Licenced to kill: consultation on permits to control birds in Wales
Natural Resources Wales (NRW) is consulting on how it permits the killing of wild birds and the destruction of eggs and nests. All birds are protected by laws, which have been the result of campaigns by RSPB supporters over many decades.
So, allowing birds to be killed lawfully should not be undertaken lightly. We think it is important that NRW has a robust and transparent system to regulate these permissions in Wales, very much as a last resort.
We will be responding to the NRW consultation, which ends on 11 November, and encourage our supporters to contribute their views and experience too. The consultation covers a range of issues, and builds on changes made to the General Licences in 2019 – you can read here about what we thought of that. RSPB Cymru provided evidence to the NRW review and is contributing to a group on issues relating to cormorants, goosanders and declining populations of Atlantic salmon.
The consultation is extensive, involving 70 questions, and quite technical, so this blog is not a detailed analysis. Broadly, we think the proposed changes are sensible and support the principles that NRW proposed to adopt, which will apply to decisions made about all of its bird licences, whether specific (where evidence has to be provided in an application made to NRW) or general. It’s these General Licences that are most controversial, since they can be used by almost anyone in Wales outside certain Sites of Special Scientific Interest (SSSI) without making a specific application. Providing the conditions of the licence are met, the user can kill an unlimited number of certain species, such as woodpigeon, jackdaw and jay. NRW does not require the circumstances or numbers killed to be reported, so has no real idea about the scale, benefits or consequences of this control.
For one of its General Licences (004, which permits several crow species to be killed in order to protect wild birds), NRW is seeking views about deleting the General Licence and requiring users to apply for a specific licence. That would be our preference, but if that is not the option chosen by NRW, we think that, as a minimum, users should have to register and report their use of the licence annually, to inform how licences should be issued in the future. We believe that should apply to all General Licences, to improve the evidence available to NRW, and not just GL004.
The consultation makes no mention of how NRW will provide the public with summary information about how it is implementing its policy. In the interests of transparency, this is a serious gap. Natural England provides such information for the licences that it issues, and we believe that the people of Wales are owed the same level of information about what is permitted to happen to our birds. Although publication is not a legal requirement, since NRW’s website states that “Natural Resources Wales is fully committed to openness and transparency in all our dealings,” it would instil greater public confidence in the policy if the summary was published each year.
We welcome NRW’s commitment to review the application of its licensing policy every three years, supported by an external panel, to account for new evidence and for changes in species’ status. This must also keep under review potential changes that are not adopted in 2022. For example, we have provided evidence of how registration and marking of crow cage traps would assist law enforcement, as is required in Scotland.
We will be responding to the consultation and hope that our supporters will too, especially if you can provide documented evidence and experience. NRW has important decisions to make, and it’s crucial that these are based on good evidence even where this challenges perceptions and the status quo.
To access the consultation in English, click here. You can respond online, by email or by post.