Hunting Bird Consultation Guide
Confidentiality and Questions about you
Q 1. Would you like your response to be confidential?
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Answer: Yes or No as is your preference
Q 4. Please tell us who you are responding as, selecting from the following: (Please tick as many as relevant)
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Answer: Member of the public
Q 5. If responding on behalf of an organisation, please provide the name of the organisation you are responding for. If you are responding for more than one organisation, please say how many organisations you represent and their category (as set out in the previous question).
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Answer: N/A as member of the public
Q 6. If you are a business, how would you identify based on your number of employees? ​
Answer: Not applicable
Q 7. Considering the reform proposal, are you able to provide any feedback on additional wider impacts to business, competition and trade, skills and training requirements and investment within the sector?
Answer: Yes
Further Information:
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Create training for those who shoot, so they understand the connection between shooting and the extinction of a species.
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There is an ongoing conflict between those who kill for fun and the general public at large. It is time to consider training that addresses the disorders that underpin the desire to kill helpless animals for personal entertainment.
Q 8. If you are a Small and Micro Business (SMB) (qualified as 1-49 employees), are you able to provide any information on impacts, including on additional costs, from the proposed reform?
Answer: Yes or No
Q 9. If you are a Medium-sized business (50-249 employees), are you able to provide any information on impacts, including on additional costs, from the proposed reforms?
Answer: Yes or No
Q 10. Do you foresee any impacts on business from the proposed reform being different between regions across the UK?
Answer: No
Q 11. Please select the geographical coverage of your organisation or the area that your response relates to from the following: (Please tick as many as are relevant)
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Answer: UK
Questions 4A1-4G4
Q 4A1: Do you agree the European white-fronted goose should be removed from Schedule 2.1 in England and/or Wales?
Answer: Yes. Both Nations
Q 4A2: Can you provide more recent evidence on the number of European white fronted goose that are shot in England and/or Wales?
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Answer: Yes or No
Further Information:
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It would be ideal for more recent evidence, but it is unlikely that numbers have increased without removing the threat of shooting.
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However, it is concerning that the European white-fronted-goose has not been removed from Schedule 2.1 sooner. The same N.J. Aebischer, 2019 research reveals that the number shot have remained at less than a hundred in 2004, 2012 and 2016. ​They were added to the Red List in 2015, which is a shameful indictment of our government's priorities.
Q 4B1: Do you agree the goldeneye should be removed from Schedule 2.1 in England and/or Wales?
Answer: Yes. Both Nations
Further Information:
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The goldeneye is on the Red List of Birds of Conservation Concern so should be removed from Schedule 2.1.
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The 2019 N.J. Aebischer research reveals that 680 Goldeneye were shot in 2004, 200 were shot in 2012 and 450 were shot in 2016. The number of Goldeneye shot are a clear reflection on their declining population and should therefore have been removed from Schedule 2.1 a long time ago. A worrying reflection of the Government's priorities.
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There is scientific evidence to prove that anti hunting laws are one of the most efficient ways to ensure population recovery.
Q 4B2: Do you agree the close season for the goldeneye should be extended in Scotland to 30 September?
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Answer: No
Reason/Evidence:
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This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the goldeneye.
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Extending the close season does not protect bird numbers from shooting. This is because a hunter could:
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Go on twice as many shooting trips
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Extend the hours that he is shooting
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Kill twice as many birds
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The Goldeneye is still on the Red List of Conservation Concern in Scotland. As such, we are way beyond employing a precautionary approach in protecting this species. Allowing the Goldeneye to remain on Scotland’s Schedule 2.1 and continue to be hunted is ignoring all scientific evidence and will raise significant red flags.
Q 4B3: Can you provide more recent evidence on the number of goldeneye that are shot in England, Scotland and/or Wales?
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Answer: No
Further Information:
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It would be ideal for more recent evidence, but it is unlikely that goldeneye numbers have increased without removing the threat of shooting.
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Also, relying on the recreational shooting sector to provide accurate, unbiased data on the number of birds they are killing should never be asked or relied upon, particularly since the publication of N.J. Aebischer (2019) research. The revelation of this data has understandably led to strong anti-shoot campaigns.
Q 4C1: Do you agree the close season for the pintail should be extended in Scotland to 30 September for below and above the high-water mark?
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Answer: No
Further Information:
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​This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the goldeneye.
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By asking biased hunters about their hunting bag numbers means that the dataset used to conduct the analysis relies on unscientific data collection. Hunters are deeply investested in keeping this form of entertainment killing active.
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Extending the close season does not protect bird numbers from shooting. This is because a hunter could:
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Go on twice as many shooting trips
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Extend the hours that he is shooting
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Kill twice as many birds
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Extending the close season of Pintails in Scotland has the undesirable cascading effect of more hunters shooting in October and beyond, leading to further harm of the already declining winter population.
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I also believe that removing Pintail from schedule 2.1 in England, while extending the close season for Scotland has a counterproductive effect on population as there is no way to determine if the shot birds are from Scotland or England.
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I believe an easier solution is to remove Pintail from 2.1 for Scotland, Wales and England to allow population recovery.
Q 4C2: Do you agree the close season for the pintail should be extended in Wales to 30 November?
Answer: No
Further Information:
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​This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the goldeneye.
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By asking biased hunters about their hunting bag numbers means that the dataset used to conduct the analysis relies on unscientific data collection. Hunters are deeply investested in keeping this form of entertainment killing active.
-
Extending the close season does not protect bird numbers from shooting. This is because a hunter could:
-
Go on twice as many shooting trips
-
Extend the hours that he is shooting
-
Kill twice as many birds
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Extending the close season has the undesirable cascading effect of more hunters hunting in December and beyond, leading to further harm to the already declining Pintail population.
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Removing Pintail from Schedule 2.1 in England, while extending the close season for Scotland/Wales has a counterproductive effect on population as there is no way to determine if the shot birds are from Scotland or England.
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An easier and safer solution is to remove Pintail from 2.1 for Scotland, Wales and England to allow population recovery.
Q 4C3: Do you agree the pintail should be removed from Schedule 2.1 in England?
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Answer: Yes
Further Information:
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The pintail is on the Amber List of Conservation Concern and as such should automatically be removed from Schedule 2.1. The N.J. Aebischer (2019) research reveals a steady and dramatic decrease in the number of pintails shot. There were 1,400 shot in 2004, 800 shot in 2012 and 680 in 2016.
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It’s vital that the number of birds killed by hunters does not continue to be used as a conservation measure. The insidious links between hunting and conservation create practices like this that are damaging to wildlife protection. It has created a mindset that accepts hunting bag counts as a conservation tool rather than the cause of a species decline.
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There is scientific evidence to prove that anti-hunting laws are one of the most efficient ways to ensure population recovery. If hunting didn't negatively impact bird populations, this consultation would not be happening.
Q 4C4: Can you provide more recent evidence on the number of pintail that are shot in England, Scotland and/or Wales?
Answer: No
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Q 4C5: Can you provide evidence on the proportion and destination (for example private domestic consumption, sold, given to third parties, etc..) of shot pintail birds?
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Answer: No
Q 4C6: Can you provide evidence on what is the market price of pintail both wholesale and retail?
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Answer: No
Q 4D1: Do you agree the pochard should be removed from Schedule 2.1 in England, Scotland and/or Wales?
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Answer: Yes, all three nations
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Further Information:
The pochard is on the Red List of Conservation Concern and as such should automatically be removed from Schedule 2.1. The N.J. Aebischer (2019) research confirms the dramatic decline in the number of pochard that have been shot which indirectly reflects their struggling population. There were 2,400 shot in 2004, 180 shot in 2012 and 370 in 2016.
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Going forward, we should not be using the number of birds killed as a conservation tool. This gives the pro-hunting lobby a foothold in conservation and creates insidious links between hunting and conservation.
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There is scientific evidence to prove that anti-hunting laws are one of the most efficient ways to ensure population recovery. If hunting didn't negatively impact bird populations, this consultation would not be happening.
Q 4D2: Can you provide more recent evidence on the number of pochard that are shot in England, Scotland and/or Wales?
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Answer: No
Q 4D3: Can you provide evidence on the proportion and destination (for example private domestic consumption, sold, given to third parties, etc.) of shot pochard birds?
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Answer: No
Q 4D4: Can you provide evidence on what is the market price of pochard both wholesale and retail?
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Answer: No
Q 4E1: Do you agree the close season for the common snipe should be extended in England and/or Scotland to 30 September, for reasons of both conservation and animal welfare?
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Answer: No, both nations.
Reason/Evidence:
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This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the common snipe. Quite the opposite. As the common snipe is on the Amber List of Conservation Concern, they should automatically be removed from all Schedule 2.1s.
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Asking biased hunters about their hunting bag numbers means that the dataset used to conduct the analysis relies on unscientific data collection. Hunters are deeply invested in keeping this form of entertainment killing and keeping it active.
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Extending the close season does not necessarily protect more birds. This is because a hunter could:
- go on twice as many shooting trips
- extend the hours that he is shooting
- kill twice as many birds -
Extending the close season could therefore mean more concentration of hunters during open season and the same or potentially more birds killed. Particularly if hunters feel pressured to get their kills in due to a shorter hunting season. This would render the iconic common snipe vulnerable to a population collapse over the years.
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Allowing hunting in one or two of the three countries will encourage hunters to travel further to go hunting. This just displaces the problem that hunting causes.
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A much better approach would be to mirror Wales. Removing the common snipe from Schedule 2.1 for England and Scotland would allow the population to recover and address animal wellbeing concerns associated with shooting.
Q 4E2: Do you agree the common snipe should be removed from Schedule 2.1 in Wales?
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Answer: Yes
Reason/Evidence:
There is scientific evidence to prove that anti hunting laws are one of the most efficient ways to ensure population recovery.
Q 4E3: Can you provide more recent evidence on the number of common snipe that are shot in England, Scotland and/or Wales?
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Answer: No
Q 4E4: Can you provide evidence on the proportion and destination (for example, private domestic consumption, sold, given to third parties, etc..) of shot common snipe birds?
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Answer: No​
Q 4E5: Can you provide evidence on what is the market price of common snipe both wholesale and retail?
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Answer: No
Q 4F1: Do you agree the close season for the woodcock should be extended in England and/or Wales to 30 November in order to protect our native breeding population?
Answer: No, this does not mean we are happy with the status quo.
Reason/Evidence:
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This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the woodcock. Quite the opposite.
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I am struggling to comprehend why a species on the Red List of Conservation Concern (BoCC) is not automatically removed from Schedule 2.1. The optics of a bunch of men shooting this iconic ‘prized quarry for the challenge’ is concerning on so many levels. But the optics of the Government simply extending the close season and factoring entertainment killing into legislation that is there to protect the birds, well, it goes beyond comprehension.
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Extending the close season does not protect bird numbers from shooting. This is because a hunter could:
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Go on twice as many shooting trips
-
Extend the hours that he is shooting
-
Kill twice as many birds
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Q 4F2: Do you agree the close season for woodcock should be extended in Scotland to 14 November in order to protect its native breeding population?
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Answer: No. Your proposal is insufficient.
Reason/Evidence:
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This question should allow the respondent to reject the Government's proposal as insufficient, but instead reflects a pro-hunting stance. Please ensure that our 'No' is not taken to mean that we are rejecting protection for the woodcock. Quite the opposite.
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We are struggling to comprehend why a species on the Red List of Conservation Concern (BoCC) is not automatically removed from Schedule 2.1. The optics of a bunch of men shooting this iconic ‘prized quarry for the challenge’ is concerning on so many levels. But the optics of the Government simply extending the close season and factoring entertainment killing into legislation that is there to protect the birds, well, it goes beyond comprehension.
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Extending the close season does not protect bird numbers from shooting. This is because a hunter could:
- Go on twice as many shooting trips
- Extend the hours that he is shooting
- Kill twice as many birds
Q 4F3: Can you provide more recent evidence on the number of woodcock that are shot in England, Scotland and/or Wales?
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Answer: No
Q 4F4: Can you provide evidence on the proportion and destination (for example, private domestic consumption, sold, given to third parties, etc..) of shot woodcock birds?
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Answer: No
Q 4F5: Can you provide evidence on what is the market price of woodcock both wholesale and retail?
Answer: No
Q 4G1: Do you agree to adding woodpigeon to Schedule 2.1 in England, Scotland and/or Wales?
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Answer: No
Reason/Evidence:
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Adding the Amber Listed woodpigeon to Schedule 2.1 could have a catastrophic effect on their population and we recommend the government rethinks this proposal.
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Animal Wellbeing
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Resolving the cruelty associated with all year-round killing of pigeons using General Licenses by removing protection for the woodpigeon on the Wildlife and Countryside Act 1981, is not logical. Especially if the General Licenses are allowed to continue. It simply emphasises the cruelty inflicted upon this species.
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Animal welfare was cited earlier in the consultation as a reason for avoiding cruelty, so we urge the Government to rethink this suggestion which compounds cruelty, not relieves it.
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Wildlife Criminals
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The Consultation states that “there is plenty of evidence to suggest some woodpigeon shooting is carried out for recreation and/or food rather than explicit crop protection.” This means that people are breaking the terms of their General License and are therefore committing wildlife crimes. The Government proposal to add woodpigeons to Schedule 2.1 shows they are prepared to change the law to suit those breaking it. A serious and worrying precedent to set.
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Conservation - Precautionary Principle
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The precautionary principle has been cited several times in the consultation; however, the time to apply it is before there is a problem, not when a bird is on the red or amber list of conservation concern.
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People mustn't be given a legal avenue to hunt woodpigeon for recreation or food. This will create a 'tragedy of the commons', where business models exploit wildlife for free and then become reliant on this system to maintain their lifestyle.
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When a bird becomes rare, it then becomes impossible to change the actions that have caused the problem, as people are desperate to maintain their lifestyle choices and the actions that fund them. eg: businesses that sell meat or shooting.
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Shooting woodpigeons for food and recreation will lead to the ultimate demise of one of our most iconic British species. Similar to the Passenger Pigeon in the US, which went from 3-5 billion in the 1800s to extinction from hunting by the year 1914.
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With other birds removed from Schedule 2.1, this will add significant hunting pressure on the woodpigeon.
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UK woodpigeons are of international importance as they represent 20% of the European population. We therefore have a duty of care to protect this species and consider the bigger implications of our decisions.
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For all of the above reasons, we recommend that the woodpigeon remain off Schedule 2.1.
Q 4G2: Can you provide more recent evidence on the number of woodpigeon that are shot in England, Scotland and/or Wales?
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Answer: No​. I would like to emphasise that asking biased hunters about their hunting bag numbers means that the results of any research will be relying on unscientific data collection. Hunters are deeply invested in keeping this form of entertainment killing active.
Q 4G3: Can you provide evidence on the proportion and destination (for example, private domestic consumption, sold, given to third parties, etc..) of shot woodpigeon birds?
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Answer: No
Q 4G4: Can you provide evidence on what is the market price of woodpigeon both wholesale and retail?
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Answer: No
Questions 5A1-5B3
Q 5A1: Do you agree the coot should be removed from Schedule 2.1 in Wales?
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Answer: Yes
Reason/Evidence:
The coot’s Vulnerable rating in the GB IUCN Red List and the BoCC Amber Rating make this decision logical.
Q 5A2: Do you agree the Schedule 2.1. status of the coot should not be changed but maintained as it is in England and/or Scotland?
Answer: No
Reason/Evidence:
No, as the consultation suggests, there is scientific evidence proving that coots’ wintering population was steadily declining as of 2023. Maintaining Schedule 2.1 status for coots could put them at risk of population collapse. I believe excluding the coot from schedule 2.1 is a sensible solution.
Allowing hunting in England and Scotland would just encourage people to travel further to go hunting. This just displaces the problem that hunting causes and exerts an increased pressure on coot populations in England and Scotland.
Q 5A3: Can you provide more recent evidence on the number of coot that are shot in England, Scotland or Wales?
Answer: No
Q 5B1: Do you agree the golden plover should be removed from Schedule 2.1 in Wales? ​​
Answer: Yes
Reason/Evidence:
The severe long-term decline of breeding golden plover populations to less than 30 pairs makes it essential. How has the shooting of the golden plover been allowed to continue unchecked for so long?
Q 5B2: Do you agree the Schedule 2.1. status of the golden plover should not be changed but maintained as it is in England and/or Scotland?
Answer: No
Reason/Evidence:
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No, I think the golden plover should be removed from Schedule 2.1. As the consultation quotes, the UK wintering population is declining and the easiest way to ensure population stability is anti-hunting laws.
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Birds do not restrict themselves to human borders. With the Welsh population of golden plovers down to a devastating >30 pairs, protecting the populations in nearby countries could help to protect and bolster the Welsh population.