Invasive Species Plans Questioned
15 May 2007
GB Invasive Non-native Species Framework Strategy
The National Gamekeepers' Organisation has made the following robust response to the Draft GB Invasive Non-native Species Framework Strategy. This is a set of official proposals for dealing with harmful non-native species throughout Great Britain. The draft framework can be viewed at: http://www.nonnativespecies.org/07_Latest_Developments_(Public_Consultations).cfm
The NGO was specifically asked for its comments but the public can respond as well. The closing deadline for comments is 23 May 2007.
This is what the NGO said:
We find it surprising, not to say highly unsatisfactory, that there were no representatives of gamekeeping, farming, landowning or field sports on the 29- strong Strategy Working Group which produced the draft.
The absence of these interests from the Strategy Working Group perhaps explains why the draft strategy has several serious flaws from a practical standpoint.
The overall aim of keeping harmful non-native species at bay is no doubt shared by us all and the strategy's overall intentions are worthy and in most cases quite well expressed. We feel, however, that the document loses sight at times of the practicalities and realities, so that when the consequences of the fine words are actually thought through, significant practical problems and questions emerge.
Crucially, the strategy does not address the issue of where to draw the line historically in establishing what is ‘native' and what is ‘non-native'. There has been complete muddle over this in recent decades and the strategy as drafted is missing a good opportunity to bring some clarity and logic to bear.
For example we have recently seen officials variously:
- encouraging the eradication of ruddy duck (a genuine non-native)
- facilitating control, but not seeking eradication, of Canada geese (an introduced species that has been here over a century)
- successfully eradicating the non-native coypu (an escapee)
- attempting eradication of the non-native mink (but only in the Hebrides)
- supporting sustainable management of sika deer, fallow deer and muntjac (all introductions or re-introduced species)
- actively encouraging release of red kite, pine marten and beaver on the basis that these species ‘were once native to GB'.
Natural England now wants to see wild boar remain here for the same reason. Meanwhile, it seems that no-one wants to do anything about the escaped eagle owl (a genuine non-native) probably because it has large, appealing eyes and public sympathy! Yet all these species can be harmful in their various ways.
So lets use this framework strategy to get a more sensible, consistent approach.
One concern is that if species such as boar and beaver are being allowed - despite their potential downsides - simply because ‘they were once here', what guarantee is there that officials will not extend this logic and argue that species that ‘were not always here' should consequently be eradicated? Gamekeepers and sportsmen would be in danger of losing several important quarry species: the redleg partridge (introduced c.1770), all three deer species listed above, the pheasant (brought in by the Normans), the rainbow trout (another introduction) and even the rabbit (courtesy of the Romans).
Now clearly the eradication of such common and accepted species is unlikely to be attempted but the list does serve to illustrate that the high-minded objectives set out in the draft strategy do not always make sense when worked through to their logical conclusion.
Moving on to another fundamental point, the draft makes no exemptions that we can see for farming and other important plant and animal management situations. We can see nothing that would have allowed, for example, farmers in GB to rear llamas, alpacas, and ostriches, and going back further possibly even Friesian cows. We can likewise see nothing that would allow for the importation and use of important new crop varieties from overseas (including the past examples of oilseed rape, linseed, lucerne, maize and several of our important gamecrops such as millet, sorghum and quinoa, all of which are invaluable for native seed-eating songbirds). There is likewise nothing to allow the import and holding of exotic animals in zoos, deer parks, safari parks and aquariums, or even as pets.
The Wildlife and Countryside Act took quite a sensible line in preventing the release of animals ‘not ordinarily resident' in GB or which were on a list (Schedule 9, Part 1) of species which are ordinarily resident but deemed not to be encouraged (eg mink, grey squirrel). The Act made a similar provision for plants, allowing gardeners, for example, to grow exotic species in their gardens provided they did not encourage them ‘in the wild'. The system is not perfect, not least because it does not apply the same logic to animals as to plants (you can ‘release' an exotic plant whether it is ordinarily resident or not, so long as it isn't on the list of harmful species (Schedule 9, Part 2)), but it was more workable in a practical sense than what is being implied in the current draft framework strategy.
Next we come to the idea prevalent in the draft strategy (eg paragraphs 3.2 and 6.4) that ‘invasive' species should include anything native within GB but which is being encouraged outside its natural GB range. That may not be too bad if officials only take exception to species which are genuinely causing harm when outside their natural range but if you add to the concept of the precautionary principle, which is also widespread in the draft strategy (eg: para 6.4 "...that may become invasive...", or para 6.5 "...where they could become invasive...", or para 6.7 "...reduce the risks associated with the movement of species outside their natural range within GB"), we could soon get into real problems.
For example, many pheasant shoots in the wetter west of England and in Wales are arguably well outside the ‘natural range' of the pheasant (whatever that is - China?). Likewise, several grouse moors are now sustaining their crucial gamekeeping infrastructure in lean grouse years by releasing redleg partridge on the moorland fringe, where these birds can certainly live but are unlikely to breed particularly well.
If officials are minded to move against these and other similar man-made extensions of ‘natural range', when there is no evidence of an ecological problem and yet there is a proven economic conservation benefit arising from the shooting, how can they not move against the ‘natural' spread of wild boar or sanction the man-made extension to the range of the pine marten and red kite? It makes no logical sense.
Surely the framework strategy needs to allow for the reasonable deployment of useful species (ie natives and non-harmful exotics) beyond their natural range, whether by farmers, gamekeepers or others, or indeed naturally, providing that the benefits outweigh any downsides. It makes nonsense of current practice and our country's agricultural and livestock history to require anything else.
Furthermore, there is no legal framework for insisting on the sub-national management regime suggested, because the Wildlife Act, quite sensibly, addressed this point on a countrywide basis, not at the micro level of the ‘natural range' of each species concerned. The logical extension of the ‘natural range' strategy set out in the draft would be to work at the level of something like Natural England's 159 ‘natural areas'. It just couldn't be done.
We would also like to emphasise two very positive ways in which gamekeepers should be able to help with a sensible strategy in this area.
Because they are in so many ways the ‘eyes and ears' of the wider countryside, keepers are in a very good position to help report the appearance or impact of non-native species. For example, it was often the gamekeeper who first noticed that the grey squirrel had arrived on his patch. It is likewise the gamekeepers in Kent who are so convinced that wild boar should be eradicated because they see the damage they do at first hand, and every day.
Secondly, keepers are a well-trained, well-armed resource with excellent field craft skills who may well be able to assist in any future eradication programmes deemed necessary. They helped considerably, for example, with the eradication of coypu. But this won't be done for nothing in cases where there is no particular benefit for game species. Defra suggested recently that keepers might like to help hunt down the increasing number of non-native parakeets but why should they want to? The keepers certainly could help but the motivation for their involvement needs to be thought through and incentives provided (remember the bounty on grey squirrel tails).
Finally, these last two points and the practical implications of the evolving strategy will best be addressed if gamekeepers are a central part of decision-making in this area and not just part of a very wide public consultation list. We believe the errors and omissions in the draft strategy amply demonstrate why we and the farmers, landowners and sportsmen should have been on the working party which drafted it and why we need to be involved in future with structures such as the Stakeholder Sounding Board.
Notwithstanding our criticisms, the National Gamekeepers' Organisation looks forward to helping the GB Non-native Species Secretariat with its important work. We believe, however, there is still a long way to go before coherent and workable policy can be made in this area. If the strategy as drafted goes ahead, we will all be in for more chaos and not less.