Natural Resources Wales and one-sided ‘compromise’

As Protect the Wild’s Glen Black outlined in a March 31st news post, Natural Resources Wales (NRW) is asking the public for its thoughts on new regulations designed to licence the release of pheasants and partridges by the shooting industry.

Glen wrote that we need to ‘keep our eyes on the prize’ and that ‘those of us that want to see an end to shooting altogether’ need to view such incremental changes as ‘licencing regulations’ with a critical eye.

He is absolutely correct, we do need to look very carefully at these proposals, because as NRW themselves clearly say, “This is not a consultation on whether or not shooting live quarry should continue to be allowed in Wales.”

There is therefore no much-needed ‘third-way’ option to ban shooting: all this ‘consultation’ wants to know is in what form shooting birds should continue – with limited licencing or without.

The ‘licencing’ compromise

Protect the Wild wants the shooting of live targets banned. We see selling birds to guns for profit as morally repugnant. As biodiversity crashes and more and more land is taken so that shoots can create conditions they need to ‘farm’ huge numbers of birds to be shot we also think it is indefensible.

But licencing might perhaps – in this example anyway – see a limiting of shooting and possibly (though it’s never quantified and numbers specific to Wales aren’t available anyway) fewer birds being reared in appalling conditions to be shot. Even maybe a reduction in the damage caused by releasing omnivorous pheasants and partridges near protected sites that potentially look after rare invertebrates and plants (both of which they may either eat or defecate on). Either would be preferable to the situation now. So should Protect the Wild compromise, support the consultation because ‘something is better than nothing’, and perhaps suggest that our audience add a note to NRW telling them that next time they’d like to see proposals for a ban included?

We don’t think so.

Yes, compromise does (sometimes) lead to resolution, but for that to happen both sides – and there are two clear sides in this debate: the pro-shooters and the pro-wildlife campaigners – must be genuinely prepared to give something up to reach a middle ground acceptable to both.

And that is NOT what is happening here…

Dead pheasants Cornwood shoot

What changes for the shooting industry?

According to the terms of the consultation, NRW is proposing adding:

“…common pheasant and red-legged partridge to part 1 of Schedule 9 of the Wildlife and Countryside Act 1981. Part 1 of Schedule 9 lists non-native species that are already established in the wild, but which may pose a conservation threat to native biodiversity and habitats. This would mean that any release of those species in Wales would need to be carried out under a licence issued by NRW.”

Under these proposals, then, shoots releasing pheasants and partridges more than 500m from protected sites like SSSis or nature reserves (which are going to be the majority of shoots) aren’t affected in any meaningful way at all. All they will require is what is known as a general licence, a virtual piece of paper that doesn’t even require downloading and is available to anyone who wants it ‘provided they comply with its terms and conditions‘. Enforcement is typically weak, and actually removing a general licence from an individual or an estate involves difficult and expensive visits to a court.

Shoots planning to release relatively large, non-native birds near protected sites can apply for a different licence with slightly more arduous conditions attached. Applicants will be asked to ‘demonstrate how they will ensure their releases will not harm the environment, and ideally provide benefits for biodiversity’. But where ‘releases would be highly unlikely to have an impact on any of the designated features [of the protected site]’ all that will be needed is a general licence.

With the best will in the world, it’s difficult to see how that makes a jot of difference to the birds being shot, or to the people lining up to kill them.

If NRW were proposing adding Common Pheasant and Red-legged Partridge to the Invasive Alien Species (Enforcement and Permitting) Order 2019 which (as NRW themselves explain) would make it an offence to release them into the environment at all, we might support the consultation as that would severely curtail bird shooting. If they were proposing a rigorous and novel licencing system which would almost eliminate the tipping of millions of non-native birds into an already stressed environment and the conditions of that system included a legal obligation to ensure positive ‘benefit to the environment’ rather than the woolly condition to ‘not harm the environment’, again we might support the consultation. Both proposals would see shooting give something up, and would lead to less killing and less damage.

But that’s not even on the table.

Think on this too: this consultation wouldn’t even have to take place if the shooting industry (which repeatedly claims it’s all about ‘conservation’) took a precautionary stance and agreed that ‘protected sites’ should be off limits as a matter of principle.


dead woodcock


What should we compromise on?

So, under the terms of this consultation shooting gives up nothing meaningful. And no red lines on, for example, toxic lead shot (which the industry refuses to compromise on) or the mass trapping of mammals like foxes and mustelids (ditto) are crossed. The industry continues to normalise the  release of millions of birds to be shot, and – despite the knee-jerk squealing coming from shooting lobbyists who have historically lobbied incredibly hard to not have to give up anything – it will be business as usual.

What might we be asked to compromise (or give up) on, then?

We’re effectively being asked to support an unquantified reduction in the killing of millions of birds, and to accept a licencing system which implies that killing massive numbers of birds for entertainment is legitimate – and the endorsement of which could even make it harder to bring shooting to an end.

For a start, it’s impossible to know how many fewer birds will be killed. There may well be no reduction at all. Just as with proposing to change when Woodcock can be shot rather than working to ban the shooting of a Red-listed, declining bird altogether, isn’t it likely that shooting will work out ways to sidestep any constraints and sell just as many birds to its clients as it does now? A slight change in location here, a waft of a general licence there. How does that help pheasants or partridges, or move us any closer to the end of this organised slaughter?

It doesn’t, of course. If we sign up to back licencing (and remember the option is to back it or not back it) we not only let down the birds we want to protect, but, if legislation is then passed, the shooting industry will (as they always do) tell the world how they have compromised and that should be the end of the discussion. We have accepted licencing, they will say, let’s hear no more about this.



The end result

This is the inevitable conclusion of ‘consultations’ like this that don’t actually include the option many of us want to see. They don’t come close to ending anything, just offer legitimacy and allow one side to claim they’ve compromised while the other is forced to abandon their principles and their aims for a theoretical position they don’t actually agree with and an end result they don’t actually want.

Why on earth would we sign up for that?



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