NGO letter to Natural Resources Wales in response to the proposed general licences changes

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Following Natural Resources Wales’s consultation at the end of last year, there are a number of proposed changed to their General Licences which, if approved, could come into force in Wales as of 1 July. The NRW Board are meeting today (24 March). Below is the submission we sent to board members in advance of today's meeting.

Dear NRW Board Member,

We note with dismay the proposal to remove magpies, jackdaws and jays from the General Licence for Conservation (GL004), which are being presented at your upcoming board meeting on 24 March.

The purpose of GL004 is to conserve wild birds; indeed your proposed new GL004, which includes only the carrion crow, states clearly that it exists “for the purpose of conserving eggs and chicks.”

Given the fact that the Welsh Government have, with good reason, declared a Nature Emergency, we have serious concerns over the impact that this decision would have on farmland and songbirds, many of which are in a state of serious decline.

Magpies, jays and jackdaws are all known to predate on the nestlings of vulnerable, smaller birds. This is the exact reason why they were originally included on GL004, where the focus is on the conservation of wild birds.

The fact that these three corvid species predate on nestlings and eggs is not mere hearsay. On the British Trust for Ornithology’s own website, the diet of a jackdaw is listed as including “Small vertebrates or eggs; nestlings.” With regards jays, the BTO state that “they will also raid the nests of smaller birds to take eggs and young.” When it comes to magpies, it has long been established that they predate on songbird young; the RSPB themselves state that magpies “will take eggs and nestlings”, as will most members of the crow family.

As the National Gamekeepers’ Organisation, our members are responsible for much of the conservation work that happens across both the UK and Wales more specifically. Conserving nature and helping to protect the most vulnerable and threatened species is an important part of a gamekeeper’s job, and with that in mind we wanted to canvass our Welsh members on what the change to GL004 might mean to them.

Three specific anecdotes that we heard from our members stood out, and we wanted to share them with you.
The first came from a Welsh keeper named Chris who spoke of regularly seeing magpies hopping along the hedgerow last springtime searching for nests to raid. On one occasion, he observed a magpie raiding the nest of a yellowhammer – a bird that is on the ‘red list’ for conservation concern –and removing nestlings. If magpies were removed from GL004, he would have no other option but to stand by and watch nests and chicks be destroyed, as incidences like these increased.

The second came from another keeper in Wales, Dave, who talked of having had numerous kestrels living on his estate in the past. These used to be one of the most abundant birds of prey in the UK and Wales, and they play an important role in the biodiversity of the Welsh countryside. However they are now in a state of decline. The keeper in question noticed that many of the kestrel’s nesting sites have now been filled by jackdaws, and worried that the influx of jackdaws, and the competition for both nest sites and for food, was having a direct effect on the estate’s kestrel numbers.

We note that the RSPB appear to back up his concerns. On this link, which refers to their work into declining kestrel populations, they state that one of the main reasons for their decline is: “Increased nest site competition from jackdaws and barn owls”.

The third anecdote concerns footage that another Welsh NGO member, Steve, obtained from a CCTV camera which he had trained on a blue tit nest. We know already that jackdaws are keen on nestlings and eggs, but he managed to obtain video footage of jackdaws visiting and destroying every egg in that nest.

More widely, we are concerned that this proposed change to GL004 suggests a more general move away from predator control as a management tool when it comes to conservation and nature recovery. We know that predator control can be a controversial issue, but our view is that it is a necessary tool if we are to protect our most threatened species. This is not just our opinion. The GWCT are an entirely independent and research-led organisation – their view is that predation control can play an important role in conservation and species recovery. Even the likes of the RSPB accept that when it comes to protecting species such as the curlew, predator control (in this case foxes and crows) is vital.

If you would like to see what happens without predator control, we might suggest a visit to Lake Vyrnwy, the RSPB’s flagship reserve in Powys. When this was managed as a grouse moor, the area was abundant in red and amber-listed species including curlew, lapwing and black grouse.

In the decades that the RSPB have managed the reserve without the use of predator control, all of these species have seen their populations plummet, as have many raptor species. This is again not just hearsay, but something the RSPB themselves admit. In their own bid for a grant from the Heritage Lottery Fund, the RSPB stated that without this money, “in the next few years curlew, black grouse and merlin will cease to appear as a breeding species in this area of Wales. It is likely the same fate would befall red grouse and hen harrier within the next decade.”

We hope that this letter will encourage you to reconsider the proposal to remove magpies, jays and jackdaw from GL004. If the Welsh Government do truly want to see their nature and wildlife restored and biodiversity improved, we would urge you to follow the science, rather than leave threatened species vulnerable to predation.

Yours sincerely,

The National Gamekeepers’ Organisation