Bird flu strategy for England and Wales

https://www.gov.uk/government/publications/mitigation-strategy-for-avian-influenza-in-wild-birds-in-england-and-wales/mitigation-strategy-for-avian-influenza-in-wild-birds-in-england-and-wales

In response to this document published yesterday I said this (in a series of tweets, reproduced here below with typos corrected) and the RSPB said this (lower still):

UK context: this is by and for England and Wales. It rather ignores the fact that birds fly around between England and Wales and Scotland. For example, later in the document it talks about species of conservation concern and mentions worries for Gannets on Grassholm with no mention of Bass Rock etc.  This looks a little unjoined up to any UK nature conservationist.

However, Sec 3.6 claims that ‘detailed epidemiological assessments‘ are made at infected poultry premises to investigate source. I think this is bigging it up a bit. Biosecurity is considered & then wild birds are blamed is closer to the truth – the wild bird species are never identified.
I don’t say that to get wild birds off the hook but merely to point out that WHICH wild birds are not known. Knowing which wild birds are involved would be very  useful in protecting commercial flocks. To labour the point perhaps, I’ve never seen a Mute Swan trying to break into a poultry shed but I have seen corvids, sparrows and Starlings in their vicinities. Am unaware of any testing whatsoever of House Sparrows, Starlings for relevant bird flu virus.
Do outdoor flocks, organic flocks, free range flocks, succumb to bird flu outbreaks more than wholly captive ones? That would be interesting to know. Do we know? If the source is infected bird shit falling from the sky then those outdoor flocks might be considered more often exposed to virus. Are they more often affected by outbreaks? Has anyone looked or asked?
Sec 3.8: ‘the risk of avian influenza incursion during summer typically decreases as environmental conditions (warm, dry, high sunlight exposure) can reduce virus survival in the environment‘ looks rather out of date. The reason we are talking about this today is that bird flu has been with us all summer in unprecedented levels (or at least with unprecedented impacts) in wild birds. The danger, obvious from early July or before, is that bird flu is no longer reliably absent in summer & comes back in autumn. Sec 3.8 is complacent and off the pace.
The 2nd (long) sentence in Sec 3.8 is written as though we know something about this whereas we know practically nothing about it. These two governments couldn’t give us an estimate of any of those parameters. Which it would be useful to have – not least to protect poultry.
Sec 7.4 is welcome and very new. It shows that months of nagging by a wide range of naturalists & conservation organisations have had some impact.
First bullet – by George they’ve got it! Now Defra needs to get on and do it. Second bullet – yes
Third bullet – yes 
Fourth bullet – yes.
That section 7.4, and those bullet points now need to be backed up by proper research. Writing them down isn’t quite enough.
Jumping ahead to Sec 12.1 – ‘APHA carries out year-round avian influenza surveillance of dead wild birds submitted via public reports and warden patrols…‘. Yes it does, but it’s very poor indeed to answer any of the questions in Sec 7.4.
It isn’t sampling species in any meaningful way. This needs to be improved. Why aren’t wild birds sampled in vicinity of poultry infections, for example?
But primarily, how would we know the things in Sec 7.4 with the surveillance we have at the moment? Clearly, we wouldn’t, because, clearly, we don’t!
Moving on again, to Sec 14.
Sec 14 says that something great has been set up. It’s unclear what has been set up except it rather looks as though a load of government labs are involved and rather few ecologists. Maybe I’m wrong, but I would bet money it won’t answer the four bullets in Sec 7.4 unless it has a strong emphasis on birds as well as viruses.
Sec 15
Sec 15.3 is the most E&W blinkered statement possible – it’s as if Defra, APHA and the whole of Wales are unaware of what has happened in Scotland this summer. No wonder the Scots…
Sec 15.5 mentions White-tailed Eagle and Hen Harrier specifically & says birds of prey ‘are susceptible to avian influenza and can be infected if exposed, either directly through contact with other birds, through the ingestion of infected material where the birds of prey feed on other infected birds or scavenge infectious material, or indirectly via contact with environmental contamination‘. Probably true, but the  importance of each route is completely unknown – it would be useful to know.
But if true for BoPs then presumably also true for a wide range of other birds, particularly the scavenging bit. Corvids and gulls especially. Carrion Crows? The clue is in the name. Now you won’t see Hen Harriers forcing their way into poultry sheds, despite the name. And nor will crows and gulls. But those two  groups are numerous, widespread, and fly around a lot.
I wouldn’t bet much of my own money on crows & gulls being vectors – but I wouldn’t bet against it either. If I were a funder, I would invest in studies. But I’m not, so I can’t.
Sec 16 – this is welcome & new. It is though, all very wooly and we’ll have to see what actually happens. Sec 16.7 at least recognises that there is something going on, even something starting, that is significant in nature conservation terms as well as potentially commercially
The document has ‘got’, to some extent, the seabird thing but it isn’t just a seabird thing. All those Barnacle Geese dying last winter in Scotland (but almost within sight of England!) also demonstrate what might happen.
Let’s hope that quarter of a million Knot which pass through The Wash each autumn don’t pick up bird flu in the UK. I’ll skip Sec 17.
Sec 18 – ringing and shooting.
Sec 18 – you can ring birds. Sec 18.4 – I think it’s probably right that curbing wildfowling wouldn’t have much impact on anything. However, shouldn’t all those dead birds that are retrieved, of several species, be analysed to give a better picture of virus by species? Seems obvious to me.
The emphasis of the consideration of driven shooting is whether the birds go very far. That’s a bit blinkered? If gamebirds get avian flu, however they get it, and they can pass it on to other birds, then releasing millions of gamebirds is greatly adding to the disease reservoir, isn’t it? Why would we do that?
But since Defra and Wales left it so late to bring this document together then they couldn’t say it would be sensible to ban gamebird releases because most releases have now happened. They’ll be keeping their fingers crossed that virus isn’t found in gamebirds. But then again, how many will be tested? Surely, again, having not stopped releases, shot birds should be analysed to build up a better picture? Seems pretty obvious…
Sec 18.6.2 says that a risk assessment of gamebird releases will be done by APHA – bit late! Feel free to use mine above, so allowing gamebird releases is based on the absence of a risk assessment. Hmmm.
And finally, Sec 21. You can leave dead birds lying around if you like. So we’ve forgotten, have we, the possibility of scavengers being important? What do scavengers scavenge? 

It’s good to have this document but it reveals the lack of real thought that has gone into this issue. Defra has been ‘asleep at the wheel’ as RSPB said 40 days ago markavery.info/2022/07/20/rsp I’ll take this document as Lord Benyon‘s apology to me for this markavery.info/2022/07/22/its

Katie-jo Luxton, the RSPB’s Executive Director for global conservation, said:

We’re pleased guidance has been published but this plan must be more ambitious and set out greater action to help our wild birds bounce back from this crisis. We believe it offers little new, and fails to set out the actions required to address the wider impact of this outbreak on wild birds. The central objective still emphasises poultry protection and will only centre on wild birds already of conservation concern.

The stakes could not be any higher and waiting for a species to become of conservation concern leaves us playing Russian roulette with their future. In Scotland this disease has led to species newly and suddenly entering that category, including the great skua, with reports pointing to declines of between 50 to 85% in the number of adults in some colonies, putting it at real risk of global extinction.

The news that a stakeholder working group is now promised following months of delay is a step in the right direction. However, it makes no sense that the APHA-chaired Ornithological Expert Panel has not already been convened during what all agree is the worst outbreak of avian influenza we have ever seen, and that there still seems to be no commitment to engaging with it. Had they engaged with us and others, this guidance could undoubtedly have been more comprehensive and produced quicker.

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