NGO Response to Gamebird Welfare Code For Wales
12 April 2010
The Response of the National Gamekeepers' Organisation to
The Welsh Assembly Government's Public Consultation on
A Gamebird Rearing Code for Wales
General Comments
The NGO represents gamekeepers in Wales and England and has 14,500 keeper and supporter members. Many of the estates and shoots buying gamebirds from game farms have NGO members as their gamekeepers. Several thousand of our members are also involved in game rearing programmes of their own.
Game shooting is an important economic and social activity in rural Wales. It is essential that the gamebird code, whilst ensuring good welfare, does not impact unnecessarily on the industry.
As one of the bodies represented on the GB Gamebird Working Group, which helped to write the draft gamebird code on which the Welsh Assembly's text is based, the National Gamekeepers' Organisation (NGO) welcomes the draft code sent out for consultation.
We want to see high standards throughout shooting and gamekeeping. Bird welfare during the rearing process is particularly important. The NGO has long supported the Game Farmers Association's voluntary Code of Practice as a good standard for all who rear gamebirds and, though our support of the wider Code of Good Shooting Practice, we expect our members to be guided by it. The proposed Welsh Assembly code is closely modelled on the pre-existing GFA Code.
Having been part of the Working Group which examined and amended that text, the NGO is content with the WAG code in the form it has been sent out for consultation. To us it combines the essential characteristics of simplicity and practicality with a good base standard of animal welfare.
On the unresolved issue of raised laying units/cages, our settled policy is on our website at: http://www.nationalgamekeepers.org.uk/library/resource/39/ In essence, we think that good management within any system is more important than the type of system itself and we believe that individual shoots and gamekeepers should be left to decide for themselves which laying/rearing systems to use or to buy from. As long as legislation requires a satisfactory overall welfare outcome - which the 2006 Act and Option 2 will do - the choice of system should be a matter for individuals and not for Governments.
Don't Repeat What has Happened in England
We know from our attendance of the GB Gamebird Working Group that the Welsh Assembly Government has always seen the benefit of the gamebird codes for Wales and the rest of the UK being the same. We agree strongly with that, provided that a good text is used. The text on which the Welsh Assembly is consulting is very good and, with Option 2 on cages, is supported by the Farm Animal Welfare Council.
The English consultation began with the same text, which we welcomed, but the English code as laid before Parliament on 15 March has departed from it markedly, without further consultation or impact assessment. It has turned from being a sensible, practical codification of exiting good welfare practice into a document that effectively bans things, such as small area laying systems (on-ground as well as raised cages) and gold plates others, such as inspection times. Its requirement that incoming birds may not be mixed with existing laying flocks is totally impractical and will have widespread impacts on gamekeepers. We have called for the English code to be withdrawn and re-worked. We still hope for a good text that can be used throughout the UK. Perhaps the Welsh Assembly can show the way!
Answers to the Welsh Assembly's Specific Questions
Within the consultation document there are 24 questions for stakeholders to answer. Our response to these follows and if we can help amplify them in any way we will be pleased to do so.
Q1. Do you agree that a code of practice is the most appropriate option or do you consider that game farms should be regulated?; if so, who should regulate them?
We agree that a code of practice is the right approach. Regulation would be going too far. Apart from large game farms, there are many individuals who rear modest numbers of gamebirds, including many of our members. It would be hard to regulate for these very differing scales and systems of rearing. A code that sets out the basic welfare principles is clearly the right approach.
Q2. Do you think that a code reflecting the gamebird rearing season is the most sensible approach?
Yes. It will be easier to understand and follow if set out that way.
Q3. Is it clear and easily understandable?
Yes. The Welsh Assembly just needs to make sure that in any accompanying publicity it is made clear that the code applies to all who rear, and not just to game farmers. The consultation document is unclear on this point although the text of the draft code itself is fine.
Q4. Or do you think it should be set out in the alternative format with sections relating to each of the animal's five needs?
No.
Q5. Is it useful to have an Annex containing information on other legislation affecting gamebirds?
Yes, very. Knowing which of the many laws applies is far from easy.
Q6. Are there any additional recommendations that should be in the code?
No. The GB Working Group spent many months considering all aspects of rearing and everything that needs to be covered in the code is already in there. Things which are not included were left out for the very good reason that rearing systems are highly varied. Getting too specific in the text of the code would therefore be problematic. The code as drafted combines a good standard of welfare with the flexibility to rear birds in different ways. This is important.
Q7. Do you consider that cages can provide adequately for the welfare needs of breeding pheasants? Or do you consider that barren cages should not be used for the housing of breeding pheasants? Or do you consider that all cages for breeding pheasants should not be used?
Barren cages should not be used for pheasants because by definition they cannot provide for the birds needs in accordance with the Animal Welfare Act. We can see no justification, however, for banning cages that do provide for the birds welfare needs and we therefore support Option 2 under paragraph 6.11. It would be good to have more research on which to base the design, enrichment and management of cages so as to ensure that they provide for the birds' needs and we regret that Defra has had to cancel the research programme on which it was about to embark. In the meantime, the advice of the Farm Animal Welfare Council and the GB Gamebird Working Group should be followed, which was that barren systems should not be used.
Q8. Do you consider that cages can provide adequately for the welfare needs of breeding partridges? Or do you consider that barren cages should not be used for the housing of breeding partridges? Or do you consider that all cages for breeding partridges should not be used?
Barren cages should not be used for partridges but properly enriched and well-managed raised pair units which provide for all the birds needs should be allowed. This middle way (Option 2) was what FAWC recommended and we see no justification to go further. A total ban on all cages would affect lots of our members, who either used raised partridge systems or who buy eggs, chicks or poults from them. It would just have the effect of exporting partridge egg production overseas, where the French in particular are just waiting to snap up more business from the UK.
Q9. Do you consider that having a standard definition for a cage is necessary for a clear understanding by keepers if cages are to be restricted or banned? If so would the EFSA definition be a suitable approach?
No. A definition of a cage would be problematic and arbitrary. The key thing is that any system should provide for the needs of the birds - which is what the Act and the code require. Anything that does not provide for those needs should not be allowed and would not be allowed under the code and Option 2. It is the result in terms of bird welfare that matters, not the name or definition given to any particular system.
Q10. Do you consider that setting space allowance for breeding pheasants and partridges would address the concern?
No. See above. Setting arbitrary space allowances would not guarantee good welfare and there is insufficient evidence available to do so. The issue of whether or not there is sufficient space is best judged by the condition of the birds. In any case, poorly treated birds do not perform well so it is in the producer's interests to make sure his system is well-designed and managed.
Q 11. What would be the space allowance for an adult pheasant and what is the evidence that this is appropriate?
We oppose the setting of arbitrary space requirements. The issue should be judged by outcomes. ‘Enough to ensure good bird welfare and the birds needs' is the answer and that will vary depending on the system. Things like enrichment and, in particular, the standard of management will make a big difference. Isolating space as an issue is illogical and misleading. Any laying system has to be looked at in the round.
Q12. What would be the space allowance for an adult partridge and what is the evidence that this is appropriate?
See Q11.
Q13. Do you agree that spectacles should not be used? Or do you consider that spectacles have welfare benefits provided they are used appropriately?
We support the wording used in the draft code that ‘spectacles should not generally be used.' This wording makes it quite clear that the expectation is that specs will not be used, but it also provides that in really exceptional circumstances someone may be able to justify their use within the code.
Q14. Do you agree that the use of bits for younger pheasants should continue when justified, monitored and fitted on an enterprise-by-enterprise basis as described above?
The correct use of bits is absolutely fundamental to the continuance of game rearing and shooting in this country and they should always be monitored and justifiable on a case-by-case basis. The recent studies by the GWCT showed that without bits, welfare would be worse.
Q15. Do you agree that bumpa bits should only be used in exceptional circumstances?
Yes.
Q16. How many producers, to your knowledge house pheasants in cage systems in Wales?
We are not certain but fewer than 10.
Q17. Pheasant keepers currently using cage systems are estimated to have approximately 1,000 cages on average. Is this estimate reasonable?
It seems reasonable.
Q18. How many partridge keepers within Wales use cage systems?
We are not certain. More than use them for pheasants. Perhaps 20.
Q19. Partridge keepers currently using cage systems are estimated to have around 2,000 cages on average. Is this estimate reasonable?
It will vary widely but as an average this is probably about right.
Q20. How many partridge establishments are there in Wales that use a) metal cages, b) wooden cages?
We do not know but generally wooden ones are more common than metal.
Q21. How many pheasant establishments are there in Wales that use metal cages?
Wooden cages for pheasants are rare, so most will be metal.
Q22. What impact will the code of practice have on the number of gamekeepers in Wales?
As drafted, and assuming Option 2 on cages, the code will have little if any impact on the number of keepers in Wales. Option 3 on cages would restrict the availability of eggs, certainly in the short term, and might therefore have some translation into job losses.
Q23. A cost per establishment of £300 has been suggested for ‘Flock Health & Welfare plans', does this seem reasonable?
Yes.
Q24. Cage enrichment costs of £5-£15 for pheasants and £0-£10 for partridges have been suggested, are these reasonable?
Probably reasonable.