Disagree
The incorrect cost assumptions alone will have caused a significant underestimate of the economic impact. In our answers to Q.10, we estimate the cost of trap replacement for our three (low-ground) gamekeepers to be ca. £17,295, with an offsetting cost (by not replacing Fenn traps for ten years) of £2,327. This gives a trap replacement cost of £4,989 per gamekeeper. If these costs are typical and there are 7,000 gamekeepers as assumed in the IA, this alone suggests that the cost would be £35 million, almost ten times the highest estimate suggested in the IA.
The impact could be five times greater still if users other than gamekeepers need to replace traps, because Defra's figures suggest that only 20% of Fenn-type traps were sold to the gamekeeping sector. If that premise was itself incorrect (i.e. the proportion of traps used by gamekeepers is larger), the impact might again be up to five times larger than suggested. Finally, costs would be 80% higher again if tunnels were purchased rather than home-made.
It is claimed that “because game managers and others will often operate stoat traps to target a range of small predator species, including weasels and rats, there will be consequentially positive impacts for those as well.” This is by no means certain, because the traps proven to be AIHTS-compliant for UK stoats have not been tested for target species other than stoat. One compliant option - the Goodnature A24 – is understood to have been found inhumane for grey squirrels, but it is not clear how this species can reliably be excluded while allowing rat captures.
In any case, the alleged benefit would apply only to the 20% of Fenn traps that are used by gamekeepers, unless the owners of the other 80% also target stoats or feel obliged to upgrade their traps because of the insecurity of their legal position. It is inconsistent to claim that the cost of implementing AIHTS applies to only 20% of the sector, but that the humaneness benefits apply to appreciably more than 20%.
It seems likely that if a 1 January 2019 deadline is enforced, replacement traps will be in short supply in 2019 and possibly for some years thereafter. This will affect the ability of gamekeepers to manage stoats and other pest/predator species. A realistic assessment of the impact of the proposed policy should include the consequences of this for both commercial (shoot) and public (non-game wildlife) interests. The likely impact on pest control in food and forestry sectors should also not be ignored.