Common pheasant Phasianus colchicus, huge group of individuals in a field RSPB (rspb-images.com)
Today’s blog is written by Chris Calow, Species Policy Officer. He provides an update on what two recent Defra announcements mean for gamebird licensing in England and what more needs to be done to better protect our native wildlife.
History of regulation of gamebird releases on protected sites
Last autumn I wrote a blog explaining RSPB’s call to UK Governments to licence release of gamebirds as the only way to address a range of issues associated with large-scale high-density shoots. The RSPB was recently consulted by Defra on the changes they have made to the licencing scheme for releasing non-native gamebirds – Pheasant and Red-legged Partridge - on protected sites in England. Here I share our views on what more could be improved.
Since 2021, releases of gamebirds on European protected sites, or within 500m of their boundary, in England have been regulated. Following the 2022 outbreak of Highly Pathogenic Avian Influenza (HPAI), in 2023 Natural England announced further restrictions on releases on or near to protected areas to reduce the disease risk to the species for which these sites were notified. This meant that on Special Protection Areas (SPAs) an Individual Licence with bespoke conditions was needed to release gamebirds. Releases on Special Areas of Conservation (SACs) could continue under General Licence as they had the year before.
The RSPB agreed with the principle of these restrictions but highlighted that they did not go far enough. Whilst we support the ambition of protecting our most valuable sites for nature by restricting gamebird releases in these areas, the use of a General Licence is a blunt tool that does not deliver the desired outcome.
Concerns about decision making and reporting process
We also had concerns that the decision-making process to grant Individual Licences for releases was opaque (most of our Environmental Information Requests were refused) and inconsistent with Natural England advice. Extraordinarily, advice provided by the Game & Wildlife Conservation Trust (GWCT), an organisation which promotes game shooting and management was favoured over that of the Government’s own advisory body for the natural environment. On top of that, Ministers with known shooting interests were ultimately responsible for the decision-making which at the very least, could reasonably be seen to perceived as a conflict of interests (as set out in the Ministerial code[1]) We weren’t the only ones concerned about this and Wild Justice brought a successful legal challenge against Defra, which admitted that the issuing of these licences was unlawful because the ministers involved could show ‘no cogent reasons’ why Natural England’s advice was not heeded.'
Other concerns related to a lack of up-to-date information on the numbers, location and species makeup of reared gamebirds. The UK Government has announced that from this autumn it will be a legal requirement for all bird keepers (in Great Britain) to register their birds on the Animal Plant and Health Agency (APHA) poultry register and to update annually. Registered birds are an important data source for both disease control as well as monitoring the total captive bird numbers in Great Britain and understanding where birds are released. This very welcome change is exactly what the RSPB asked for in our consultation response. However, further work is required on compliance...and we will be watching closely to see whether the new requirement is adhered to, finally giving us a clear picture of the scale of the gamebird industry.
Common pheasant Phasianus colchicus Ben Andrew (rspb-images.com)
The 2024 Licensing scheme
This year the licencing scheme has changed again, with 30 SPAs no longer requiring the use of an Individual Licence and a new decision-making tool being used to help make risk-based decisions on other SPAs. This was based on ‘expert opinion’ which ignored a lot of published evidence on HPAI and gamebird movements. The RSPB declined to participate in this process. This is not the place to go into all of the changes and our concerns, so I will concentrate on one SPA on which gamebirds can this year be released under a General Licence, as an example. Flamborough and Filey Coast SPA is home to our Bempton Cliffs reserve and, at the height of the breeding season, a colony of over half a million seabirds.; Defra know this has they had access to seabird colony count data for the SPA, collected by the RSPB.
It’s a spectacular place which has to be seen, (and smelt!), to be believed. Here you’ll find the largest colony of Kittiwakes in the UK and our only mainland breeding Gannet colony as well as thousands of Guillemots, Razorbills, Puffins and more. The entire colony here has been relatively unscathed by the current outbreak of HPAI. That’s not to say that there have been no deaths but compared to other seabird colonies the birds here appear to have got off lightly.
We believe that gamebird releases here should continue to be strictly regulated but Defra have come to a different conclusion. This year, releases here will only be lightly regulated under a ‘General Licence’, which will have no application process, and conditions which are not bespoke to the site. Defra’s Habitat Regulations Assessment says that the likelihood of gamebirds coming into contact with the seabirds is low because the seabirds mainly stick to the cliff edges and cliff top, however the cliff top is a place where the two groups of birds could certainly come into contact. Defra also acknowledge the presence of ‘bridge species’ (which could transfer the virus from gamebirds to the designated species) in the area, in this case gulls, but seem to dismiss their importance.
What about Mallard releases?
We also have concerns about the role of Mallard releases in the spread of HPAI which we have flagged with Defra and the UK Statutory Nature Conservation bodies. Unfortunately, these releases will not be regulated by this licencing scheme. Mallards are particularly susceptible to infection with HPAI and can shed the virus asymptomatically for up to three weeks and therefore once released, pose a risk to wild birds using waterbodies, including on protected sites. These Mallard releases will continue completely unregulated in 2024.
There is considerable uncertainty as to how many captive-reared Mallards are released in Great Britain annually, but it is thought that numbers have been rising rapidly since the 1970s (Champagnon 2011). Madden (2021) analysed 12 datasets, mainly from 2016, to calculate an annual release of 2.6 million (range 0.9-6.0 million)
What would a good scheme look like?
We acknowledge that some management linked to gamebird shooting can benefit native wildlife, particularly in landscapes that have been heavily modified by intensive agriculture.
However, we have growing concerns about the environmental impact of large numbers of non-native gamebirds being released into the countryside, as highlighted previously.
Further regulation and better enforcement of existing rules are essential to minimise the adverse impacts of gamebird releases. The RSPB is calling for governments across the UK to license all releases of reared gamebirds (not just those on protected sites), underpinned by a statutory code of practice, with mandatory reporting of movements and releases. We believe statutory licensing is the only way to achieve these changes and we are keen to engage with other interested parties in the design of future licensing regime in all four UK countries.
A new licensing scheme will be in place for 2025 in England and we will continue to advocate for it to contain meaningful conditions that address environmental impacts and improve reporting and compliance.
[1] https://www.gov.uk/government/publications/ministerial-code/ministerial-code#ministers-private-interests