Do you agree or disagree with the approach undertaken in the impact assessment?

Disagree

We suggest the approach taken in the IA is unsafe in several respects.

Although we do not query the concern of the British public for animal welfare, we observe with amusement that the “significant evidence” of public concern amounts to a “small survey” involving just 278 respondents! Willingness-to-pay surveys are notorious for exaggerating public values, largely because the questions isolate issues rather than asking the respondent to allocate a finite budget among conflicting demands. Also, the Kehlbacher et al. study related to quality of life for farm animals before slaughter, not to the slaughter method itself, as in the present case!

Accepting, however, that the public - including trap users - are concerned with the humaneness of traps, the IA is presented as a balance between public interest in animal welfare and costs to small businesses (shoots). This is over-simplistic because there are also public interests in the conservation of wildlife other than game species through control of predators including stoats and weasels; and in pest control (rats and grey squirrels). There is very good scientific evidence that predator control on gamekeepered estates contributes substantially to the viability of several wildlife species in Britain.

Furthermore, substitution of one trap for another can only be as uncomplicated as suggested in the IA if the traps are equally effective; that has yet to be determined. Loss of effectiveness would be a serious cost that is not easy to monetarise but would have ramifications into regional socio-economics and conservation. The importance of traps in the pest control sector is also difficult to quantify, but given the concerns over poison resistance and secondary poisoning, and the withdrawal of warfarin poison for grey squirrels, there is an evident public interest in maintaining the option to use effective traps in pest control.

In summary, the balance to be struck is between animal welfare on one hand; and on the other hand, immediate costs to small businesses, plus potential short- or long-term loss of effectiveness causing costs across a wider set of public and business interests.

As stated in the consultation document, if a trapper is unable to replace their Fenn-type traps by the implementation deadline, their only options would be to:

  1. Seek licensed use of their illegal traps. This would be granted only in exceptional circumstances.
  2. Choose not to target stoats whilst trapping other pest species. As noted above, this is fraught with problems, and would prevent a component of game management that is important, especially in the uplands and other areas with wild game interests.
  3. Purchase and use “compliant but less effective traps (e.g. baited traps)” (IA, p12). This presumably refers to the Goodnature A24 trap. This option would depend on availability not only of the traps but also of the stoat lure, which is not currently sold in the UK.

Given the initial cost and the level of public scrutiny placed on gamekeepers, it seems likely that to avoid non-compliance, there will be an initial decrease in the amount and effectiveness of stoat trapping, with consequent lost-opportunity costs for commercial shoots (particularly in the uplands), and negative impacts on associated ground-nesting bird species of conservation concern.

The conclusion of the IA depends heavily on the statement “Manufacturers have estimated that only 20% of their trade in traps is with game keeping sector, so we have reduced the reported annual sales figures by 80%.” If this information was incorrect, the estimated impact might be up to five times as great as suggested. The evidence on which these 20/80% figures are based is not given (presumably for reasons of commercial sensitivity), so we are obliged take it on trust. We would like to ask how many manufacturers contributed to this estimate, and how the estimated proportions varied among those contributing? We would also question whether manufacturers can really be expected to know the answer to this question, when sales to the end-user are handled by retailers?

The IA makes no analysis of the alleged 80% of the market who are not in the game management sector, but who have the same compliance obligations as gamekeepers. Game management and shooting organisations have reached out to their memberships regarding the proposed changes. We do not know the extent to which the other 80% of the ‘market’ are aware of the proposed changes. It is therefore a moot point whether any non-compliance and public interest concerns post-implementation will fall primarily on the game management sector.

Several of the assumptions about costs are under-estimated even in the ‘High’ scenario:

  • Assumption 1. The hourly rate used covers wages, but not other employer’s costs, which may include NI, housing, utilities, phone, vehicle running costs, dog costs, and protective clothing. GWCT calculates that a typical overall cost of employing a gamekeeper (excluding costs of predator control equipment) is £40,000 p.a. Assuming 300 days work at eight hours/day, the hourly cost would therefore be £17/hour.
  • Assumption 6. We believe the time to rebuild and deploy a tunnel would be more like 1.5 hours, assuming workshop facilities for the construction part.
  • Assumption 7. The cost of materials to build a new wood-and-plywood tunnel is now around £10 (incl. VAT). Ready-made trap tunnels for DOC traps cost approx. £60 (incl. VAT).
  • Assumption 9. DOC traps cost in the region of £35; Tully traps £30; the Goodnature A24 rat and stoat trap £115 (+consumables).

Despite the search for traps that would fit existing infrastructure, it is likely that modification or replacement of existing tunnels will be required in many or most cases. DOC traps must be strongly fastened to a base to allow setting, and will need inner baffles when used as a run-through. Although in theory it should be possible to contrive a slide-in base for DOC traps incorporating baffles, no such development is possible until the conditions of use containing baffle specifications are published by Defra. The Tully trap is longer than a Fenn trap, so particularly short tunnels and rail sets will need to be modified. The Goodnature A24 is not a tunnel trap at all, but to use it some kind of add-on structure to exclude non-target species would have to be contrived.

References

  • Fletcher, K., Aebischer, N.J., Baines, D., Foster, R. and Hoodless, A.N. (2010), Changes in breeding success and abundance of ground-nesting moorland birds in relation to the experimental deployment of legal predator control. Journal of Applied Ecology, 47: 263-272. doi:10.1111/j.1365-2664.2010.01793.x
  • Teunissen, W., Schekkerman, H., Willems, F. and Majoor, F. (2008), Identifying predators of eggs and chicks of Lapwing Vanellus vanellus and Blackntailed Godwit Limosa limosa in the Netherlands and the importance of predation on wader reproductive output. Ibis, 150: 74-85. doi:10.1111/j.1474-919X.2008.00861.x
  • Tharme, A., Green, R., Baines, D., Bainbridge, I. and O’Brien, M. (2001), The effect of management for red grouse shooting on the population density of breeding birds on heather-dominated moorland. Journal of Applied Ecology, 38: 439-457. doi:10.1046/j.1365-2664.2001.00597
  • Mustin K., Arroyo B., Beja P., et al. (2018) Consequences of game bird management for non-game species in Europe. Journal of Applied Ecology, in press, but available online. doi:10.1111/1365-2664.13131

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