NRW Firearms Review Consultation

NRW Consultation

 

Natural Resources Wales

 

Date:  April 2018

 

Completed Online to NRW

 1. Do you agree that the use of firearms should continue to be an option available to NRW in managing the negative impacts of wild species on the land it manages to achieve the sustainable management of natural resources?

We strongly agree that the use of firearms should continue to be an option available to NRW in managing the negative impacts of wild species on its land.

We responded to the Call of Evidence from NRW last year, and agree with the proposals drafted in A review of the use of land managed by Natural Resources Wales. As the review concludes, “Alternatives to our current approach to managing the impacts of wild species do not provide the same level of confidence that our land management objectives will be achieved.”[1] We are confident that the review was carried out to high standards, which has been independently assured.[2] We would have issue with any changes to the proposed proposal, which is currently based on strong scientific evidence to limit the damage from wild species to protect the land management objectives of NRW.

We are confident that NRW are using best practice, as written in the review of the use of firearms on land managed by NRW “firearms are used by our highly trained staff applying best practice standards to ensure animal welfare”[3]

We understand that the main use of firearms on NRW land is for the control of deer. The deer is the largest wild animal in the Welsh countryside and they do not have a natural predator. The number of deer roaming the countryside in Wales has increased on a yearly basis[4]  but in reality come into minimal human contact.

Whilst forest design and enclosures sound like a good idea, this is not always practical. As written in the NRW review it ‘is not likely to be appropriate to protect priority species and may not meet management objectives for species protection, productive capacity or maintenance of native habitats.[5]Such an alternative means of control would involve increased levels of cost, management and human resources to maintain fences, as well as stock control. Close management of species in the wild is difficult and can be dangerous for those taking part, the use of firearms offer an important safety mechanism for those involved.   

We would also raise serious concerns with the proposed alternative of using contraception for the management of wild species.  We would argue that this would still require the use of firearms to administrate. The use of contraception would be a huge cost burden for NRW.  We would also be concerned about the long-term impact that introducing contraception would have, as its effect on deer fertility are unclear. As mentioned by the British Association for Shooting and Conservation in their written evidence, ‘the risk of steroidal contraceptives being persistent in the food chain[6] could create waste of an otherwise possible funding resource for NRW. 

We have a responsibility to manage our land for future generations, and without appropriate management, deer may have a detrimental effect on out agriculture output, timber quality and lead to increased tree stocking cost for other foresters.[7] NRW should be allowed to maintain the ability to carry out control with firearms as part of a long-term management plan.

 2.    Do you agree that NRW should continue to consider applications for permission to carry out control of wild species using firearms on the land we manage?

 We absolutely agree that NRW should continue to consider applications for permission to carry out control of wild species using firearms on the land that they manage, for the same reasons given in the above response.

 There is a strong mechanism in place for those who have been chosen to carry out control of wild species on behalf of NRW. From a cost perspective, this also allows contract holders to be used when necessary. 

 3.  Do you agree that NRW should continue to consider the leasing of land for pheasant shooting, wildfowling and other pursuits involving firearms where it does not negatively impact on sustainable management of natural resources?

 We agree that NRW should continue to consider the leasing of land for pheasant shooting, wildfowling and other pursuits involving firearms. We do not see any issue with the use of firearms being carried out on leased land, and we are not aware of any compliance issues between NRW and shooting leaseholders. Furthermore, the review itself concludes, “Alternatives to our current approach are less likely to achieve the desired outcomes”[8] Along with the examples given above the practicality of the alternative approaches and the increased cost burden, it would have a negative impact on the sustainable management of natural resources.

 Many of the alternatives proposed by NRW for the control of wild species, such as contraception would still involve firearms.  NRW require those who have leases to follow the Code of Good Shooting Practice, which, along with providing rules and guidance for a range of ethical and practical matters relating to game shooting, it also recognises the conservation benefits that game shooting provides.

 Land that is shot over tends to be managed to encourage game to thrive within it. In practice, this means managing woodlands, hedges, streams and other watercourses in a more proactive way than might otherwise be the case. In addition, shoots often plant areas of cover, providing safe habitat for a variety of wild species.

 Shooting is an important contributor to the rural economy, providing income to local businesses out of the normal tourist season. Those who take part bring revenue by supporting local commerce in the form of hotels, gun shops, petrol stations, restaurants and other leisure and tourism operators. There is powerful evidence from organisations such as the Countryside Alliance, BASC and the GWCT regarding these benefits and are highlighted in a report published in 2014 called The Value of Shooting.

 Land owned by NRW, when let for sporting purposes, will have the benefit of being ‘policed’ by the tenant – this is a distinct advantage. In increasing its commerciality, NRW should look at shooting on its estate as a way of securing future additional funding and not as a negative activity. As acknowledged in the review, “There is an economic benefit to Wales through shooting activities.”[9] Land that is shot over tends to be seen by a greater number of people than land that is not. Generally, this evokes a greater sense of pride and management input to keep the land in good order and ensure it is of greater landscape value.

 In response to previous similar inquiries, CLA members have told us that shooting provides employment in rural areas where other opportunities may not exist e.g. keepers, beaters, pickers and loaders.

 Taking the principles enshrined in the Well-Being of Future Generations (Wales) Act as reference, it is important that decisions on how our public estate in Wales is managed be taken with the balance of economic, social, environmental and cultural well-being in mind. We would urge NRW to look at the impact that a decision to limit shooting on NRW land could have on the balance. NRW should be seen as setting the benchmark for good land management practices and a decision to limit shooting could be seen as a signal to other land users to follow suit, which could have an even greater impact on the industry and rural economy. Should NRW consider a ban on shooting, other bodies, may follow which could lead to a significant decline in the lucrative shooting industry in Wales.

 Any individuals not complying with the Code of Good Shooting Practice should be tackled on a case-by-case basis, but tarring all practitioners with the same brush would not be equitable when so much good practice is observed.

 We understand that NRW are under pressure from a strong anti-shooting lobby to consider its position, however we would urge that the decisions taken should not be one based on a single interest, but one based on scientific evidence that will improve the sustainable management of natural resources for the long term.

 

4.Are you a member of or affiliated to an organisation with an interest in this review?

 

Yes.

 

 

For further   information please contact:

 

Branwen   Miles

Policy   Advisor

CLA

Orbit Business Park,

Merthyr Tydfil, CF48 1DL

 

Tel: 01547 317085

Email: Branwen.miles@cla.org.uk

www.cla.org.uk

 




[1] A review of the use of firearms on land managed by NRW page 7

[2] Natural Resources Wales, Report by Dr Dam Hillyard and Professor Garry Marvin, Dec 2017

[3] A review of the use of firearms on land managed by NRW page 7

[5] A review of the use of firearms on land managed by NRW page 6

[6] Written evidence submitted by British Association for Shooting and Conservation on the NRW call for evidence April 2017

[7] A review of the use of firearms on land managed by NRW page 7

[8] A review of the use of firearms on land managed by NRW page 8

[9] A review of the use of firearms on land managed by NRW page 11