central nervous system is susceptible to lead.  Decreases in the IQ scores of children are associated with increases in blood lead level.  Health authorities consider that there is no safe threshold level of exposure to lead, below which there is no risk of harm.

    Surely government regulations protect us against eating meat with lead in it? The current situation is bizarre; Maximum Levels (MLs) for lead exist for most meats such as chicken, beef, pork etc, but not for game meat which is shot with ammunition, very often lead ammunition. The ML for lead in most meats is 0.1mg/kg wet weight (WW); that’s 1g of lead in 10,000,000g of meat, or 1g of lead in 10,000kg of meat – a standard portion of meat is around 80g (0.08kg).

    Because there are no MLs set for lead content of game meat, most consumers (with no specialist knowledge of lead levels in foods) have to trust retailers to provide food for sale with low lead levels, or for retailers to flag the health impacts of high lead levels in such meat, or for the suppliers of shot game to switch away from lead ammunition to the many non-toxic alternatives. There is very slow progress on any of this.

    Why did we pick on Sainsbury’s game meat to analyse? Sainsbury’s is a big company and it ought to be well aware of all of the above. Sainsbury’s is selling game meat with a prominent British Game Alliance logo on it and the packaging prominently states that it is ‘ideal for a healthy casserole or game pie’. At the back of the packet there is a small warning that mentions that shot might be in the meat, but not that the shot is probably lead and not that ingesting lead has health implications for all, but especially for young children. The front of the packet says ‘healthy’, the back of the packet does not even flag health concerns.  And when Sainsbury’s were asked about lead in their game meat they clammed up very quickly, passed enquirers on to their supplier, Holme Farmed Venison, who have not answered enquiries about lead levels in the game meat that they supply.

    That’s why we thought it worth testing Sainsbury’s game meat for lead levels – because they would not tell us or anyone else about the levels of a poison in their meat.

    We expected to find high levels of lead in Sainsbury’s game meat because all similar studies of lead-shot game meat have found high levels of lead in them. We thought that it was unlikely that Sainsbury’s had ensured that they had removed the possibility of lead being in the meat they sell to their customers because we thought they would have said so.  But you never know until you look, and so we looked.

    Methods

    20 Sainsbury’s British Small Whole Chickens (to act as a control), 20 Holme Farmed Venison Diced Game Casserole Mix packs and 10 Holme Farmed Venison packs of Pheasant breasts were purchased in Sainsbury’s stores or from Sainsbury’s online between 8 January and 10 February 2021 (more details in Appendix 1 below).

    Samples from each purchased pack were taken, labelled and frozen. From the chicken meat, two samples were taken from the breast and one from each leg, making a combined total weight of 20-40g per bird.

    Frozen samples were sent to a laboratory for analysis where they were desiccated, ground down and then a sample of the milled dried meat analysed with standard techniques by a team with experience in this type of chemical analysis (for more details see Appendix 2).

    Results:

    No lead shot was found in any of the samples, consistent with Sainsbury’s saying that lead shot are removed. However, what were the lead levels?

    All 20 of the chicken samples had lead levels below the limits of detectability for the process – less than 0.04 mg/kg WW. They were all, therefore, well below the ML of 0.1 mg/kg WW which is set by regulation.


    But it’s a different situation for game meat. Despite there being no lead shot found in these samples the lead levels are high – so high that if the ML for lead in meat did apply to game meat Sainsbury’s wouldn’t be able to sell this meat (24 out of 30 samples were above the ML).

    The highest recorded level in this relatively small sample of game meat is at least 200 times higher than that present in the chicken samples, and 87 times higher than would be legal in chicken, pork, beef, etc.


    Discussion:

    These results are in line with previous studies. They don’t really show anything very new but they are of high relevance to public policy, retail practice and the public’s ability to make informed choices about what food to buy.

    If government applied the same ML to game meat as is applied to other meats then lead-contaminated meat would essentially disappear from our tables.

    If government and the Food Standards Agency regularly tested game meat for lead levels, and publicised the results, then we, and others, wouldn’t have to.  Actually, a government body, the Veterinary Medicines Directorate, has been measuring levels of lead in venison, pheasant and partridge destined for consumers for many years, but they do not publicise their results.

    If the Food Standards Agency made their health warnings about game meat prominent and if they required labelling of game meat with warnings then consumers would be making a more informed choice when buying such food.

    If supermarkets voluntarily put warning labels prominently on their game meat then consumers could make a more informed choice and choose to eat high levels of lead if they wanted, and choose to feed high levels of lead to their children if they really wanted to do that.

    If the shooting industry switched to the readily available non-toxic ammunition then this would be a done deal.

    Sainsbury’s have not done a good job in protecting their customers from high lead levels in the meat that they sell, they have not done a good job in highlighting the health issues and they have not been open with customers who have asked them specifically about these matters. We’re not impressed by Sainsbury’s on this issue.

    Waitrose is the supermarket which has reacted to this issue the best. We also collected 20 samples of Pheasant meat from Waitrose stores and got them analysed. We will report on those findings tomorrow.

    Acknowledgements:

    This study was entirely funded by supporters of Wild Justice donating money to our general funds – thank you! We’d like to thank Dr Mark Taggart and Dr Yuan Li of the Environmental Research Institute, University of the Highlands and Islands, Thurso, for carrying out the lead analysis. A variety of friends and colleagues helped with this project, collected samples, commented on drafts of this blog or helped in other ways.

    Wild Justice:

    Wild Justice is a not-for-profit organisation set up by Chris Packham, Ruth Tingay and Mark Avery. We are entirely dependent on donations. To support our work – click here. To hear more about our campaigns and legal cases subscribe to our free newsletter – click here.

    Appendix 1

    The meat samples were bought at the following Sainsbury’s supermarkets: Chicken; Romford, Ilford, South Woodford, Walthamstow, Stratford City and Beckton (all London), Brentwood (Essex) and Biggleswade (Beds); Game Mix; Romford, South Woodford and Beckton (all London), Brentwood (Essex), Hoddesden (Herts) and Biggleswade (Beds); Pheasant breast; online (4), Beckton (London), Brentwood (Essex) and Hoddesden (Herts).

    Appendix 2

    The frozen samples were first dried in a drying oven at 65°C to constant dry weight. The average wet weight sample size was 38.3g, dropping to 11.8g after drying – giving an average moisture content of 69%. Dried samples were then milled to a fine powder and stored in zip-lock bags in a desiccator post mill to ensure they remained dry. Milling was undertaken very carefully to ensure thorough cleaning of the mill between samples, using dry lab tissue and a stream of compressed air to remove all residual particles of material. Milled samples were digested using a microwave digestion system and pressurised Teflon vessels – using trace metal grade nitric acid and trace metal grade hydrogen peroxide. A 0.4g subsample of each powdered sample was digested and following complete dissolution solutions were made up to 15ml volume with Type I Milli-Q ultrapure water. In parallel with samples, blanks were run to attain a procedural limit of detection for the process, and a certified reference material (CRM) was used to ensure Pb recovery was within tolerance (strawberry leaf powder (LGC 7162) was used as the CRM, with a certified Pb level of 1.8 +/-0.4 mg/kg DW). Once digestions were complete, all samples/CRMs/blanks were analysed using an ICP-OES system (Agilent 5900). The instrument was calibrated against five Pb wavelengths and the 220.353nm Pb line was used for final data processing/calculations. CRM recovery was within the above CRM tolerance. Analysis was undertaken at the Environmental Research Institute, University of the Highlands and Islands, Thurso, Scotland.


  133. Lead levels in game meat

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    Later this week we will publish the results of laboratory analyses of lead levels in game meat sold in Sainsbury’s supermarkets. Here we provide background to the issue, following Monday’s blog on what Sainsbury’s say about the game meat they sell.

    Lead is a poison and it is harmful to wildlife and to people. There is a vast literature on this subject, much of it is technical and scattered across the scientific literature. Here are some pointers to fairly accessible accounts that you can read in order to learn more about the subject:

    1. The Peregrine Fund 2008 conference proceedings, Ingestion of Lead from Spent Ammunition: Implications for Wildlife and Humans, held in Boise , Idaho. Have a look at Qualitative and quantitative detection of lead bullet fragments in random venison packages donated to the Community Action Food Centers of North Dakota, 2007 (p154, it’s a short paper and Figure 2 is worth seeing), Lead bullet fragments in venison from rifle-killed deer: potential for human dietary exposure (p144, the abstract is quite clear about the issue), Hunters and anglers at risk of lead exposure in the United States (p169, again the abstract is good).
    2. The 2014 Oxford Lead Symposium proceedings; the Foreword by Professor Lord Krebs FRS contains the phrase ‘Lead ammunition may be traditional … but it is doubtful whether future generations would perpetuate a tradition of knowingly adding lead to food‘, the Introduction by Professor Christopher Perrins FRS says ‘Successive Governments have dragged their heels over the issue of lead ammunition, none seeing it as a serious enough concern compared with other issues with which they are dealing‘ and the paper Risks of health effects to humans in the UK from ammunition-derived lead has a very accessible abstract.
    3. the 2015 Final Report of the Lead Ammunition Group is a weighty and massive review of the literature. The Key Questions (and the answers to them) are a very accessible summary of the issue (p vii – ix). there is also a useful update on the same site.

    The current health advice from the Food Standards Agency is blunt, saying ‘Consuming lead is harmful, health experts advise to minimise lead consumption as much as possible.’ and ‘Those who eat lead-shot game should minimise the amount they eat, especially for small game animals.’ and ‘Exposure to lead can harm the developing brain and nervous system. So cutting down the amount of lead-shot game eaten is especially important for toddlers, children, pregnant women and women trying for a baby‘. But these warnings are not visible on packaging and, as we have seen , game suppliers are tight-lipped about such dangers and most supermarkets selling game do not highlight this issue at all.

    How could we reduce the risk of exposure to lead in game meat? It’s simple – stop shooting lead ammunition into animals that are destined for the human food chain. One of the useful properties of lead is that it is soft and malleable – that’s why, in the past, we have used it widely. But those same physical properties mean that lead passing through the flesh of a shot animal, hitting organs, soft tissue, bones and cartilage, shatters and tiny fragments of lead spread through the body of the animal. Here are three x-rays of shot birds that were bought in butcher’s shops and then x-rayed. The top x-ray is of a partridge and the other two are Red Grouse. Large white circular objects are lead shot. The green arrows point to fragments of bone and the red arrows indicate fragments of lead, from the shot, that have spread through the flesh.

    Almost all of the fragments of lead are tiny – far too small to be detected in the cooking or eating process. Yes, you can spit out the almost-intact lead shot but you can’t get rid of the fragments. The lead analyses that have been done in studies cited above, and in our own, remove the lead shot and analyse the lead content of the meat after that removal. So when Sainsbury’s say that their game meat has no lead shot in it that’s good (although careful eating would remove those anyway) but they are not removing the tiny fragments of lead. So removing the almost intact lead shot particles is pretty irrelevant to the lead levels in the meat, as we will show you later this week…

  134. Sainsbury’s game meat – and why we tested its lead levels

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    Later this week we will publish the results of laboratory tests that we commissioned to determine the amount of toxic lead present in samples of game meat being sold by Sainsbury’s supermarket.

    The reason we chose to test game meat samples from Sainsbury’s for traces of toxic lead was because in autumn last year we became aware that Sainsbury’s was selling two game meat products – pheasant breasts and a mixed-game casserole (venison, Pheasant and Red-legged Partridge marketed as ‘healthy’) – both produced and supplied by game dealer Holme Farmed Venison (HFV) in North Yorkshire. Both products were ‘kite-marked’ by the British Game Alliance which claims to be the ‘official marketing board for the UK game industry’ offering ‘traceability and credibility’.

    However, despite this endorsement both Sainsbury’s and the supplier were reluctant to answer customers’ questions about why there was no health warning that these products may contain toxic lead shot, for which there is no agreed safe level of consumption according to the Food Standards Agency. Health warnings were absent from the product packaging, from Sainsbury’s in-store shelf labelling and from the sales pages on both Sainsbury’s and HFV’s websites.

    Repeated requests were made to Sainsbury’s and to HFV for information about the lead content of these products. Sainsbury’s initially responded with this generic corporate response, which dodged the direct questions about whether the products contained, or had been tested for, toxic lead:

    The product you have enquired about is a branded product (not Sainsbury’s own brand) and we would encourage any further questions to be directed to Holme Farmed Venison, through their customer helpline. The branded Holme Farm Venison (HFV) [sic] game products are assured by the British Game Alliance (BGA).

    The British Game Alliance independently audits all shoots participating in the accreditation, ensuring that they are all compliant with the requirements.

    Lead shot is being phased out, but is still in use, however 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. There are additional warnings on pack that refers to shot to ensure customers are aware.

    When customers weren’t satisfied that their concerns had been addressed and wrote again to Sainsbury’s, Sainsbury’s responded in a shocking display of complacency about its own customers’ health concerns:

    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.

    Holme Farmed Venison failed to respond to a single information request.

    So, since Sainsbury’s seemed so reluctant to provide health information on products it had chosen to sell, and Holme Farmed Venison refused to communicate at all, we thought we’d do some testing to find out whether these products contained any toxic lead and if so, how much.

    We’ll tell you about those analyses later this week.

  135. 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.

  136. 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.

    Regards,
    Customer Hub

  137. 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.
  138. 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.

  139. 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

  140. 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

  141. 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
  142. 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

  143. 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

  144. 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.

  145. 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.

  146. 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.

  147. 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.

  148. 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.

  149. 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 https://www.sciencedirect.com/science/article/abs/pii/S0006320704003350?via%3Dihub ). 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 https://markavery.info/2020/11/05/gamebirds-victory-16-the-500m-myth/ ) 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 admin@wildjustice.org.uk 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.

  150. 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.

  151. DEFRA launches gamebird consultation

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    https://www.gov.uk/government/news/consultation-launches-on-interim-licences-for-releasing-gamebirds

    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.

  152. 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.

    .

  153. 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.

  154. 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.

  155. 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;

  156. 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 https://petition.parliament.uk/petitions/333693

    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.

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

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    https://www.gwct.org.uk/blogs/news/2021/february/wild-justice-asks-gwct-for-help/

    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.

    https://wildjustice.org.uk/general/gwct-please-check-these-statements/

    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)

    https://wildjustice.org.uk/general/gwct-please-check-these-statements/

    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?

    https://wildjustice.org.uk/general/gwct-please-check-these-statements/

    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.

  158. 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.

    https://www.gov.uk/government/news/defra-concludes-its-review-into-releasing-gamebirds-on-and-around-protected-sites

    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.

  159. 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!

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

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    https://www.nationalgamekeepers.org.uk/articles/natural-england-individual-licences

    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.

  161. Making payments to our bank account

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    https://www.triodos.co.uk/

    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.

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

    Comments Off on Further success on general licences – this time in Wales

    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:

  163. 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.

  164. We’re waiting patiently

    Comments Off on We’re waiting patiently
    https://cdn.cyfoethnaturiol.cymru/media/692740/general-licence-001-english-2021.pdf

    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.

  165. This is a surprise…

    Comments Off on This is a surprise…
    https://petition.parliament.uk/archived/petitions/266770

    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.

  166. 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.

  167. 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.

  168. 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.

    FAQ

    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.

  169. 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.

  170. 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: admin@wildjustice.org.uk 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.

  171. 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

  172. 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

  173. 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 mark@markavery.info

    Notes:

    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.
  174. 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