Natural Resources Wales consultation on game bird release: supporter advice

We strongly 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. It is a proportionate response to the environmental damage the release of these non-native birds can cause and the failure of self-regulation.

Some of the reasons include:

• They are non-native birds, and so the established mechanism is to include them in Part 1 of Schedule 9 of the Wildlife and Countryside Act in Wales.
• There is clear evidence that their release can have negative effects on the environment and biodiversity.
• This problem is made worse by the huge numbers released without regulation, with the proportion of very large shoots being greater in Wales than elsewhere.
• The shooting industry has shown it is incapable of regulating itself, including by keeping mass release within voluntary guidelines. A license system is necessary step towards limiting the worst excesses and environmental damage of shooting birds for ‘sport’.

We believe the proposed licensing system must go further if it is to be effective in reducing environmental damage. Buffer zones around protected sites should be increased to 1km and individual licenses should be required for all releases.

Some of the reasons include:

• It is welcome and necessary that a licensing system will apply to all land in Wales. Habitats and species of importance to biodiversity and sensitive to damage are present across the country, not just on protected sites.
• The proposal to require individual licenses for release near sensitive protected sites is important. However, birds disperse beyond the proposed 500m distance. There is good evidence to show that it would be more proportionate and effective to increase ‘buffer zones’ around protected sites from 500m to 1km.
• The proposed use of general licences for land not near protected sites lacks appropriate reporting requirements and enforcement powers. If shoots are not required to register or report their activity, it is unclear how NRW will know if the rules are being followed or be able to enforce them. NRW acknowledges that compliance with existing legal requirement is low but does not make any credible proposals to tackle this. It would be more effective to require individual licences for releases wherever they take place.
• One of the problems the proposed system is supposed to address is the lack of data available on the scale and location of the release of pheasants and partridges in Wales. This picture will not be improved unless there is a reporting requirement which applies to everyone.

[Question continued] 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.

We believe it would be more appropriate and workable for the density thresholds to be reduced. This would better protect the environment and ensure that it is not just ‘business as usual’.

Some of the reasons include:

• The proposed density thresholds for release rely on the views of those heavily linked to the shooting birds for ‘sport’.
• If the vast scale of the release of birds is to be reduced to protect the environment, thresholds should be lower than existing industry guidelines or little is likely to change.
• If there is limited evidence available, particularly in relation to the release of red-legged partridge, then it would be appropriate to take a more cautious and precautionary approach while more evidence is gathered.

[Question continued] 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?

We disagree with this approach and would like to see protections for woodland habitats strengthened.

Some of the reasons include:

• The proposed recommendation for the amount of release pens in woodland relies on the views of those heavily linked to the shooting birds for ‘sport’.
• Sensitive woodland sites exist in many places outside of protected sites in Wales. Releasing game birds into sensitive woodland sites can have negative impacts on native flora and fauna and should be prevented.
• Current proposals to allow release in woodland under general licence, and their lack of reporting or enforcement mechanisms, will not allow NRW to increase its understanding of the extent of the problem in Wales.

[Question continued] 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.

We disagree with this approach.

Some of the reasons include:

•  To exclude small shoots from licensing conditions would ignore the cumulative impact of smaller shoots, limiting the potential positive impacts of licensing. This may be especially true because negative impacts are acknowledged to take place on a landscape scale, not just in the vicinity of release sites.
• Exempting some shoots from the licensing system will further reduce NRW’s ability to understand the scale and location of release across Wales.