Defra Gamebird Call for Evidence: Read the MA’s Draft Response and Help Us Strengthen It
Quick summary
The MA has published its draft response to Defra’s Call for Evidence on gamebird release, shooting and welfare.
Members should check it for missing evidence or practical errors and send comments by Friday 16 October.
Annex 1, the Evidence Schedule, sets out the principal sources, what each shows and its limitations.
Estates can submit their own evidence to Defra; separate guidance and a 30th September Zoom meeting explain how.
What we need from members
The Moorland Association is today publishing its draft response to Defra’s Call for Evidence on gamebird release, shooting and welfare.
Before we submit it, we are asking members to do three things:
1. Read the MA’s draft response and tell us if we have missed important evidence, misunderstood a practical point or failed to explain something clearly enough.
2. Send any corrections, comments or additional evidence to agilruth@moorlandassociation.org by Friday 16 October, so we have time to consider them before the final submission.
3. Consider submitting your own estate-level evidence directly to Defra where you hold useful records or practical evidence. We have published separate guidance to help members do that.
Need help with your own submission? We will hold a members’ Zoom session at 6pm on 30 September to talk through the process and answer practical questions.
Published today
1. MA draft response to Defra – our proposed organisational submission
2. Annex 1: Evidence Schedule – the principal evidence relied upon and its limitations
3. Guidance for members – how to submit useful estate-level evidence directly to Defra
The MA response deals principally with wild red grouse and the management of England’s uplands, rather than the breeding and release of pheasants, partridges and mallard.
Why we are publishing the draft
Defra’s Call for Evidence opened on 4 September and closes at midnight on 1 November.
Defra says that no decision has yet been taken on future policy. Its stated purpose is to gather evidence, identify areas where evidence is incomplete, uncertain or contested, and use that material to inform any future policy development.
The MA has now prepared a substantial draft response dealing with the questions most directly relevant to red grouse shooting and the management of England’s uplands.
This is not yet the final MA submission.
We are publishing it now so members have a genuine opportunity to scrutinise it before it goes to Defra. If we have missed important evidence, misunderstood what happens in practice or overlooked estate-level information which would strengthen or qualify what we have said, we want to know.
What does the MA response say?
At its heart, our submission asks Defra to look at what the evidence actually shows about individual management practices and their outcomes, rather than starting with a conclusion about grouse shooting as a whole.
Red grouse are wild birds. They are not bred, reared or released. Evidence concerning grouse shooting therefore needs to be distinguished from evidence concerning released pheasants, partridges and mallard.
The draft also argues that “grouse shooting” or “grouse-moor management” cannot sensibly be treated as one single environmental pressure.
The relevant evidence concerns a series of different activities: habitat and vegetation management, lawful predator control, grazing, hydrology, wildfire-risk management, monitoring, access and the harvesting of grouse. Different practices can have different effects on different species, habitats and places.
The evidence is not all one way.
There is credible evidence of adverse impacts associated with some practices and of illegal killing and other offences against birds of prey. There is also experimental and observational evidence of positive outcomes associated with some aspects of grouse-moor management, including for ground-nesting birds and upland habitats.
Our draft therefore asks Defra to do six things consistently:
assess individual practices and measured outcomes, rather than attributing everything to the label “grouse shooting”
consider what would actually happen if the existing management system changed or ceased
recognise uncertainty and conflicting evidence where it exists
deal with demonstrated problems in a proportionate way
consider the wider consequences of change, including what happens to management, jobs and conservation investment
make the way it assesses the evidence open and capable of being checked
That last point matters. If evidence is eventually relied upon to justify a change in policy, everyone should be able to understand what evidence was included, how it was weighted, what contradictory evidence was considered and where significant uncertainty remains.
Why we have published the Evidence Schedule
Alongside the main draft we are publishing Annex 1: the MA Evidence Schedule.
This is important because it does something rather different from a conventional bibliography.
For each of the principal sources, we explain what kind of evidence it is, what it is being used to show and the important limitations that need to be kept in mind.
We have deliberately not suggested that every source should be given the same weight.
A peer-reviewed experiment, Government evidence review, commissioned report, practitioner survey and individual operational record are different types of evidence. Each should be considered for what it can reasonably establish.
That applies equally to evidence which supports and challenges existing grouse-moor management.
The Schedule also recognises that practical evidence from estates can be valuable without pretending that it is equivalent to independently audited or peer-reviewed research.
Operational and practitioner evidence may capture management, restoration, monitoring and practical delivery which academic research does not. What matters is being clear about where the evidence came from, what it shows and what its limitations are.
What should members look for?
As you read the draft, please ask yourself three questions:
Is it factually right? Does it accurately describe what happens on the ground?
Have we missed evidence? Is there a paper, report, dataset or estate record which strengthens, challenges or qualifies what we have said?
Have we missed something important in practice? Is there an issue Defra needs to understand which is not properly captured by published research?
We are particularly interested in evidence concerning species monitoring, habitat and vegetation management, peatland restoration, wildfire prevention and response, regulation and licensing, wildlife crime, grouse counts and harvesting, employment, skills and community participation.
Please do not assume that because the draft is detailed the evidence-gathering is finished. A well-documented example from one moor may be valuable precisely because it shows what happens in practice.
Commenting on the MA draft and making your own submission to Defra are two separate things. We would welcome both.
Your own evidence matters
You do not need to produce an academic paper. Defra has expressly said that it welcomes monitoring data and well-documented operational or experiential evidence.
That means evidence held by individual moors may be directly relevant to Defra’s review.
The MA’s submission can bring together the wider evidence base, but it cannot substitute for evidence from individual places.
Estate records may contain information about species counts, habitat work, peatland restoration, wildfire prevention and response, management inputs, staff and equipment, licences and consents, or other practical outcomes which are not captured in published studies.
Defra has also subsequently confirmed that, while personal views and observations are welcome, its assessment will focus on evidence falling within the scope of the exercise and addressing its questions.
A short, clearly evidenced estate submission can therefore be very useful to Defra. It does not need to be a lengthy response covering every issue.
Guidance for your own submission
To help with this, we have also published separate guidance for members on submitting estate-level evidence to Defra.
The guidance explains:
which questions are likely to be most relevant to grouse moors
the types of estate records and practical evidence which may be useful
how to explain where information came from
how to distinguish an observed result from an assumption about what caused it
how to record relevant dates, locations and methodology
why it is useful to acknowledge the limitations of your own evidence
You do not need to answer every question in Defra’s Call for Evidence. A clearly documented piece of evidence addressing just one relevant question can still be useful.
Members’ Zoom meeting
We will also hold a members’ Zoom meeting at 6pm on 30 September to help members who are considering making their own submission to Defra.
The session will talk through the Call for Evidence, highlight the questions most relevant to grouse moors, explain the types of estate-level information that may be useful, and give members the opportunity to ask practical questions about preparing and submitting their evidence.
If you plan to join the Zoom meeting, please register below:
Please help us improve the MA submission
We would now welcome comments on the draft.
In particular, please tell us if:
we have missed an important paper, report or dataset
a statement does not reflect practical experience on the ground
you have evidence which supports or qualifies one of the points made
an important limitation has not been acknowledged
there is something Defra needs to understand which the draft currently fails to explain
Please send comments and supporting material to agilruth@moorlandassociation.org by Friday 16 October so that we have sufficient time to consider them before the final submission.
What happens next?
The Call for Evidence closes on 1 November 2026. Defra states that submissions received after that deadline will not be analysed.
We will consider members’ comments, continue reviewing relevant evidence and revise the MA response before it is submitted.
Members are also encouraged to consider making their own evidence submission where they hold useful information. Our guidance published alongside this update is intended to make that process as straightforward as possible.
The purpose of publishing our draft now is simple: the MA’s final submission should contain the strongest evidence available, describe that evidence accurately and acknowledge its limitations.
If you can help us do that, please do.
