The GWCT has been represented on the Technical Working Group and consequently we are happy with the approach taken to identify and test candidate spring traps suited to UK stoats and UK working conditions.
Table 1 of the consultation document states that the DOC200 and 250 traps will be approved for stoat in a run-through configuration. The TWG agreed that the DOC200 and 250 traps should be approved in a run-through configuration for stoat only if they were tested as such in their own right; it would not be safe to ‘read across’ from run-through tests on the DOC150 trap.
We suspect that manufacturing capacity is currently insufficient to allow a rapid transition. We believe that there could be ca. 250,000 Fenn traps in use in the UK. Two of the trap-types to be approved for stoats after 2018 must be imported from New Zealand. The third manufacturer (Tully) is a start-up company – they will presumably answer this consultation and indicate their manufacturing capacity. It seems unlikely that any of the three manufacturers/importers will commit to any business plan until the outcome of this consultation has been announced, and expansion of their capacity would require a considerable degree of confidence in the market.
For these reasons, availability of AIHTS-compliant traps will clearly be relatively small in 2018-19. Without investment to increase capacity, it could take several years to supply enough traps to replace those being outlawed. This argues in favour of a transition period, to allow the switch without penalty to the trap-user. Trap-users are understandably reluctant to commit resources to unfamiliar traps until they have had opportunity to try them in small numbers. However, we appreciate that there is a difficult conundrum here. Manufacturers, importers and retailers need certainty in the regulations and order-book confidence to make investments, but trap-users are reluctant to commit expenditure while they imagine that the choice of compliant traps could be wider in the future. This argues in favour of an early cut-off date for outgoing traps, with no transition period, to force change. We do not currently have a solution to this dilemma, but it has implications for the impact assessment, discussed below.
As suggested above (Q1), implementation of AIHTS by tweaking existing legislation will leave an ethically inconsistent and confusing regulatory framework. We would encourage Defra to allocate resources to validate all their pre-existing spring-trap and live-trap approvals through humaneness testing, across all legitimate target species. We note that some current approvals were made purely because the trap in question was as powerful or more powerful than other traps already approved in the UK for the same species, not on the basis of any testing (e.g. approval of the DOC200 for mink).
It will be necessary to remove rabbit from some current trap approvals (BMI Magnum 116, Kania 2500) because there are no circumstances in which it is possible to trap rabbits while excluding stoats.