Wildlife Health Strategy
NGO comments on a Government Consultation
20 September 2007
The National Gamekeepers Organisation (NGO) was pleased to be included by Defra in their consultation (begun during July 2007) on Working Towards an Wildlife Health Strategy.
For the record, the NGO was founded in 1997 and now has over 10,500 members. It represents the gamekeeping profession in England and Wales. More details about the organisation can be found on our website: http://www.nationalgamekeepers.org.uk/
The NGO assisted Defra with the preparation of its wider Animal Health Strategy some years ago and we are pleased to see this is now being rolled out into other areas, including wildlife health.
As professional wildlife managers, gamekeepers have been more aware than most about the implications of disease in wildlife. In particular our interests are in four areas:
- Diseases of wildlife species (and especially game species) which damage the harvestable population. The best example would be grouse disease (Trichostrongylosis) which has been the major factor affecting annual grouse numbers for over a century but there are others too.
- Diseases which pass between wildlife and kept animals, such as Avian Influenza (wildfowl, gamebirds and poultry), Foot and Mouth Disease (cattle, pigs, sheep and deer), Swine Fever (pigs and wild boar) TB (deer, badgers and cattle). Most can move both ways of course.
- Diseases of wildlife which can threaten human health - particularly those in close proximity to wildlife, such as gamekeepers. Examples include Rabies, Lyme Disease, TB, Rabbit Flu and Weils Disease.
- The commercial and environmental impact of some of the emergency measures used to manage outbreaks of notifiable diseases in wild and/or farmed animals (AI, FMD, Blue Tongue, etc). For example, the FMD and AI related bans on shooting, deer stalking and predator control have recently caused major problems for some of our members
We agree that too little interest has been shown by Government in wildlife diseases in the past. Just about the only long term monitoring of wildlife disease has been in the field of game management. As front line wildlife managers we are pleased Defra is now addressing this subject area and we believe our members can play a significant role in the future.
Gamekeepers are often among the first people to notice ill-health in wildlife populations. This might be through coming across dead ducks, for example, or noticing lesions in shot deer, or simply being aware of the extent of fox mange or myxomatosis on their patch.
Gamekeepers are also a skilled, well equipped and well-distributed force on the ground. We could be used in culling operations related to disease control, as has been suggested in discussions about badger control and bovine TB, and also in the rabies contingency control plan. We already monitor TB incidence in shot deer and look for trichenella in wild boar.
We certainly need to be kept informed of any new or spreading diseases of wildlife that might affect the welfare of the species we are managing, kept livestock and/or our own health. We agree, therefore, that better communication between all parties is absolutely crucial.
We are, however, concerned at questions in the consultation paper (page 26) about restricting or licensing the release of native species. We have already made some forthright comments in response to similar suggestions in Defra's other consultation about non-native wildlife and the idea of restricting release seems to have come up again here. We would remind Defra that over 80% of UK shooting, valued last year at £1.6 billion, is dependent on the release of gamebirds such as pheasant and partridge.
Our answers to Defra's specific questions in this consultation are:
1. A chart detailing responsibilities for wildlife would be useful and gamekeepers should feature prominently on it.
2. A communications network or group to liaise about wildlife health issues would be useful. Email communication and occasional stakeholder meetings would be the best way to organise it.
3. The National Gamekeepers' Organisation would certainly wish to be involved in the above but costs need to be kept down and please remember that we and other stakeholders are not based in London.
4. We are not qualified to say whether links with overseas governments in this general subject area need to be improved.
5. Defra could certainly assist collaborative research and action by facilitating better communication between all parties and by circulating the results of any research that is going on.
6. The NGO should certainly be included on Defra's database of specialists in wildlife health. The ways in which we could contribute knowledge and skills are outlined in our general remarks above.
7. We could not currently provide statistics on wildlife disease as no-one keeps or collates them nationally but it should be possible for gamekeepers to help put some kind of monitoring and record keeping in place providing Defra is prepared to pay for it.
8. In the short term we do not have any data that could usefully be fed into RADAR.
9. Wildlife health issues certainly need to have a higher profile within Government decision-making. If evidence were needed for that, the chaos caused by the likes of AI and FMD is surely sufficient.
10. Gamekeepers could certainly help with providing carcases for surveillance. One problem in the past has been that when requests for these have been made, the arrangements for collection have been poor. If you want to get material, you have to be prepared to come and collect it when we have it - not always predictable in advance.
11. We are sure that research has a part to play in national wildlife health surveillance. Access to private land in order to undertake research and sampling is always an issue and needs to be carefully addressed.
12. Data quality and consistency are clearly crucial. Individuals vary in their powers of observation and ability to record things. It is important to make any surveillance forms etc as simple as possible. Time is always of the essence to gamekeepers.
13. The NGO would probably be happy to join a "wildlife health stakeholder partnership initiative" if we knew what that meant!
14. We are sure that our organisation and, more importantly, the gamekeepers themselves, could only benefit from a better general understanding of wildlife health, disease, and its control.
Diseases of game species and the impact of either not managing them (badgers and TB) or over-managing them (closing down large tracts of the country to address AI) are a constant problem for gamekeepers.
Concerns about zoonoses such as Lyme disease, TB and Weils disease are also high. Any improvements in overall wildlife health and its management will help.
15. We feel we could contribute as set out in our general comments above.
16. We are very concerned at the implication in this question that licensing or restricting the release of native species is under consideration. See also our comments on this above. The release of gamebirds is crucial to the UK rural economy and we see no evidence whatsoever that it should be limited or bureaucratised in any way.
17. We are not qualified to say whether wildlife re-habilitation projects pose a significant health risk to free-living wildlife but we would doubt it. There seems to be little evidence and there is surely at least as great a risk posed by walking dogs in the countryside or allowing pet cats to roam. We think Defra should stick with the bigger issues.
18. If a code of practice to address the health risks of rehabilitation programs is really needed, it just needs to say two things: ‘don't release a sick animal that might infect wildlife' and ‘don't realease unfit animals that cannot cope with life in the wild'.
19. Restricting the importation of wildlife is unlikely to affect our members, depending slightly on what is meant by the term. Restricting the import of ‘agricultural' animals, however, certainly would affect us, as most of the pheasants and partridges released in the UK have their origins overseas. (There is a good ADAS paper which summarises what goes on within the industry). If the import of pheasants and partridge, especially from France and other parts of the EU, were to be restricted we would experience real problems on a massive scale. Game managers do occasionally also import breeding stock from the US and other third countries but all these imports (EU or further afield) are already covered by import legislation and health checks. Is there really a problem here that needs addressing?
20. In summary, our ‘top three' wildlife health issues that we would like to see addressed in a Wildlife Health Strategy would be:
- Better surveillance of what disease is out there
- Better communication between all those affected
- A more even approach to tacking wildlife diseases, moving away from the current scenario of under managing some (eg TB), yet massively over-managing others (eg AI/FMD).