Natural England recently held a consultation on proposed changes to the Class and General Licences. While these changes are ostensibly aimed at protecting vulnerable species, concerns have been raised about a number of the proposals, including onerous new requirements for those involved in wildlife management.
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The State of Nature Report 2013 describes nature as being “in crisis”. It is therefore disappointing that this consultation, rather than imaginatively seeking ways in which to help to alleviate this crisis, appears only to seek ways to make the tasks of those most closely associated with wildlife management more onerous. Throughout the consultation document we are asked why a proposed change should not be made rather than the facts set out as to why the change is being proposed in the first place.
The contribution that good game management makes to the conservation of many species is well documented and NE should be finding ways to encourage people to carry out measures which help species recovery not gold-plating the operating standards we already have.
The consultation states that NE aspires to “reduce any unnecessary burdens on those we regulate” but then appears to find a raft of what we can only assume is what it deems to be “necessary” extra obligations despite the fact that they have never been required previously.
Where “requests have been received” or “welfare concerns have been raised” no evidence is presented as to whom these requests have come from, what the specific concerns are or any published evidence to support them. It is also said that some of the changes are required to prevent infraction proceedings at EU level, but we are not aware of any such infractions being threatened at present.
There are also areas of concern that we have raised in the past which have not been included in the consultation. Surely if the consultation exercise is to be meaningful it should consider all areas of concern, not just a selected few?