Natural Resources Wales (NRW) has launched a Consultation on the release of pheasants and partridges into the countryside. Although the Consultation only addresses the release of birds rather than the ethical question of whether it is acceptable to purpose-breed and then kill birds for ‘sport’, this consultation is an opportunity to help to shape NRW’s views.
Below is some guidance if you would like to respond to the Consultation. NRW is especially keen to hear from people in Wales or people who have an interest in Wales and its environment.
NRW is more likely to read individual responses, so please try to fill out the Consultation in your own words as much as possible.
Please note that Animal Aid is completely opposed to the breeding, release and killing of pheasants and partridges. We have made this very clear in all our answers to this consultation even though none of the questions relate to game bird welfare or rights.
You may like to do the same in your response.
The Consultation closes 20 June 2023.
Please note: the survey has eight questions, with the first three asking for your name and email address and whether you are representing an organisation. Please note that you are representing yourself, not Animal Aid, even if you are a member and even if you base your answers on our points below.
Questions four to eight then ask you for your views. The text below in each box just reproduces the questions, with the text in the drop-down box being our suggestions.
4. 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.
Animal Aid answered ‘yes’ to this question.
Some of the reasons include that:
- The birds are non-native and therefore this is the correct place for them to be listed.
- At the moment, shoots release vast numbers of non-native species into the countryside without regulation, and it is a positive first step to list the birds under Schedule 9 in order to acknowledge that there is an issue with their mass release by the shooting industry.
- If NRW is to go ahead and allow shoots to operate, then, at the very least, NRW should insist that all releases of non-native species are done under licence, in order to give a better level of protection to the environment.
5. If these species are added to Schedule 9, please give us your views on whether our proposed licensing approach would be effective and proportionate? Views on proposed licensing approach
Animal Aid has answered ‘No’, because the proposed licensing regime is not proportionate and will not be effective in addressing the huge enviromental damage caused by the release of many millions of birds.
Some of the reasons include:
- The harmful impacts of gamebird releases and shooting on flora and fauna are significant, but these proposals will not stop or even meaningfully reduce these releases.
- Natural Resources Wales proposes to licence shoots under the General Licence – but under the General Licence, shoots would not have to submit any sort of application for release or data on, for example, the numbers of birds released and impact on local biodiversity, and therefore the proposed licensing approach will not allow NRW to gather the information it needs on the effects of releasing pheasants and partridges into the environment.
- If NRW wants to improve its knowledge on how many birds are released, where they are released, how many shoots are operating and so forth, then it needs to require shoots to register their activity with NRW.
- Shoots have a poor reputation for following either voluntary or compulsory guidelines and therefore cannot be allowed to continue to operate as they are – which is what the General Licence would allow them to do. Because the shooting industry has a very poor track record on compliance, there is therefore a need for a tougher, legally binding and enforcing regime.
- NRW proposes to make the bulk of shoots operate under the General Licence, and not to charge them. NRW would only charge for special licences where shoots want to shoot very near to protected areas of woodland. Animal Aid believes that if NRW is going to allow shooting to continue, then, at the very least, NRW should require all shoots to fill out an individual licence application and shoots should pay the cost of issuing the licence.
6. 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 be improved. Views on conditions for partridge release
Animal Aid does not believe these proposals are appropriate or workable.
Some of the reasons include:
- If there is less evidence relating to partridge releases, then NRW should take a precautionary approach in order to protect the environment.
- It is known that mass releases cause significant negative environmental impacts, even though the full scale and scope of those impacts may not be clear. Short of stopping partridge releases completely, NRW should ensure that there would be no negative impact on local biodiversity before deciding upon any release densities.
- It has been proven that pheasants and partridges have a negative impact on the environment and therefore NRW should do everything it can to reduce that impact.
7. 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? View on including a limit on woodland used for pens
Animal Aid disagrees.
Some of the reasons include:
- NRW’s own research has found that special protection should be extended to more areas of woodland.
- Woodlands rich in lichen and vulnerable woodland plants will continue to be put at risk from gamebird releases. This affects both the pens and the wider woods in which pens are located. Such woods and all Ancient Semi-Natural Woodlands should be protected by prohibiting gamebird releases.
- Releasing birds into any woodland has impacts on native flora and fauna.
- The priority for NRW should be to work to protect the environment, and not assisting shooting to go ahead.
- The General Licence would not allow NRW to measure how much woodland is being harmed by game bird releases.
8. 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
No. Animal Aid disagrees.
Some of the reasons include:
- Under the General Licence, NRW would not know how many shoots are releasing birds or where the birds are released or how far the birds travel.
- Birds have been found to wander further than the 500m buffer zones proposed by NRW.
- If NRW is going to allow shooting of birds to continue, then it should take a precautionary approach and increase buffer zones to a minimum of 1000m. It should also require all shoots to complete licence applications indicating how many birds they are releasing and where.
- This proposal ignores the cumulative effect of smaller shoots. Taken together, a large number of small shoots could be more environmentally damaging than larger shoots. All shoots should be covered by licence conditions.
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