Make your voice heard on the future of the quarry list before 17 May deadline

Why it’s important

We would urge all members and supporters to respond to the consultation on the Schedule 2.1 quarry list review to help ensure regulation is based on evidence. Defra is proposing several changes, which have little data to support them, fail to acknowledge evidence of self-regulation and voluntary restraint, and risk being counterproductive. It is vital that responsible members of the game management community register objections to the proposed changes to counter those who will call for ever tighter regulations on ideological grounds. It is also an opportunity to make the case for a more positive and responsible adaptive management approach based on scientific research and practitioner evidence.

The GWCT will be submitting separate responses for England, Scotland and Wales, but there is no need for individuals’ submissions to be as extensive.

Key points to include in your response

When responding, remember to state your name, where you are from, and your interest in the review and relevant personal experience.

You may wish to include the following points in your submission (see more detailed explanation below):

• There is no evidence that shooting is negatively impacting on species abundance, and this should not result in the misapplication of the precautionary principle to call for further regulation.
• There is evidence that self-regulation is working regarding voluntary moratoriums on shooting and adherence to best practice guidelines on open seasons. For example, the moratorium on black grouse is widely observed and 89% of survey respondents indicated that they follow GWCT guidance in refraining from shooting woodcock before 15 November in Scotland, or before 1 December in England and Wales (see below).
• Game management is a recognised driver for conservation and unnecessary restrictions could lead to loss of habitat and predation management efforts to the detriment of the species concerned and wider biodiversity.
• It could also disincentivise harvest data collection and wildlife monitoring.
• We need to move to an adaptive management approach whereby guidance is continually adjusted depending on updated evidence.

Where to send it

By email to WildlifeManagementAndCrime@defra.gov.uk, online here or by scanning the QR code on the right, or by post to:

Wildlife Crime and Management Team
Defra
Seacole Building
2 Marsham Street
London
SW1P 4DF

Further guidance

One of the challenges with public consultations is that simple questions can often mask far more nuanced and detailed considerations. This is certainly true of the current Defra proposals to amend the Wildlife and Countryside Act 1981, allowing certain wild bird species to be killed or taken outside of their close seasons.

The consultation seeks views on either voluntary moratoriums, seasonal restrictions, or a ban on shooting certain bird species. These are set out in the table below:

The Scottish Government also proposes voluntary moratoriums on shooting ptarmigan and grey partridge (in areas where populations in Scotland remain low and no releases occur).

Whilst the consultation questions allow respondents to state their views, significant issues are mentioned in the supporting species information and proposals set out by Defra, Natural Resources Wales (NRW) and NatureScot. These bear closer examination as without review, the casual respondent may miss some important facets. Members will wish to look at these and develop their own views on the management of the species, but we share our particular concerns below.

Defaulting to a precautionary approach

A “precautionary approach” is mentioned regularly throughout the species consultation documents. This basically means that in the absence of sufficient gamebag returns and the evidence necessary to interpret whether shooting is having a particular impact on species, it is proposed to implement curbs on shooting, either by restricting the open seasons or a ban. Whilst this might provide an immediate administrative fix for governments, it does not aid species conservation. It avoids the challenge of improving understanding of all the influences on species population dynamics such as changes in habitat condition, land use and predator control alongside the shooting take. This is especially significant because, in some cases, the species reviews mention the low risk that hunting bags are having on species abundance.

• Members may wish to express concern about the risks of a precautionary approach to species management.

Practical approach to pigeon management

While the consultation raises the prospect of a precautionary approach to species management, we appreciate the practical approach regarding the proposal to add wood pigeon to Schedule 2.1. At present, many pigeon shooters may not be aware that they do so under General Licence provisions rather than an open season. GWCT feels the addition of pigeon to Schedule 2.1, the suggested dates for a close season and the maintenance of a General Licence safety valve (permitting shooting to prevent damage to crops during the close season) would offer more clarity than current conditions.

• Members may wish to endorse this approach in consultation approaches.

Evidence for self-regulation

The apparent assumption made from the lack of sufficient bag returns seems to be that hunters are not exhibiting sufficient self-regulatory behaviour that could offset proposals to restrict or ban the shooting of certain species. The GWCT recognises that with increasing need to understand the impacts of climate change, habitat condition, land use changes and shooting, we also need to encourage greater commitment to making gamebag returns so we can demonstrate ‘best practice with proof’. However, that doesn’t mean that there is a lack of self-regulation.

The GWCT has recently undertaken a membership survey. The results show a strong commitment to self-regulation, restraint and local decision-making. Habitat management and predator control feature as important components of conservation support for quarry species, which is viewed as more influential for species populations than the shooting take. Sustainability is an important subtext. Here are some examples from the survey:

• 89% of survey respondents indicated that they do not shoot woodcock before 15 November in Scotland, or before 1 December in England and Wales
• 53.2% of respondents say they have reduced the bag size since 2018
• 92% of survey respondents indicated that they did not shoot snipe before 30 September
• 32.4% also indicated that they had reduced the snipe bag size
• 49.8% of respondents indicated that they had undertaken habitat management for both species, predominantly for woodcock, in the last ten years
• 30.3% felt conservation efforts for migratory ducks and waders would cease if a species was removed from Schedule 2.1, indicating impacts on habitat retention, habitat management and predator control

• Members may wish to reference the survey results in their consultation submissions.

GWCT’s National Gamebag Census (NGC) and other recording facilities

The National Gamebag Census provides a means through which shooting estates in England, Wales, Scotland and Northern Ireland can submit information from shooting and gamekeeping activities on the numbers of each quarry species shot annually. It also enables the recording of habitat initiatives and predation control, adding vital dimensions to understanding the relationship between shooting activity and conservation effort. The NGC scheme is voluntary, so we are extremely grateful to all the owners and keepers who send in their returns at the end of each season. Nevertheless, the more returns our members can submit to the NGC, the more we will understand the relationship between shooting activity and conservation effort. This will allow governments to make informed decisions and avoid introducing disproportionate regulation.

• Members may wish to say that they already submit NGC returns, or by recognising the need for increasing the evidence base, indicate their commitment to joining the NGC scheme.

The GWCT is already providing app-based recording for practitioners to record species sightings or evidence of good practice, and we are working on extending practitioner science recording. This is well established in Scotland (see here) and we can use this technology to assist future bag returns.

• Members may wish to draw attention to GWCT’s work on providing novel bag recording approaches.

Adaptive Harvest Management

Perhaps most importantly, GWCT favours immediate dialogue with governments and agencies to work up an Adaptive Harvest Management framework before consideration of restrictions or bans indicated in the consultation. This approach is laid out by NatureScot (NS) in its document linked to the consultation. We recognise that the application of their approach needs consideration in relation to the individual recommendations made by Defra and NRW for England and Wales, but this should not deflect from the broad principles. NS describe Adaptive Harvest Management in the following terms:

“We do not have evidence to show that there are any bird species in Scotland where the pressure from hunting is material in the population declines; there is a paucity of information both in terms of bag returns and changes to hunting effort. For our [adaptive harvest management] recommendations to deliver the desired outcome and indeed have the possibility of enhancing populations of these listed species, there needs to be a change to bag-record keeping and a coordinated plan prepared by the hunting sector, to make this work.

“The development of a co-designed plan and its effective management and delivery, is something that our Shared Approach should be able to guide.”

• Members may wish to signal support for developing an Adaptive Harvest Management approach before the imposition of precautionary restrictions and bans.

Overall, the BASC position is the same as ours. The evidence does not demonstrate that hunting is a primary driver of population change, nor that legislative restriction would deliver a meaningful conservation benefit. They believe that a collaborative, sector-led approach will foster greater trust, ownership, and compliance than legislative change. Our only proviso is that this needs to be evidenced by significantly more bag and conservation returns through the NGC, app recording, BASC’s Green Shoots and other recording facilities. 

• The GWCT recognises that the British Association for Shooting and Conservation (BASC) collates info on wildfowl shooting data. Members may also wish to review BASC’s views on the consultation to supplement their responses to consultation on individual species.