Advice from the NGO on responding to the Welsh gamebird release consultation

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• As you may have seen last week, the Welsh Government have now launched a 12-week consultation which introduces proposals for a licensing system on the release of pheasants and red-legged partridge in Wales.
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• We are encouraging as many people as possible to respond, whether you are a shooter yourself, help out on shoot days, benefit from shooting through your business, or simply can see the benefits that shooting brings to biodiversity and to rural communities.
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• The consultation can be found and completed at the following link: https://ymgynghori.cyfoethnaturiol.cymru/evidence-policy-and-permitting-tystiolaeth-polisi-a-thrwyddedu/nrw-s-proposed-approach-to-regulating-the-release/consultation/intro/
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• We have put together the below advice which might help you with the consultation process. However these are just ideas; please do include any personal stories or additional information that you think would help inform the Welsh government. We would also advise you to read through the document before filling it in. 

1. Q1: Give your name
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3. Q2: Give your email address (optional)
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5. Q3: Ignore, unless you and your response represent an organisation
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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.

A:

• •State that you do not agree with the proposals, as they would mean that the releasing of pheasants and red legged partridges would become illegal in Wales, without the issue of a licence.
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• •The Welsh government have openly said that they do not support game shooting in Wales and as such would be able to change or revoke the license at any time. Can they be trusted?
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• •The Welsh Government have already gone against the advice of their own advisors NRW when they banned shooting on land owned by National Resources Wales.
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• •If you are able to use a personal experience or sentiment that shows how it might affect you individually that would be helpful. For instance, if you shoot in Wales would you have the confidence to book shooting and spend money in the Welsh economy?
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• Economy/Employment
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• •If you work within the shooting, hospitality or retail sector in Wales, how would a licensing system affect your livelihood or business if shooting interests are reduced or stopped?
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• •If you are a hospitality provider or gun shop: can your business survive if you do not have the added winter business provided by game shooting? 
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• •If you are employed in Wales as a gamekeeper, are you going to stay in the country if the licensing system comes into play, or look for work in England/Scotland/Northern Ireland?

• Community and wellness

•Shooting provides much-needed exercise and a feeling of “community” to a number of isolated communities. It has done for centuries. Potential destruction of this way of life will stoke a very real resentment, which will potentially pit town against country, in a region which is geographically predominantly rural.

•If you are a Welsh-speaker and use Welsh while shooting/on the shoot, highlight this, and the fact that there are not many opportunities nowadays to use the Welsh language. The Welsh language is a vital part of the national culture, particularly in rural areas. Suggest that any opportunities to speak the Welsh language need encouraging, rather than removing opportunities to speak Welsh.  

1. •Tell them that the uncertainty could affect people’s mental health.
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3. •Safeguards are already in place for protected sites, so there is no need for further restrictions.

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?

A:

• •Say that it should not be implemented.
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• •It will not be effective. It could in fact be counterproductive, since it is highly likely there would be less conservation work undertaken in the Welsh countryside due to the uncertainty a licensing system brings with it. 
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• •Welsh shoots, farms and estates are less likely to invest in people and conservation if the threat of a license hangs over them. This could promote a downturn in the Welsh economy and also put added pressure onto conservation efforts that are being funded by the shooting community.

•The PACEC Value of Shooting report backs this up, stating that nearly two million hectares are actively managed for conservation as a result of shooting, and that shoot providers spend nearly £250 million a year on conservation. In comparison, this is more than eight times the amount the RSPB spent on conservation on its reserves in 2013 (£29.6m) [NB, the report is from 2014; a new one is due out this year]. 

•Banning the release of game birds without a licence would mean that Welsh shoots, farms and estates are less likely to invest in people and conservation at the very time when urgent investment is required post COVID lockdowns, Avian Flu and a cost of living crisis. The timing is extraordinary inept, displaying a complete lack of understanding of rudimentary economics, rural community wellbeing and individual mental health, all of which were badly affected by recent lockdown measures designed to save an inadequate health service, under Welsh Government control.

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Q6: We have based the proposed general licence conditions for pheasant release on the recommendations in the Game and Wildlife Conservation Trust's 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.

A:

• •Clearly more research is needed in this area, and nothing should be changed that could cause nature conservation efforts or businesses to collapse due to poor decisions being made. Therefore, no reasonable governing authority should be making any recommendations or assumptions until that is done.
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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?

A:

• •Current research shows that woodland managed for game is two thirds better for flora and fauna then woodland that has no game management. Therefore, all of the woodland, hedgerow and scrub cover should be taken into account. 

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  •Research by the Game and Wildlife Conservation Trust (GWCT) shows that woodland managed for shooting rather than for commercial timber production provides richer and more varied habitat. In the wide rides required for shooting, there can be four times as many butterflies as on woodland edge, and in 2012/13 shoots managed 500,000 hectares of woodland. In addition they managed 100,000 ha of copses specifically planted to shelter game [again, please note the report is from 2014].

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

A:

• •The word 'small' has not been defined; what would be classed as a small v a medium/large gamebird release?
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• •If density is a factor, then a large number of birds released over a large area will have reduced risks.
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1. Follow this link to complete the consultation: https://ymgynghori.cyfoethnaturiol.cymru/evidence-policy-and-permitting-tystiolaeth-polisi-a-thrwyddedu/nrw-s-proposed-approach-to-regulating-the-release/consultation/intro/