The DEFRA consultation over the general licences closes on Thursday at the interesting time of 23:45.
It appears to be a serious consultation about the way forward and it asks for evidence to back up your views. If you are thinking of responding online then you will need to allow at least half an hour to respond. If you wish to respond in writing by post then you’d better get cracking now and use a first class stamp. Here is the link to the consultation.
I shall respond as an individual and Wild Justice, whose legal challenge has shaped this consultation, will respond as an organisation. Our responses will be similar and will argue that Jay, Magpie, Rook and Jackdaw should be removed from the general licences for the purposes of protecting fauna and flora. Carrion Crow may be retained on that licence but the circumstances under which lethal control should be licensed should be much more circumscribed. I and we suggest other changes too but that is the thrust of the responses.
Right at the end of the consultation there is the option for other comments. This would be the place to point out that DEFRA has no idea how many birds of which species are currently killed under the terms (allegedly) of these general licences. DEFRA does not currently require licence returns from those using the licence nor take any meaningful action to enforce these licence conditions. There is plenty of evidence, despite lack of offficial monitoring, that in the past those relying on the licences have often transgressed from the terms of the licences and that many have poor bird identification skills.
It will, of course, be interesting to see what DEFRA comes up with for new improved general licences in 2020 and whether the DEFRA proposals avoid legal challenge. The existing DEFRA licences expire on 29 February 2020 and so time is short…
Well done to you all at Wild Justice. (Do you coordinate with Client Earth by the way? Stronger together and all that.)
I’ve put in a response to the consultation, basically saying it shouldn’t be a free-for-all like it currently is.
I responded. It’s a bit trying, because the (admittedly thorough) consultation approach asks for evidence for not doing something when the approach of the law is to require evidence to do it. And it’s pretty hard to cite evidence of lack of evidence.
I chucked in a comment advocating withdrawal of general licences as is possible in Scotland (eg Leadhills), though I suppose it’s out of scope of the consultation.