NRW consultation on gamebird releases: your chance to participate

Natural Resources Wales (NRW) is consulting on future regulations to control gamebird releases. Their plans are to adopt a very similar set of regulations to those in England. We think there are lessons to be learned from the English regulations, and that Wales could do better, but we generally support the measures being proposed.

The consultation paper can be found here – click here. It closes on 20th June so there is just over a week for you to participate. Here are our suggestions for how to respond but you must make up your own mind as to what you say – but please do respond regardless of where in the UK you live.

The first three questions relate to your personal details. Here are the remaining five main questions, Questions 4-8, related to the release of gamebirds in Wales, and our suggested responses in italics:

Q4. Do you agree that common pheasant and red-legged partridge should be added to Part 1 of Schedule 9 of the Wildlife and Countryside Act 1981 in Wales? This change would mean that releasing those species in Wales would need to be carried out under licence. Please give reasons for your views.

I strongly agree with this proposal. This is a proportionate and logical response to the issues laid out in the consultation document and its accompanying papers. Self-regulation will not work as here we are dealing with the shooting industry – a notoriously uncooperative group of people who promote self-regulation but rarely deliver it (eg on wildlife crime, moorland burning and lead ammunition use). The shooting industry always claims to be highly regulated whereas in fact shooting is almost unregulated across the UK with respect to many other European countries.

Q5. If these species are added to Schedule 9, please give us your views on whether our proposed licensing approach would be effective and proportionate?

I generally support the proposals but they need to be made tougher in order to build on lessons learned from the last few years in England – Wales should do better.

Enforcement and monitoring – the shooting industry cannot be relied upon to stick to new regulations, it is a notoriously conservative industry which is reluctant to change. NRW  must ensure that monitoring and enforcement of compliance is in place. In England, Natural England has not carried out this function, and neither does Defra and so the regulations are not properly enacted. Wild Justice has recently (8 June) started a legal challenge to the regime in England.

Use of general licences – I believe that instead of a general licence, these measures should be enforced through individual licences where anyone wishing to release gamebirds must apply for an individual licence. Such measures were not introduced in England but have now been imposed for releases close to many ‘European Sites’ partly as a response to the widespread prevalence of avian flu and well-founded concerns over the role of gamebird releases in exacerbating the problem through providing a very large reservoir of captive bred and released birds. Wales should move directly to this approach.

Reporting of releases – an individual licensing system would go a long way to providing information on numbers of birds released and their locations. Current measures, including the APHA poultry register, provide very little useful information on which to base future improvements to regulation.

Should Mallard releases be included in these measures? – at a time of avian flu, but in any case, why are not Mallard releases covered by these proposals?

Buffer area around sensitive sites – the 500m proposal is not based on the current scientific evidence. Gamebirds travel much further than this from release sites. Based on the current evidence I would support a buffer zone of 1km. The maximum distance travelled by released gamebirds (Pheasants) in the study by Turner (2007) was, on average, over 900m and this only considered the first three months after release – gamebirds can be expected to disperse further in the other nine months of their first calendar year, and beyond.  It is a commonplace event whilst travelling in the countryside to see gamebirds far from any potential release sites – the 500m zone is not supported by evidence and is not fit for the purpose of protecting sites of conservation importance.

Will the proposals be sufficient to protect sites of conservation importance? – the English regulations largely ignored the impacts of gamebirds on reptile and amphibian  populations, the effects of gamebird releases on mammalian predator populations, the indirect impacts on lead shot use and the impacts on avian flu transmission to poultry and to wild birds. In England stronger measures have recently been introduced (individual licensing near SPAs) which partly address the avian flu issue. I see that Annex 3 of the consultation papers provides a long list of known or suspected impacts of gamebirds on wildlife of conservation importance and that includes reptiles and amphibians which were largely ignored by Defra. There is clear need for tougher regulations than were initially introduced in England and I strongly feel that NRW should introduce a larger buffer zone (1km) and individual licensing of releases as its starting point for effective regulation of harmful impacts of gamebirds on native wildlife.

Charging for licences – NRW and Defra have both moved to a position of regarding non-native gamebird releases as a wildlife conservation issue which must be controlled.  The polluter pays principle should apply here and the eventual licensing system should not be a burden on the taxpayer. I support individual licensing of releases and those licences should carry a charge.  This can also be seen as a charge on the failure of the shooting industry to self-regulate over recent years and their opposition to any form of new regulation which will protect the environment.

Q6. We have based the proposed general licence conditions for pheasant release on the recommendations in the GWCT guidelines for sustainable gamebird releasing. However, the guidelines do not include specific density thresholds for red-legged partridge and there appears to be less evidence on which to base conditions relating to partridge. We have used what evidence is available, and expert opinion, to propose conditions for partridge releases. These are either based on a density threshold linked to the area of cover crop provided, or on density per hectare of release pen (as with pheasants), depending on how the birds are released. We would welcome views on whether these proposals are appropriate and workable and whether they could they be improved.

I do not regard the GWCT guidelines as having taken sufficient account of new evidence or the current condition, and they were produced by an organisation strongly supportive of gamebird shooting. NRW should take a precautionary approach and assume that all impacts are worse than GWCT recognise.

Q7. The GWCT guidelines include a recommendation that no more than one third of woodland with game interest should be used for release pens. This is to ensure sufficient woodland remains that can benefit from habitat management activities. We would like to include this recommendation in our proposed general licence. However, we would prefer to be able to define what can be included in the calculation. Do you have suggestions for how this might be achieved?

I do not regard the GWCT guidelines as having taken sufficient account of new evidence or the current condition, and they were produced by an organisation strongly supportive of gamebird shooting. NRW should take a precautionary approach and assume that all impacts are worse than GWCT recognise. In any case, these measures do not in themselves limit the scale of gamebird releases – if a woodland currently has release pens that occupy less than a third of the woodland area then increases in gamebird releases would be possible. This is not what NRW should be accepting. An individual licensing system and a 1km buffer would go some way to addressing this point.

Q8. Location and density appear to be the main factors influencing the environmental impact of releases, but we recognise that smaller releases in less sensitive areas are likely to present reduced risks. It may be appropriate that small gamebird releases taking place away from sensitive protected sites and their buffer zones are not subject to the same general licence conditions that apply to larger releases. Do you think this is something we should consider? Please give reasons.

Many small releases add up to the same cumulative impact as few large releases – it is the overall impact that NRW must address. I cannot see that this approach does anything other than complicate matters to the benefit of very few individuals and the potential disadvantage of the wildlife that NRW must protect.

Please do consider responding to the consultation – click here – which closes on 20 June. Numbers are important and we know that the shooting industry is encouraging their supporters to respond. Numbers do matter, so this is definitely a subject on which you can make a difference. 

It was thanks to Wild Justice, including our supporters, that regulations were brought in in England and those regulations of gamebird releases are better than nothing but need to be improved over time (hence our current legal challenge about the release of gamebirds in England – here). NRW has been slow to move on this subject, but quicker than Scotland and Northern Ireland, and needs to be shown that there is public support for effective regulation now. You can help that to happen.