Call for evidence: Review of the use of shooting on land managed by Natural Resources Wales Submitted to: Shooting.review@naturalresourceswales.gov.uk Date 30th April 2017 Introduction Wildlife Trusts Wales (WTW) represents the six Wildlife Trusts in Wales Brecknock, Gwent, Montgomeryshire, North Wales, Radnorshire and South and West Wales (hereafter referred to as the Wildlife Trusts ) working together in partnership to achieve common aims. The Wildlife Trusts collectively speak on behalf of more than 24,000 members and manage over 200 nature reserves, covering more than 8,000 hectares of prime wildlife habitat, from rugged coastline to urban wildlife havens. The Wildlife Trusts in Wales are all about restoring biodiversity across Wales. We strive for Living Landscapes and Living Seas, recognising this as an inspirational end point where our environment, society, and economy coexist for the benefit of wildlife and people. A Living Landscape is a recovery plan for nature championed by The Wildlife Trusts since 2006 to help create a resilient and healthy environment rich in wildlife and to provide ecological security for people. Within A Living Landscape, habitats are restored and reconnected on a large scale with the local community closely engaged. The vision is a primary objective of The Wildlife Trusts and builds on a groundswell of landscape-scale activity. The Wildlife Trusts have a long track record of delivering landscape-scale conservation. Across the UK there are now more than 150 Living Landscape schemes covering an area of more than four million hectares. These are being delivered in partnership with many different individuals and organisations, including farmers and landowners, water companies, land-based industries, local authorities, other NGOs, statutory agencies, local communities and volunteers. As the statutory body in charge of the environment in Wales, and a landowning organisation, we believe NRW has a significant role to play in the creation of healthy ecosystems and a biodiverse natural environment. NRW manages 7% of the land area of Wales, including 120,000 hectares of woodland i, therefore management decisions, such as the appropriate use of firearms on NRW managed land, will affect large areas of Wales. Below we provide our evidence as to the appropriate use of firearms on NRW managed land and how this aligns with the sustainable management of natural resources and the wellbeing goals. Our main points are: Decisions to kill any animal on conservation grounds should be based on the ecological impact of the species concerned, i.e. its effects on species of conservation importance and/or habitats Rearing and releasing game birds, particularly pheasants can have negative impacts on biodiversity and ecosystems which should be investigated before permission is granted The use of lead shot presents a serious risk, both to humans and wildlife 1
Conservation Grounds A key purpose of NRW is to limit damage from pests to protect delivery of NRW land management objectives, including the conservation of protected and priority species and habitats and producing capacity. There are some species which would threaten this conservation at high densities without population control. It is therefore vital that monitoring of species, such as red, roe, muntjac and fallow deer, mink, grey squirrels and boar, is undertaken. This will enable managers to identify when the densities become so high that they have a detrimental impact on the natural environment. Where there is a risk of species damaging habitat, it is important that the impacts of these species is taken into consideration in management plans. The general principles we feel should be followed around any use of firearms on NRW managed land are: Decisions to kill any animal on conservation grounds should be based on the ecological impact of the species concerned, i.e. its effects on species of conservation importance and/or habitats To proceed there should be a convincing case that killing the animal concerned will address the management problem that has been identified and that killing is the only practical mechanisms that would achieve this Any killing should be done by the most humane, practical method available Any proposal to undertake a killing programme should be adequately researched and justified on paper, be for a limited time scale and have a monitoring mechanism built in. The decision to continue to a further phase should be based on the assessment of the effectiveness and continued relevance of the previous phase. Methods of regulating the population by other means e.g. by habitat manipulation, altering food supplies, adjusting natural predation levels etc. to achieve a self regulating system should be frequently reviewed as the preferred long term solution. Our understanding is that shooting of some species is currently permitted on NRW land for reason given below: Deer, as high densities of deer present problems for woodland creation and have socioeconomic effects through impact on agriculture and vehicle collisions ii,iii. Mink, as these have a detrimental impact on water vole populations. These animals are generally trapped and killed, with shooting the most common method of killing. Grey Squirrels, as they cause severe damage to trees by bark stripping, that exposes the timber to fungal and insect attack, disrupts the flow of nutrients up the tree, and weakens the stem. In overlap areas, grey squirrels cause the extinction of the native red squirrel through competitive exclusion. Moreover, they host poxvirus, fatal to red squirrels but benign to grey squirrels, which dramatically increases the rate of replacement 2
It is important to note that some species of deer are native. In this case, shooting should only be considered when population densities are proven to be detrimental to the natural environment. We believe that whilst light grazing by wild deer is generally beneficial to natural heritage, uncontrolled and excessive grazing by deer can be a threat to the healthy, natural functioning and connectivity of ecosystems in Wales. We therefore support a wide range of management measures which aim to stabilise deer numbers at ecologically acceptable and sustainable levels. Where shooting of deer is considered necessary we support a professional qualification for stalkers that tests understanding of ecology and wider issues relating to deer management and best practice guides to ensure the humane taking of deer. We recommend that any guidance is kept under regular review. For non-native species, the detrimental impact of the animals presence, and the benefits of their removal, should be clearly identified. Any shooting taking place should be undertaken with careful consideration of the aim, i.e. eradication or population control. All culling should be carried out safely, legally and humanely, with clear guidance for best practice, e.g. in the Practice Note by Forest Research for deer iii. There are examples where species control can be done to provide economic and environmental benefits. A major example of this is found in the Forest of Dean where Wild Boar are shot by wildlife rangers and measures are in place to use the end product so it is not wasted. Without population control of some species in Wales, the ability of NRW land to contribute to achievement of the Resilient Wales goal would be impaired. Culling is in line with the sustainable development principle to Take action to prevent significant damage to ecosystems and takes account of the resilience of ecosystems. Game Management There are several management practices used in the UK for game bird shooting. A report by the James Hutton Institute identifies these and the positive and negative impacts iv. Some of the techniques do pose risks for biodiversity including: Rear and release which can cause habitat changes, soil enrichment, browsing of native flora, competition for food and introduction of parasites and disease iv Predator control which has led to illegal control of protected species and has led to meso-predator release iv Habitat management, such as burning and grazing control can have positive and negative effects on different species iv Of these techniques, the one presenting the greatest potential challenge to a biodiverse natural environment and healthy, functioning ecosystems is the rearing and releasing of game birds, such as pheasants. Around 2.6 million gamebirds (pheasants and partridges) are released into Wales each year v. Ecological effects of introducing hand-reared birds on natural environments include vi : Potential threat through the spread of disease and parasites vi. Pheasants may spread numerous parasites to wild birds, particularly at feeders vi ; 3
Modification of woodland ground flora through browsing, disturbance, creation of gaps in the canopy and soil enrichment, with characteristic woodland species replaced by disturbance tolerant perennials vi,vii. These changes were found even at low stocking densities; At high densities, modification of hedgerow and hedgebank floral structure. This may have knock-on effects for hedge nesting birds vi ; Pheasants reduce the biomass of overwintering ground-active invertebrates and caterpillars which are important food resources for breeding birds vi. Pheasant rearing and release has detrimental effects on specialist woodland invertebrates when at high densities vii ; Breeding gamebirds may compete with native birds for invertebrate resources vi ; Gamebirds on moorland fringe habitat threaten rare and endangered bryophyte communities, and may impact on red grouse and other fragile moorland bird species vi ; Unintentional shooting of non-target species results in population declines in other species vi. Predator numbers may increase when numbers of gamebirds are high. These numbers are then unsustainable at the end of the hunting season, causing a switch to other prey types leading to detrimental effects on nesting birds vi There have been successful prosecutions of some gamekeepers for persecuting protected predators vi Suggestion that released pheasants predate hibernating dormice, with predation rate greatest closest to release pens (although results require further investigation) viii It has also been found by some authors that the impacts of pheasant releasing on vegetation structure and bird communities in lowland woodlands are benign ix. Some aspects of woodland management for pheasants, such as reducing the extent of canopy cover, can encourage growth of ground flora leading to more favourable conditions for some woodland bird species ix. The impacts on ecosystems listed above suggest rear and release of gamebirds can severely reduce the resilience of the natural environment and its ability to adapt to changes, including a changing climate. The potential positive impacts mean that the specific changes caused by this practice on NRW land should be thoroughly investigated to determine whether it is detrimental to achievement of a Resilient Wales and to the principles of sustainable management of natural resources, namely Take action to prevent significant damage to ecosystems. Therefore, we recommend thorough investigation to be undertaken prior to any rear and release activity being permitted on NRW managed land. Within Wales, the shooting industry has been reported to support around 2,400 full time equivalent jobs (including the entire supply chain) and has a total GVA of around 75 million x. However, there are also some socio-economic negative impacts of shooting vi : 0.9-1.8 million pheasants collide with vehicles each year in the UK, with unknown insurance costs vi Pheasants may increase the risk of exposure to Lyme disease in humans vi 4
These negative impacts along with ecological concerns listed above, may affect Wales ability to achieve the Prosperous and Healthier Wales WFG goals. Impacts of Lead Shot Lead is known to be a highly toxic poison and is the subject of global public health targets and recognised as a source of wildlife mortality and morbidity. It has serious negative impacts on human health and the natural environment. Since additives to petrol were regulated, the main source of lead contamination of people has been via the diet, with lead ammunition being the most readily controllable source xi. Lead obtained from wild meat, whether as shot pellets or bullet fragments, has been linked with elevated blood levels. The consumption of meat from wild game animals killed using lead ammunition was found by the Lead Ammunition Group to pose risks to high-level consumers of wild game xii. Potential adverse effects on people include reduced intelligence and cognitive function in children, increased risk of spontaneous abortion in pregnant women and cardiovascular effects and chronic kidney disease in adults xii. The work by the Lead Ammunition Group also found that continuous use of the same areas for discharging large quantities of lead ammunition are likely to lead to lead deposition that may adversely affect the health of livestock grazing or foraging in these areas xii. Harvesting silage or haylage from these areas may have toxic effects in livestock feed. Poultry are particularly at risk from feeding and foraging in these areas and there is evidence of transmission of lead to eggs and the meat xii. Therefore, use of lead shot directly opposes the Healthier Wales goal due to the risk of lead getting into the human diet. Lead is also toxic to animals and is thought to kill tens of thousands to hundreds of thousands of birds in the UK annually xii. There are five ways in which lead from ammunition can reach susceptible animal tissue xii : Direct ingestion: Species such as waterfowl, game birds and pigeons, ingest spent gunshot incidentally along with the grit needed in food breakdownerror! Bookmark not defined. xiii,xiv. This lead poisoning does not normally produce mass mortalities as birds die slowly through the year, a few at a time, their carcasses quickly removed by scavengers. Indirect ingestion: Meat-eating scavengers ingest the lead from the carcasses,xv,xvi. In the UK, deaths and sub-lethal effects have been recorded in Red Kites Milvus milvus and possibly other raptors, including Buzzard Buteo buteo and Peregrine Falcon Falco peregrinus xii. Movement of spent ammunition lead via plants into their consumers Movement of spent ammunition lead by ingestion of soil or soil organisms into their consumers Movement of spent ammunition lead from embedded shot/bullets into body tissues 5
The Lead Ammunition Group assessed the risk to wildlife from lead ammunition as medium to high i. Discarded shot also contributes to soil contamination with lead xiii. Therefore, use of lead shot directly opposes the Resilient Wales goal due to the negative impact it has on creating a biodiverse natural environment with healthy functioning ecosystems. We recommended that solutions to the problem of lead poisoning in wildlife and humans could be solved by replacing lead ammunition with non-toxic alternatives and this should be the absolute minimum requirement for any shooting on NRW managed land as these areas are to be managed for public benefit, including wildlife value. Recommendations Based on the evidence presented above, it is clear that any shooting on NRW land should be carefully considered, taking into account NRW s purpose, the WFG goals and the principles of sustainable management of natural resources. Where there is a risk of a species having a negative ecological effect, management plans should be in place and shooting should be a last resort. The Wildlife Trusts in Wales, therefore, recommend the following: Decisions to kill any animal on conservation grounds should be based on the ecological impact of the species concerned and should only be sanctioned where animals have been proven to have a detrimental impact on achieving a biodiverse natural environment with healthy, functioning ecosystems. Where shooting is permitted, it requires clear guidance on best practice and training to be provided Game shooting, and rearing of game birds such as pheasants, can, in some cases, have positive impacts, however there is also evidence to suggest it is not in line with the principle of sustainable management of natural resources nor the Resilient Wales goal. Therefore, before any rear and release activities are permitted on NRW land, their impacts need to be thoroughly researched. As a minimum, any gamebird rearing and release on designated land (SSSI, SAC) should require Habitat Risk Assessments Use of lead shot should be banned as an absolute minimum to avoid impacting the health of the natural environment and people. Wildlife Trusts Wales April 2017 i NRW (nd): Managing land for the people of Wales. Natural Resources Wales, available at: https://naturalresources.wales/people-and-communities/managing-land-for-the-people-of-wales/?lang=en on 6 th April 2017 ii Welsh Assembly Government (2011): The Welsh Assembly Government s strategy for wild deer management in Wales iii Mayle, B. (1999): Managing deer in the countryside. Practice Note. Forest Research. iv Mustin, K. et. al. (2011): Biodiversity impacts of game bird hunting and associated management practices in Europe and North America. 6
v Defra (2013): Great Britain Poultry Register (GBPR) Statistics: 2013. Animal Health and Veterinary Laboratories Agency vi Bicknell, J. et. al. (2010): Impacts of non-native gamebird release in the UK: a review. RSPB Research Report no.40. Sandy, UK. vii Neumann, J., et. al. (2015): Releasing of pheasants for shooting in the UK alters woodland invertebrate communities. Biological Conservation. 191. Pp50-59 viii PTES (2015): How do pheasants impact on dormice during hibernation? The Dormouse Monitor. Winter 2015. ix Draycott, R.A., Hoodless, A.N. & Sage, R.B. (2008): Effects of pheasant management on vegetation and birds in lowland woodlands. Journal of Applied Ecology 45 pp334-341 x PACEC (2014): The Value of Shooting: The economic, environmental and social contribution of shooting sports to the UK. Public and Corporate Economic Consultants (PACEC) xi Delahay, R.J. & Spray, C.D. (Eds) (2015): Proceedings of the Oxford Lead Symposium. Lead Ammunition: understanding and minimising the risks to human and environmental health. Edward Grey Institute, The University of Oxford, UK xii Lead Ammunition Group (2015): Lead ammunition, wildlife and human health. A report prepared for the Department for Environment, Food and Rural Affairs and the Food Standards Agency in the United Kingdom xiii Bana, G (2004): Ecological effects of lead-shot on terrestrial habitats and on the accumulation of lead in wild birds and other waterfowl. Report to the Council of Europe Standing Committee of the Convention on the Conservation of European Wildlife and Natural Habitats. T-PVS/Inf xiv Ares, E. & Baker, J. (2015): Lead Shot Ammunition. Parliamentary Briefing Debate Pack Number CDP 2015/0120 xv Bana, G (2004): Ecological effects of lead-shot on terrestrial habitats and on the accumulation of lead in wild birds and other waterfowl. Report to the Council of Europe Standing Committee of the Convention on the Conservation of European Wildlife and Natural Habitats. T-PVS/Inf xvi Ares, E. & Baker, J. (2015): Lead Shot Ammunition. Parliamentary Briefing Debate Pack Number CDP 2015/0120 7