This is my advice on responding to the consultation on changes to shooting seasons for a variety of bird species across England, Wales and Scotland. The consultation can be found – click here. The closing date is Sunday 17 May so you have nearly four full weeks and all of four weekends to get this done. Please give it a go. I’d suggest having a look at it soon and then coming back to it when you have time to go through it, although it is possible to complete part of the consultation, save your work, and come back to it later so it doesn’t have to be completed in one go.
If you have never responded to a government consultation before, then this consultation might look a bit daunting but it is an important one and only you can express your views so please consider taking part. If you agree with me that, on the whole, the proposals are sensible and represent progress then please respond because otherwise there is the danger that the shooting industry will pressurise governments across Britain to water down what are fairly sensible reforms.
It is unfortunate that the three administrations have not agreed more closely about the proposals and that means that you have to respond in more detail if you want to speak up for these species across England, Wales and Scotland. However, you can respond to as many questions as you like, in as much or little detail as you like.
There are questions relating to whether you have information on numbers shot – you almost certainly do not – I don’t. Why should I? How could I? The point to make here is that governments should have this information and the absence of that information demands a cautious approach to shooting. In some cases it is claimed that there is independent information on numbers of birds killed but that isn’t the case – all the information comes from shooters who may or may not be telling the truth but cannot in any sense be described as independent since it is their behaviour that is being regulated.
There are 22 pages of consultation but you can get to page 7 in about three minutes by answering some questions about yourself and reading some information about the consultation. And pages 21-22 won’t take you any time at all. So that leaves about 13 pages of having to think about what you write. I did my response in 30 minutes and it’s a bit more detailed than what I am putting in front of you now, and it only took me 25 minutes. It took me much longer to copy my answers into this blog for you!
Let’s rattle through the pages;
Page 7 White-fronted Goose
Q4A1: Yes and Both Nations
Q4A2: No and then I put this text in the box ‘This is something you should be telling me, not asking the public for information.
In the absence of this information a precautionary approach is needed.
Government should collect this information as part of a proper licensing system.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live White-fronted Geese wintering in the UK are known pretty accurately thanks to volunteers like myself.’
Pages 8 and 9 Goldeneye
Q4B1: Yes and Both Nations and then put this text in the box ‘It’s a rare UK breeding bird.
Birds shot in winter might be Scottish nesting birds.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Goldeneye wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.
Q4B2: No and then I put this text in the box ‘It’s a rare UK breeding bird.
Birds shot in winter might be Scottish nesting birds.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Goldeneye wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.‘
Q4B3: Yes and then put this text in the box ‘It’s a rare UK breeding bird.
Birds shot in winter might be Scottish nesting birds.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Goldeneye wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.’
Pages 10 and 11 Pintail
Q4C1 and Q4C2: Yes and then add this text in each box ‘BUT it would be much better to remove the species from the list of shootable species as an even more sensible approach which would be consistent with proposals for England and would give a greater reduction of ‘the risk of resident birds being shot before the arrival of of the migrant population‘.
Q4C3: Yes
Q4C4: Yes and then add this text in the box ‘It’s a rare UK breeding bird.
Birds shot in winter might be Scottish nesting birds.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Pintail wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.‘
Q4C5 and Q4C6: No
Page 12 Pochard
Q4D1: Yes and All three nations
Q4D2: Yes and add this text in the box ‘It’s a rare UK breeding bird and a declining species.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Pochard wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.‘
Page 13 and 14 Common Snipe
Q4E1: Yes and Both Nations and add this text to the box ‘BUT I would prefer the approach taken in Wales.
I agree with the argument in this consultation but believe that removal from the shootable schedule is a better approach.
85,000 Snipe is a high number and these figures are unreliable and not independent. It’s a rare UK breeding bird.
Birds shot in winter might be UK nesting birds.
The data quoted from Aebischer are not based on ‘research’, they are based on asking a small and unrepresentative sample of shooters how many birds they shoot. These figures cannot be regarded as reliable.
In any case the figures are from 2016 and are thus out of date.
In contrast, the numbers of live Snipe wintering and breeding in the UK are known pretty accurately thanks to volunteers like myself.’.
Q4E2 Yes
Q4E3 No and add this text to the box ‘No – the regulators should know this number. We need licensing of shooting with strict bag limits per shooter and mandatory bag returns particularly when the inadequate data to hand suggest very large numbers of birds are killed.‘
Q4E4 and Q4E5 No
Page 15 Woodcock
Q4F1: Yes and Both Nations and add this text to the box ‘I agree with the evidence in the consultation and with that provided by Wild Justice which kicked off this proposed change which was supported by 107,000 people signing a UK Parliament petition. I predict there will be far fewer than 107,000 respondents to this consultation.
Shooting organisations already suggest that responsible shooters should not shoot this species until late November but it was noticeable that they were reticent about coming out for a change in shooting dates – I regard this as being because they know they have a lot of irresponsible shooters in their memberships whom they do not want to upset. This in itself is an argument for the proposed changes.‘
Q4F2: Yes and add this text to the box ‘EXCEPT it should be 30 November as is proposed in England and Wales.‘.
Q4F3, Q4F4 and Q4F5: No
Page 16 Woodpigeon
Q4G1: No and add this text to the box ‘This would mean that Woodpigeons could be shot in unlimited numbers for recreation (under these proposals) and in unlimited numbers for protecting crops (under existing general licences). This needs more thought. For example, what is the argument that a species can be killed for pest control without a close season to protect young in the nest? The whole shooting regime should be reviewed and a separate consultation issued.
Is there actually a case for allowing unlimited shooting of Woodpigeons for crop protection now that oil seed rape forms a much smaller part of the cropping regime. Should this species be shot as a pest? If so, under what conditions? A fuller review of when Woodpigeons can be shot should be undertaken before a species is added to the shooting schedule.
The Woodpigeon is not fully non-migratory. There are large movements within the UK in late October/early November involving millions of birds.
Some of these birds are thought to be of continental origin.
Some, maybe many thousands, are thought to leave the south coast of England for France each autumn.’.
Q4G2: No and add this text to the box ‘There are no reliable data because many shooters don’t realise that they can only shoot this species to protect crops.
Stock Doves are fully protected but are often shot by shooters where Woodpigeons are shot – loosening the system will result in more of a protected species coming under fire.‘.
Q4G3: No
Q4G4: Yes and add this text to the box ‘Usually free but may be expensive in posh urban markets.‘.
Page 17 read and move on
Page 18 Coots in Wales
Q5A1: Yes
Q5A2: No and add this text in box ‘I am told there is a New Year’s Day shoot of Coot at a site in southern England where hundreds of Coot are driven and shot every year. This is not sport, it is carnage.
Whereas much shooting can be seen as a traditional rural activity (which is in desperate need of reform and modernisation) there is no popular literature, folklore or anything else to suggest that Coot shooting has any real place in field’sports’. It is an anachronism that this species can be shot and that ability should end.’.
Q5A3: No and add this text to the box ‘I am told there is a New Year’s Day shoot of Coot at a site in southern England where hundreds of Coot are driven and shot every year. This is not sport, it is carnage.‘.
Page 19 Golden Plover in Wales
Q5B1: Yes and add this text to the box ‘I agree with the argument set out in the consultation.‘
Q5B2: No and add this text to the box ‘Golden Plover should be removed from shooting lists in England and Scotland too.‘.
Q5B3: No and add this text to the box ‘It’s the regulators’ job to have this evidence, not mine.’
Page 20 Any other business
Q6.2: Although it was tempting to ask for loads of changes I limited myself to this in the text box ‘Moorhen should be removed in all three nations.
Why is it there at all?‘.
Q6.2 and Q6.3: leave blank
Pages 21 and 22 – the end!
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