Fersiwn Gymraeg ar gael yma
The RSPB is concerned about the environmental impacts of releasing large numbers of Pheasants and Red-legged Partridges at high densities, as we describe in this blog. RSPB Cymru welcomes the analysis undertaken by Natural Resources Wales (NRW), on behalf of Welsh Government, that proposes to licence releases. Where permitted, this would place conditions on the numbers and location of non-native gamebirds released.
We are formulating our detailed response, but many supporters have asked us what we think of the proposals. Some will want to support our e-action [link], but others have asked for more detail so they can also respond to the consultation in more detail. Our thoughts on the five questions are set out below. Your own experiences of released gamebird management in Wales will provide valuable information for the consultation, and you may feel you don’t want to respond to every question.
You can answer the questions on the NRW consultation hub or by email to Gamebirds@cyfoethnaturiolcymru.gov.uk. The consultation closes on Tuesday 20 June.
We hope that you find our comments to the consultation’s questions below helpful in writing your own response.
(Question 4) 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.
Our response: Yes, adding Pheasant and Red-legged Partridge to Schedule 9 is an appropriate and justified response to the review undertaken by NRW. The voluntary approach to self-regulation has failed to demonstrate that it can meet effectively the challenges raised by emerging evidence of environmental impacts of releases and associated management. Welsh Government and Natural Resources Wales cannot rely on self-regulation, especially given the absence of data on the scale and distribution of releases in Wales.
(Question 5) If these species are added to Schedule 9, please give us your views on whether our proposed licensing approach would be effective and proportionate?
Our response: We broadly support the proposals for licensing, in particular the strict regime of bespoke licences for sensitive protected sites. However, we do not think that a 500m buffer around SSSIs will provide adequate protection and believe that there is good evidence to justify a buffer of 1000m.
We believe that all releases should be subject to bespoke licenses (perhaps with a lighter touch for smaller releases). NRW’s own report shows that more than 90% of Ancient Semi-natural Woodland, potentially sensitive to damage by high density gamebird releases, are not protected by SSSI designation. Unless significant efforts are made in relation to enforcement, we suspect that a General Licence is viewed as authorisation to continue ‘business as usual’.
The proposals miss an important opportunity for NRW to gather more information about the scale and location of releases. All licensees should be required to provide this data to NRW annually under any licence, which would enable NRW to understand the future trends.
We support the proposal to review the licensing scheme in five years and ask NRW to make a formal commitment to that review. We do not believe that it will be possible to evaluate the effectiveness of regulation without mandatory reporting on the scale and distribution of all releases and spot-checks of releases under both the General Licence and bespoke licences.
(Question 6) We have based the proposed general licence conditions for pheasant release on the recommendations in the GWCT 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.
Our response: Our view is that in the absence of robust evidence in relation to Red-legged Partridges, it is reasonable to incorporate expert opinion. If you have experience to comment on this question, please do include it.
(Question 7) 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?
Our response: We support the need to incorporate the spatial element from the GWCT guidance, without which they will be undermined. We believe that this should be a licence condition, not just a recommendation.
(Question 8) 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.
Our response: We recognise that the risk of environmental damage is lower where smaller numbers of gamebirds are released. We believe that NRW could explore excluding some conditions for smaller releases away from sensitive sites. It is unclear how “small” would be defined and suggest that NRW considers whether such relaxation should apply around Ancient Semi-natural Woodlands.