General licences and BTO
Andy Clements, BTO Chief Executive, sets out BTO’s position regarding the current debate about wildlife licensing
Revoking the General Licences
In response to a legal challenge to three General Licences, Natural England has recently decided to revoke these licences and is reviewing their approach to issuing new licences. Some of this work is already underway and a fuller review is planned for this summer. While BTO does not play a direct role in this process, we are naturally very interested in this issue and believe we have a strong role to play in informing the debate so that the decisions made are based on the best available scientific evidence.
The legal challenge, which Natural England has conceded, is that three General Licences are illegal because Natural England has delegated the responsibility for assessing alternatives to lethal control (for example, bird scaring) to those using the licence. For reasons explained in the blogs by Natural England interim CEO Marian Spain (“The next steps” and 30 April update) , the licences had to be revoked quickly, and replaced by new, legal licences. In addition to this urgent response, Natural England had already planned to review General Licences during 2019/20.
This is a time for cool heads and clear thinking; let’s set our direction for the future based on the very best information available to us.Andy Clements, BTO Chief Executive
BTO’s role in the discussion
BTO stands ready to help with that review process. We will expect to be asked to provide the most up to date and rigorous evidence that supports the licensing of activities that would otherwise be illegal under the legislation. It shouldn’t surprise you to learn that as BTO’s CEO I believe that scientific evidence can and should play a key role in decisions about future policies. This is particularly important when emotions are running so high and the issues under debate affect the lives of birds and the livelihoods of people. This is a time for cool heads and clear thinking; let’s set our direction for the future based on the very best information available to us.
In addition to being Chief Executive of BTO, it is my passion for science and the use of evidence to inform conservation that motivated me to take on my role as a Natural England Board member. As part of that role I chair the Natural England Science Advisory Committee, focusing on the evidence that informs the organisation’s work. I firmly believe that my experience of leading BTO over the last ten years puts me in a uniquely privileged position to champion the use of science from an impartial perspective. Both at BTO and at Natural England, I will continue to look for the evidence to inform decisions. In this case I would be looking towards the work of the Avian Population Estimates Panel to give us up-to-date population figures for the species under scrutiny. Population trends from the recently published Breeding Bird Survey report will provide additional context, as will longer-term patterns from the Bird Atlases.
BTO already recognises from our own research and reviews of predation and conservation by the RSPB as well as from other sources of evidence, that some aspects of species control are well informed, while others are not. In advising Natural England, or indeed wider government or their agencies, we would be taking this into account. For example, there may be insufficient scientific evidence to merit the inclusion of Jay on the licence list in order to conserve birds. On the other hand, our study of Carrion Crows and Curlews indicate a negative relationship and this is alongside other evidence that predation is suppressing Curlew productivity.
On the one hand, the current issue around General Licences does not affect the specific licensing of ringing, marking, and photographing birds which is delegated to BTO by the government agencies in England, Scotland, Wales and Northern Ireland. However, the high-profile nature of the General Licence debate is causing some confusion and, potentially, some fall-out. Alongside this, some people have expressed concern about Chris Packham as BTO President. Chris was our President between 2014–2018, championing our science and raising BTO’s profile through his work on BBC SpringWatch. He stood down in 2018.
BTO will continue to maintain its neutral, evidence-informed position in assessing applications for specific ringing and nest photography licences. This impartial reputation should ensure that our volunteers and staff continue to be welcomed in all the places they currently are to carry out survey, ringing and other activities that are licenced. I sincerely hope that those with whom we work will continue to accept our staff and volunteers as impartial gatherers of important scientific data.
The control of certain species continues to be allowed under the legislation, so let’s make the process as good as it can be. As BTO informs the way forward, I would hope we can all agree that, for licensing to work, there needs to be an open and transparent system that enables monitoring and the legal adherence to appropriate conditions. BTO’s evidence-informed advice will aim to contribute to this approach.
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Andy Clements, 03 May 2019
Director of Science James Pearce-Higgins comments on the general licenses:
The value of the BTO’s role is well illustrated by the debate around general licences. In reply to a call for evidence by the Secretary of State, regarding the impact of the withdrawal of general licence GL04, GL05 and GL06, BTO submitted a response, which is available for download below. The subject of predation is a controversial one, and is often the subject of keen debate, if not impassioned disagreement. This is where BTO’s impartially is important. But in order to be able to speak with authority in this space, we must present the best available evidence in a dispassionate manner. Our evidence draws upon robust information collected by volunteers, contributing to national monitoring schemes, our expertise in analysing and interpreting such data to identify the likely importance of different drivers of change in bird populations, and our ability to set this alongside wider scientific information.
In our submission we summarised recent population trends in most of the species subject to general licence using data from the latest BTO/JNCC/RSPB Breeding Bird Survey report. For Canada goose and Egyptian goose, the just published BTO/JNCC/RSPB Wetland Bird Survey report also provides year-round population information from wetland habitats. We then considered the evidence that species listed on the general licence impact the conservation of flora and fauna, drawing particularly on the Understanding Predation project that BTO helped to lead, and research we have undertaken on the impact of predators on songbirds and Curlew. Finally, we also referred to a small number of incidents where individual landowners appear to have recently refused access permission to our volunteers in response to the withdrawal of these general licenses. Given the importance of long-term data collection and its key role in helping to understand the changes that are occurring in the countryside, coupled with its value in monitoring the impact of any licensing changes in the future, I hope this submission emphasises how such a refusal is counter-productive, whatever views are held.
Looking forward, it appears likely that there will be ongoing consideration of the future of general licenses in England. BTO stands ready to contribute further evidence as required to inform such decision making.
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