Gamebird Licensing: Defra's Call for Evidence Is Now Open

Quick summary

• Defra's Call for Evidence on gamebird release, shooting and welfare opened on 4 September and closes 1 November.

• It does not propose licensing; Defra says no decision has been taken on changing policy.

• Practical and operational evidence counts, not just peer-reviewed research, so moorland managers can submit directly.

• The MA is pressing for grouse to be assessed separately and for a transparent evidence trail.

Earlier this week we explained why the Moorland Association had begun engaging with Defra over the Government's examination of possible further regulation of grouse and gamebird shooting.

Defra has now published its Call for Evidence on Gamebird Release, Shooting and Welfare during Rearing in England. It opened on 4 September and closes on 1 November.

We have read the 49-page document and attended Defra's pre-launch stakeholder briefing. This is an important stage, but it is worth being clear about where things now stand.

The Call for Evidence does not propose a licensing scheme.

Defra says that no decision has been taken on whether policy should change. The purpose of the exercise is to gather evidence, and any subsequent proposals would be subject to public consultation.

That is important. The question at this stage must remain whether any additional regulation is justified, not simply what form licensing should take.

What is Defra asking about?

The Call for Evidence is wide-ranging.

It asks about the positive and negative effects of grouse shooting, pheasant and partridge release and shooting, and mallard shooting on biodiversity. It also asks about protected sites and habitats, disease, bird-of-prey crime, animal welfare, use of natural resources and the effectiveness of existing regulatory and voluntary standards.

Defra is accepting not only peer-reviewed scientific papers but monitoring information, reports, unpublished material and well-documented practical or operational evidence. It says greater weight will be given to evidence for which the methodology, context and limitations can be demonstrated.

This matters for the MA because Defra is expressly inviting practical and operational evidence, not just published academic research. Moorland managers therefore have an opportunity to put evidence from the ground directly into the process.

Grouse shooting must be considered separately

Although much of the document concerns the breeding, rearing and release of pheasants, red-legged partridges and mallard, it also asks directly about grouse shooting.

Red grouse are fundamentally different. As wild birds, they are not reared and released. Grouse moor management also operates within a very different environmental and regulatory framework.

The MA will therefore continue to press Defra to ensure that evidence concerning grouse shooting is assessed separately from evidence concerning the release of reared gamebirds. Evidence about one activity should not simply be transferred to another because both involve shooting.

We welcome the request for evidence of benefits

We welcome the fact that Defra is asking for evidence of benefits as well as possible harms. That gives us an opportunity to put forward evidence of what managed moorland delivers (including for species, habitats, peatland and wildfire resilience) and of the considerable resources owners commit to conservation. We will now pull that evidence together.

The evidence process must also be transparent

Defra is asking everyone who submits evidence to explain where it comes from, how it was produced and what its limitations are. We think Defra should be equally open about how it assesses what it receives.

At present, Defra has committed to publishing a summary of the evidence and a final report. It has not yet said whether it will publish the submissions themselves, the method used to assess them or any independent review of the evidence.

We have therefore asked Defra to commit to publishing the full evidential audit trail before any policy proposals are developed. If evidence is later used to justify further regulation, members and the wider public should be able to see how that conclusion was reached.

Defra has told us that it intends to publish the results of the Call for Evidence. We are now seeking clarity on exactly what that will include.

Separately, Defra is commissioning an independent assessment of the economic value of the gamebird sector. We will also ask how that work will feed into Defra’s wider assessment before any decisions are taken.

What the MA is doing now

The MA will respond fully on the issues that affect grouse shooting and moorland management. We are now bringing together evidence on the conservation benefits of managed moorland, habitat and vegetation management, wildfire resilience, predator management, the existing regulatory system and the practical consequences of adding further regulation.

We will also look closely at the evidence relating to wildlife crime, including the distinction between proven offences and wider assumptions or associations.

Alongside that, we will continue asking a basic question: what problem would any new licensing system actually solve that existing law and regulation cannot?

How members can help

Members who wish to respond now can do so. At this stage, Defra is primarily asking for evidence, so the most useful submissions will be those supported by documented information, practical experience or data.

Over the coming weeks the MA will also contact members where we need specific evidence to support our own response, including monitoring data, conservation outcomes, expenditure, experience of existing licences and consents, examples of overlapping regulation and evidence of the practical consequences of management decisions.

We will also provide further guidance for any members who would find it helpful when preparing their own submissions.

The Call for Evidence closes on 1 November, so there is still plenty of time to put together a considered response.

What happens next?

The MA will now prepare its response and continue engaging with Defra as the evidence is gathered.

Our position remains straightforward: the Government should first establish whether there is an evidenced problem that existing law and regulation cannot address. Only then should it consider whether further regulation is necessary.

If Defra later proposes licensing or another significant change, it has said there will be a public consultation. We will keep members informed as the process develops.