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.