DEFRA’s consultation on their proposed gamebird regulation is a shocking example of pretending to do something worthwhile whilst failing to do anything much at all.
This is the worst consultation from government I have ever seen – it is so unshamefacedly biased.
If we hadn’t all got used to it by now it would be profoundly shocking. No stop! It is still profoundly shocking.
But it only takes a matter of minutes to respond so I have, and so have hundreds, maybe even thousands of Wild Justice supporters and others. The Wild Justice suggestions for responses are here (click here) and extracts from my own personal response are below. You should have all day to respond but closing times for consultations are a bit erratic. Please do respond if you possibly can.
Q A1:
I consider that many of the excluded sites are vulnerable to non-native gamebird releases and you have provided no information to back up your view. I have personal knowledge of some of the sites and I know that they are sensitive to eutrophication, some have important reptile and amphibian populations, and many have large areas of high quality habitat.
The starting point for the ‘interim’ measures must be to include all sites unless proven to be invulnerable. DEFRA has had since late October to make that case and have failed to do so in this consultation.
Q A2:
The DEFRA position is completely divorced from the scientific information available.
The Madden and Sage review did not come up with any studies that support this short distance, and that’s even though that review largely ignored many of the potential impacts of non-native gamebirds. DEFRA’s suggestion is simply made up and is too short.
The structure of this consultation has largly excluded evidence from ordinary people who have gamebirds running around in their gardens, causing damage to their vegetables, plants and eating the bird food they have put out for wild birds, at distances far further than 500m from releases pens.
It is a commonplace observtion by birdwatchers that Pheasants are often seen on nature reserves on which they have never been released and which are well over 500m from any release pens.
A 500m buffer zone is laughable, partial and biased to the wishes of the very interest group whose activities have got DEFRA into this problematic area.
I propose a 1km buffer zone but I could make an argument for a much wider one very easily.
Q A4:
These density limits are unenforceable and in any case do not necessarily limit the numbers of gamebirds released nor do they necessarily do anything to reduce ingress to N2K sites.
No releases should be allowed on any N2K sites or in the buffer zone, and the buffer zone should be at least 1km in width.
Q A8:
The important thing is to prevent releases on or within 1km of all N2K sites
Q C1:
There should be no releases of non-native gamebirds on N2K sites or within 1km of their boundaries for the next five years. Only if sufficient independent research is carried out should relaxation of this regime even be considered.
Simples!
Q D1: Very dissatisfied
Q D2:
This consultation is biased in the questions it asks (why no questions on economic benefit to the public of curbing releases or to game releasers away from N2K sites?), misleading and not science-based on the position it takes (the perpetuation of the myth that there is evience that a 500m buffer zone would protect N2K sites from damage) and nugatory in the impact that it would make on the total numbers of non-native gamebirds released in or around N2K sites.
If DEFRA persists with this approach then I would contribute gladly to any further legal challenges of their lawfulness. DEFRA is failing in its primary role of protecting the environment.
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I have responded to Defra on this consultation very much on the lines you have suggested Mark. When I went through it I too was shocked at how grossly biased the questions are and how slanted they are in favour of the shooting brigade.
One really does not expect this blatant support for the party whose activities are largely the subject of this consultation. So much so, it starts to defeat the whole purpose of the consultation. One might expect this degree of bias in a third world country with a military government in charge, but not in this country where “fair play” used to be a tradition in public service.
At least this confirms that this very rotten Westminster Government will support, those who like to kill maim and injure our fellow creatures for the fun of it, through “thick and thin” and regardless of fair play.
I wonder if this very biased consultation could almost be a case for the Ombutsman?
I too responded along the lines WJ suggested and think the consultation was bloody awful with its inbuilt biase towards the current unacceptable status quo. Frankly it is appalling that DEFRA starts from such an awful position rather than one that is relatively neutral or favouring the precautionary principle, shows where their interest lies. I think the idea of politicians being governed by the idea of fair play was a myth but even so this government takes the biscuit on myth busting.
Unlike many I am not opposed to all shooting but driven shooting of all types has to go.
Obviously we need to see how Defra responds to their consultation.
Surely they must understand that they will continue to be challenged if their response is unacceptable with regard to the broader elements highlighted in this blog; by the attitude of the general public and by Wild Justice in particular.
An Industry that feel it needs to release 61 million non native gamebirds each year into the great beyond needs to be held to proper account.
I can sense the need for a further crowd funding initiative, I for one will be happy to contribute.
I completed with a few minutes to spare.
We had a slightly chewy cock Pheasant from 2019/ 20 season for tea.
Submitted. I kept reminding them that they had to make the regs more restrictive or they wouldn’t be complying with the court ruling. I also pointed out in section D that the whole form seemed to be biased towards the shooting industry, which is composed of the natural supporters of this government, which is a very serious thing for the civil service to do.
” largely excluded evidence from ordinary people who have gamebirds running around in their gardens, causing damage to their vegetables, plants and eating the bird food they have put out for wild birds, at distances far further than 500m from releases pens.”
Sums up our situation to a ‘T’. Four female & one male pheasants this morning and we are miles from any release pen.
Plus I have learnt a new word – “nugatory” – thanks Mark. I have filled in the consultation.
It took a while, and a ruler, but response is now in.
“gamebirds running around in their gardens, causing damage to their vegetables, plants and eating the bird food they have put out for wild birds”
Pheasants are also partial to supplementary ruminant feed/sheep nuts.
As far as I can ascertain the nearest pheasant shoot from me is ~5km.