GWCT encourages those wishing to release gamebirds on to an SPA this year to apply for a licence from Natural England, regardless of whether the SPA is on Natural England’s list of SPAs likely to receive permission or not. GWCT has been told that the list does not prejudge Natural England’s decision, and that every application will be assessed on its merits. For help with what to include in your application, please refer to the guidance at the end of this blog and please do not hesitate to contact the GWCT Advisory service for help.
We view the work of game managers on these SPAs as beneficial conservation that would stop if gamebird release were not permitted. If Natural England does not receive many applications, it will deem its screening to be successful and will assume there is no problem needing further attention.
As detailed in a previous blog, Defra informed stakeholders and the public in April that it would not be re-issuing GL45, the general licence to release gamebirds on or near (500m buffer) SPAs. This decision was made due to current levels of highly pathogenic avian influenza (HPAI) and the inability to rule out the risk of it spreading to the bird features present on SPAs. Instead, those wanting to release gamebirds onto SPAs or their buffers must seek an individual licence from Natural England.
Please note that GL43, the general licence to release gamebirds on SACs, was issued on 2 May. If you plan to release on an SAC that is not within the boundary of an SPA and its buffer, then you may continue to use GL43 and must comply with the licence conditions.
Natural England opened its portal for applications to release gamebirds on SPAs (and their 500m buffers) on 22 April, asking applicants to send an email to gamebirds@naturalengland.org.uk indicating which SPA they would like to release on, the number of release pens proposed, and whether or not they propose to submit supplementary documents. Natural England also provided a stakeholder bulletin and supplementary guidance.
Unfortunately, Natural England remains incredibly risk-averse and does not appear to be considering counter arguments highlighting where game management activities support designated species on SPAs and how stopping these activities would be detrimental to those designated species. Furthermore, it is not taking account of the previous licences Defra issued in 2023 in similar circumstances, which reasonably allowed gamebird release under strict conditions and mitigating factors and evidently did not increase the Avian Influenza transmission to SPA feature species.
If all applicants are to be based on their merits, we urge those wishing to release gamebirds on to SPAs and their buffers to apply, regardless of Natural England’s screening process for those SPAs they deem unlikely to be granted permission.
As supplementary information applicants should consider including some or all the following points:
- You should find out which species your relevant SPA is designated for. For example, the North Pennine Moors are designated for breeding (not over-wintering) hen harrier, merlin, peregrine falcon and golden plover. If you know the breeding locations for these species, you should inform Natural England where they are and the distance from your proposed release pens. In theory, this allows a better understanding of the local situation, rather than a blanket understanding of the SPA as a whole.
- You could include mitigating management techniques that will deter your released gamebirds from travelling towards areas that the designated species are known to frequent. For example, feeding the birds away or dogging the birds back to areas where interaction is minimised.
- If you know when (average dates) the designated species have usually finished breeding and vacated the area in previous years, this might be helpful to agree a release date which is earlier than Natural England are currently proposing but avoids interaction with the designating species.
- You could highlight how game management activities, like predation management as an example, are intrinsically linked with your proposed gamebird release, how those activities benefit the designated species of the SPA, and how those activities would stop if release was not permitted. For example, Ludwig et al. (2020) found that average number of successful breeding attempts by both hen harriers and merlin were two to three times greater with predation management than when it was unmanaged.
- If you received a licence in 2023 you should ask for similar conditions and highlight that those releases had no apparent impact on HPAI levels for the designated species of the SPA previously.
- You can ask for your individual HRA assessment, which Natural England is obliged to share.
Whilst this issue focuses ony on HPAI transmission, you could share GWCT’s concerns that stopping game management activities in the area could have a far greater adverse impact on the SPA’s designated species in the long-term than the potential, unproven risk of HPAI transmission. Whilst Natural England is considering a ‘reasonable worst-case scenario’ for HPAI, what happens if HPAI risk levels reduce? Furthermore, whilst it might not be possible to rule out adverse effects and the possibility of HPAI transmission, we believe it is possible to reduce the risk to acceptable levels, which would be a more proportionate approach and would avoid job losses and the associated reduction in conservation work, which benefits those species for which the SPA has been designated.
The GWCT Advisory service can be contacted at mgoodall@gwct.org.uk or rdraycott@gwct.org.uk. We will provide regular updates over the coming weeks.