General Licence response

If you wish to respond to the consultation on the General Licence (in England) then you have until the end of next Monday to do it.

The General Licence does what it sounds like it does. Instead of having to apply for an individual licence to kill some wildlife, and justify it on a case by case basis, there are some species, for some reasons, that can be killed by any of us (as I understand it).  This doesn’t mean that we can kill a Carrion Crow, for example, just because we don’t like them (I do like them) but it does mean that you or I could rely on the provisions of the General Licence if someone asked us why we had shot that Crow and we wouldn’t need our own bit of paper to show that we were legal.

At one level, I feel uncomfortable about the General Licence – killing a Carrion Crow isn’t a good thing, it is something to be avoided if we possibly can (I think). But, in the real world, do we want a large bureaucracy, or even a small one, to address the thousands of Crows and other birds killed by gamekeepers and farmers every year for what they think are good reasons?  We will all have our views on that.

When I worked for the RSPB we did, as an organisation, kill some species on some nature reserves relying on the General Licence.  Most of these birds, as I remember it, were Carrion Crows (with a tiny number of Jackdaws and Magpies too).  The number of birds wasn’t negligible – and a single bird wouldn’t be negligible – but the total number across over 200 RSPB nature reserves would amount to fewer than would be killed on many individual shooting estates.  And, as you can imagine, there was a process, with the RSPB, for authorising which nature reserves did predator control and which did not.  Our aim was to minimise the number of birds (and mammals) we killed each year.

There is always strong opposition from the shooting and farming community to any changes to the General Licence provisions but it seems to me to be sensible to review them from time to time. And that’s what the consultation does.

A few years ago, House Sparrow and Starling, both rapidly declining species, were removed from the General Licence. I haven’t noticed that UK agriculture has bombed as a result.

There are lots of questions in the consultation, and the process isn’t completely easy as i found I had to keep switching tabs on my computer to read the consultation and then get back to the consultation response form – I believe it could have been made a lot simpler.

Here are a few of the answers I gave in my response – if you agree with me you might simply want to copy them.

Question 1(b) addresses two non-native species that are common on the continent and might make their way here and if they do, then they may, on the evidence of their impacts in Europe, cause conservation problems. The two species are Sacred Ibis and Indian House Crow. Be3cause of the serious conservation impacts these non-native species have had abroad I would much rather they didn’t get into the UK, but if they do, then putting them on the General Licence now seems to be a wise move. So my answer to Question 1(b) is quite simply ‘No‘.

Question 1(c) addresses three species which are on the General Licence under the provisions they may cause serious agricultural or disease problems: Collared Dove, Jackdaw and Jay.  Personally I would like all three removed but I just wonder whether I know enough to ask for that (see how reasonable I am!).  I know of know circumstances where Jays have caused damage to agriculture and await with interest any evidence to the contrary. So my answer to Question 1(c) is : ‘Jay should be removed. I am aware of no evidence that Jays cause serious agricultural damage or disease. It is for those who believe that this species should stay on the General Licence to bring forward evidence to justify its retention‘.

Question 1(d) addresses Jackdaw and Jay again, and whether they should be covered by the General Licence provision relating to conservation. I think they should both come off the list and so my answer to Question 1(d) is: ‘Both species should be removed from this list. I am aware of no evidence that either species causes serious problems for fauna or flora that could not be addressed through licensing on individual occasions.’

Question 29 relates to reporting of the scale of use of the General Licence. At present, a shooting estate or a nature reserve can operate under the General Licence and kill as many Carrion Crows, Jays, Jackdaws, Magpies etc as it likes and does not have to inform anyone.  If you believe, as I do, that bumping off wildlife is a moral issue – not a cut and dried moral issue, but a moral issue nonetheless – then surely you would want to know how much of this killing is taking place and for what reasons.  If thousands of Jays are being killed because they are thought to be a pest of wheat then I’d really like to know (because that is ridiculous) and a monitoring and reporting scheme is the way to do that.  Such a scheme should, of course, apply to the Wildlife Trusts, RSPB, WWT and others as well as farmers and shooting estates.  I think the numbers revealed would be much higher than most members of the public realise – that might influence how people respond in future consultations such as this one.  Clearly reporting increases the burden on those who exercise the licence, and they will moan like hell about ‘red tape’, ‘gold-plating’ and ‘bureaucracy gone mad’ but that’s just tough! The alternative to this proposal ought to be to remove many more species from the General Licence so that such reporting would become part of the individual licence procedure – a much more onerous way to get the data.

So my answers to these questions are:

Question 29(a): ‘YES – I strongly support this proposal.’

Question 29(b): ‘Mandatory – I cannot see any reason why the scale of licensed killing of wildlife should not be reported by those benefitting from the General Licence. I would expect government then to publish annual reports on the level of such activities. ‘

Question 29(c): ‘NO. Move to mandatory reporting straight away.’

Question 29(d): ‘We could scrap the General Licence and make all killing of wildlife controlled by individual licences – that would be more onerous. And that is what the Regulatory Impact Assessment should consider as an alternative.’

Question 29(e): ‘You should proceed with plans to gather information on General Licence use.’

If you believe, as I do, that the killing things is sometimes a necessary evil, but it is still an evil, then you will want to approve the suggested change to the wording proposed in Question 31 which requires people to have tried toscare things away and found that to be ineffective before killing them.  That is clearly the aim of the present wording but it is not sufficiently unambiguous. So,

Question 31(a): ‘NO’.

 

Well, I hope that is some help to some of you. You may not agree with me, in which case submit your own responses. My advice would be to get on with it as the forms etc are not the most user-friendly.  We can expect that there will be a lot of responses from shooters which are not exactly the same as mine here. Only by using your voice and responding can your voice be heard.  be a player – participate!

And I’d welcome any comments here on other questions, answers and views.

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22 Comments

  1. Peter Powell

    i run a dairy farm in mid wales and make regular use of the general licence. because of the feed we are giving to the cows during the winter we have a huge flock of carrion crows that feast on the maize and also on the worms from the fields where our slurry is spread. this ongoing winter feed keeps the carrion crows well fed all winter and i believe completely that this is making there survival rate higher than natural and allowing much smaller territories. i also have two pairs of lapwings on the farm and as far as i can tell they haven't managed to raise a chick for the last few years, without extensive monitoring i would take a guess that eggs and chicks are being lost to predation as seems to be the case at many other sites. Now i make use of the general license to shoot crows (to not much effect the last few years) and this year i have put in a letterbox trap which i seem to being having more success with. anyway the point i wanted to make is that with more recording and paperwork these predator control is likely to happen. in an unnatural system (dairy Farm) there is huge potential for generalists to thrive, and this can be o the detriment of other species.
    Peter
    P.s i also use the general licence for shooting woodpigeon, possibly the most carbon minimal wildlife friendly ways of putting meat on the table.

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    • Bob Philpott

      Peter's comments do bring home to me my feeling that General Licences are the least known and least understood parts of wildlife legislation (except by professionals).

      So why did Peter's comments make me think this. I personally have little problem with people shooting woodpigeon for food and it is probably much less impactive than driven shooting of pheasants or grouse. However, the General licence doesn't actually let you shoot it for food but only when it causes damage to crops etc. At the same time it is listed as the only species that once shot you can sell it at any time of the year.

      I don't really want species listed so that they can be shot at any time for food or otherwise but if there was one it would probably be the woodpigeon. What it does show is that we need very simple licence conditions that can readily be understood by anyone (especially as they do apply to all of us).

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    • Farmer Pedant

      "....also on the worms from the fields where our slurry is spread"

      Look after those earthworms Peter!! If they are coming to the surface post slurry-spreading, then it is a very good indicator that you've probably applied too much and have drowned them out.
      On clay loams and clays, I've found through past experience that applying no more than 30 m3/ha (2700 gallons/acre) in Spring and 39 m3/ha (3500 gallons/acre) in Summer as a single application, during good soil conditions, significantly reduces earthworm losses. Drowned earthworms can also be indicative of soil compaction.

      I agree with many of your other points though.

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    • Circus maxima

      Works for Ravens too, a breeding pair will keep a large flock at bay and this actually works to protect lambing.

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    • Circus maxima

      Feed stock is very expensive. Why are you not using covered creep feeders? If you deny the birds the food source they will go elsewhere.
      The general licence is too easy to use.

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      • Farmer Pedant

        Where would the sparrows and starlings go ?

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  2. John Miles

    Many years ago on an RSPB reserve pairs of crows were taken out along an area of marsh presuming that this would help the waders to breed more successfully. What actually happened was that non breeding crows descended on the marsh and removed most of the wader's eggs. The following year the breeding pairs of crows were left and waders produced a lot more young. What was learnt then was territorial crows are less damaging than having a pack of non breeders descend on your waders. Sadly this story seems to have been lost especially when Goshawks and Buzzards now prey on the crows!

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    • Peter Powell

      this could be very true, and im sure a breeding pair of crows keeps other crows out. On our farm the sheer amount of food available to them from sheds and silage clamps, spills of grain etc. means that the territories the crows are holding are very small or they seem o have become very tolerant of other crows invading their territory.

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  3. kie

    Latest figures show 153 Crows killed on 4 reserves by RSPB to protect ground nesting birds...

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  4. Keith Cowieson

    If it ain't broke, don't fix it.

    All for regular reviews such as this consultation, but there doesn't seem to be much evidence base behind some of the proposed changes. In the absence of such compelling evidence, the status quo should be maintained.

    For an alternative viewpoint, I found the GWCT's response more compelling, see here - http://tinyurl.com/le435c7

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    • Jonathan Wallace

      I was interested to read this in the GWCT's response to question 1(d):

      "Jackdaws remain predators of young birds and are particularly adept at working in family groups distracting the adults to prey on the young. Jays remain effective nest predators"

      It is surely the case that any predator that has not yet gone extinct is "an effective predator" so how is this a justification for shooting them on grounds of protecting fauna and flora? By this argument perhaps the Blue Tit should be added to the General Licence as an effective predator of moth larvae?

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      • Keith Cowieson

        Jonathan,

        I expect it is the same logic deployed for controlling foxes and corvids to protect breeding waders, and gulls to protect breeding terns. Where unnatural concentrations of predators/scavengers exist, and are having a deleterious effect on other threatened/declining species, then conservation often demands that humans, in the absence of apex predators, step in to help restore a trophic cascade and thus balance.

        I imagine the GWCT has shed-loads of empirical evidence and peer-reviewed scientific studies supporting their views. The Upland Predation Experiment, see here - http://tinyurl.com/mclabac, 20 years of experiment & study at the Allerton Project, Loddington, see here - http://tinyurl.com/nqjkq97, or during the 40 year Sussex Study, see here - http://tinyurl.com/bn8d4xk, all spring to mind.

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        • Jonathan Wallace

          Hi Keith
          If it is being argued that a species should be on the general licence for the purposes of the protection of fauna and flora then I would suggest it is necessary to give some kind of indication as to how that species is a threat to the conservation of fauna and flora. The GWCT response does not do this with respect to Jackdaw and Jay, it simply says that they are effective predators. That by itself is not a good enough reason to claim they need shooting. As my slightly flippant remark about Blue Tits was intended to suggest, our avifauna includes large numbers of effective predators most of which are not subject to demands for their control, so being a predator is not, by itself, reason enough to require control.
          If GWCT considers that Jackdaws and Jays are affecting the conservation status of other birds then that is what they should say and they should point to the evidence for the assertion. If they do not do so then their argument that they should be controlled is simply a lazy expression of a lazy view that any predation of birds is bad and therefore the predator must be shot 'to preserve the natural balance'.
          The links you provided are very interesting but none of them has anything to say on the need for Jays or Jackdaws to be controlled. The Allerton project document makes rather oblique reference to predator control but is mostly focused on a wide range of other measures implemented to boost biodiversity and as far as I can see the Norfolk Estate article does not mention predator control at all (though I accept that the estate probably does carry out some). The document on the upland predation experiment certainly talks about predator control but makes no mention of Jays or Jackdaws.
          Consequently you and I can both make assumptions about whatever logic may lie behind GWCT's view that Jackdaws and Jays should be on the General Licence for the purposes of protecting fauna and flora but in their response to the consultation they have certainly failed to make any cogent case for it.

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          • Keith Cowieson

            Jonathan,

            Fair point - neither of us know the logic underlying their response.

            On the links, Michael McCarthy's article stresses the outcomes, but not all the treatments. A fuller account of the elements of the Sussex Study (and others) is contained within Dick Potts' Partridges, New Naturalist, see here - http://tinyurl.com/ng2qa6f - a very worthwhile read that goes far beyond the subject Partridges.

            At the Allerton Project, the management regime has been experimentally and systematically deconstructed, then reconstructed, to see which treatments were most effective in boosting/restoring biodiversity. I am not aware of all the papers that the Project has spawned, (though they are probably listed on the GWCT website), and perhaps they were referring to other studies that flag up the detrimental effect that Jays have on red-listed, priority, BAP species, see here - http://tinyurl.com/p9oqxom, and here - http://tinyurl.com/lqjnna8

            Anecdotal of course, but a farmer friend of mine has described vividly the destructive effect that flocks of Jackdaws have on his crops - neatly nipping off new young growth of peas (I think). And I expect most of us will have seen the Springwatch footage of Jackdaw predation of LRP - http://tinyurl.com/k3lskzk - certainly a very effective and persistent predator and presumably this behaviour is also replicated against other, more threatened, species as well.

            My overall point was that although the consultation proposed several changes, it proffered little evidence to support them. I found the GWCT consultation response more compelling.

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  5. Mark W

    Some years ago I met a local farmer on his way down the lane, gun over shoulder. Asking him what he was after, he said "crows"!
    He was going to shoot them in their nests in "those trees down there" - yes, the rookery.
    On mentioning that crows nest by themselves and he was heading for a rookery his reply was that it was far easier to shoot the "crows" that nest all together than try to find all the scattered nests of the other "crows"!

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    • Keith Cowieson

      Perhaps off to shoot the 'branchers', the young rooks just before they fledge. An age old tradition to help protect growing crops and other fauna. Also provided the raw material for Rook Pie, another carbon minimal wildlife friendly way of putting sustainable meat on the table - "Four and twenty black birds, baked in a pie......" - see here http://tinyurl.com/n3xmt5g

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  6. Oliver Craig

    Its the same tired old argument in this country that predators and supposed pests have to be " controlled " by small narrow minded interests. A simple acceptance that
    that predators and all creatures have been on this planet a lot longer than us and a
    balance has been created over the millions of years. As long as large areas of Britain
    are set aside so that some idiot with a gun can pay thousands of pounds just to kill
    birds this problem will not go away.
    Regards,
    Oliver Craig

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  7. Dylanben

    What puzzles me is why those gamekeepers who buy their pheasant poults in when they are of a good size, rather than being reliant on wild-bred stock, need to run Larsen traps, funnel traps etc.. I would go so far as to question whether this is a legitimate practice in terms of the General Licence. What exactly are they seeking to protect? Their deliberate attempts to lure the existing territorial pairs of their target species into their traps is self-defeating when all it does is create vacancies for others to move in - as has been so well described in earlier correspondence. It is my belief that these practices are often followed, unthinkingly, as a matter of course. as distinct from having any valid and substantive basis.

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    • Mark

      Dylanben - welcome and thank you for your comment.

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  8. Chris W

    I really think that as long as there is no threat to the status of the species on the list and there is the reasonable argument they could foreseably contaminate crops with diseases that can harm people or further threaten far less adaptable/damaging/invasive species... and if the killing is done efficiently and with respect and care to minimize suffering to the animal, and esp if they provide a low carbon emission low impact meal, and some bush craft/sport in the process all the better imho (it is certainly far more moral than most of the way a lot of the food is processed both home, and around the world). So, then let land owners manage their own estates, and bush craft/wild food enthusiasts have some avenue of approach to put meet on the table and help a neighbour in the process. Shouldn't we all be concentrating on bigger, more real moral and environmental problems/threats like GMO's which threaten to contaminate the genes of normal crops or pesticide and herbicides, or the illegal shooting of apex predators such as raptors, or ..... take your pick, but

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  9. Chris W

    Whichever side of the fence you sit on, whether it be never kill nature unless your government has given you permission personally, or, you believe in some freedom of humane individual choice on this matter, the general licences do strike some balance. The biodiversity around us, is for all of us to enjoy and benefit from... it's all of ours, so, privided that my right to take listed air rifle quarry species,as myself and other property owners/estate managers see fit, does jot impinge on anybody elses right to enjoy and benefit from our outstanding natural beauty, and abundant diversity, one should not limit the others freedom to do so. Too little freedom in either regard is a complete denial of our natural human rights, and sovereign rights. Even arguably duty when the species in question are a damaging invasive species, btw I won't control Jay's, they are not personally a problem species, but I do try to limit Jackdaw numbers but only take younger ones and leave the breeding adults well alone, they are certainly a nuisance to both myself and other species at the very least, with large populations in small territories, out competing less successfull bird species, as well as damaging my property, in the process of stealing relatively vast quantities of grain, and predating fledglings of species listed as critically endangered on my small patch of land.

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  10. Chris W

    Ps. IT DOESN'T USUALLY TAKE MUCH CONTROL TO GET CORVID NUMBERS DOWN ON MY ESTATE, THEY QUICKLY LEARN THE CONSEQUENCES AND ARE INTELLIGENT ENOUGH TO STAY AWAY FOR THE MOST PART, HOWEVER SCARING THEM HAS NOT PROVED EASY THEY SOON LEARN A THREAT OR NOT, AND REMEMBER BOTH THREATS AJD FOOD SOURCES FOR IN EXCESS OF A YEAR, AND ARE ADAPTABLE AT FINDING ALTERNATIVES WHERE THEY ARE LESS PROBLEMATIC TO INDIVIDUALS

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