Memorandum submitted by National Gamekeepers'
Organisation
1. The National Gamekeepers' Organisation
is pleased to make the following short comments to the EFRA Committee
considering the recently published Animal Welfare Bill.
2. For the record, the NGO was founded in
1997 and now has over 9,500 members. It represents the gamekeeping
profession in England and Wales. More details about the organisation
can be found on our website: www.nationalgamekeepers.org.uk
3. The NGO has supported the concept of
a revision to animal welfare legislation since it was first suggested
some four years ago.
4. In general we are pleased with the Animal
Welfare Bill as published. The long period of consultation has
been helpful in reaching agreement.
5. The twin concepts of "prevention
of harm" and "promotion of welfare" are well addressed
in the Bill.
6. The idea of leaving the detail for each
sector (including game rearing) to secondary legislation has our
support.
7. In this context we welcome the Government's
stated intention to use the existing code of the Game Farmers'
Association to assist in formulating a Defra code for game rearing
in due course.
8. We note the Government has also said
that the Bill is not intended to affect shooting.
9. The provision of live quarry shooting
depends in large measure on the work of the gamekeepers we represent.
An important part of any gamekeepers work is the legal control
of predatory species such as foxes, crows, magpies, rats and stoats.
10. The definition of protected animal used
in the Bill (Clause 2) would include wild animals held in traps
and snares.
11. Defra have confirmed in their recent
response to the report of the Independent Working Group on Snares
that an animal caught in a snare would also "after a time"
become the responsibility of the person who set the snare (Clause
3).
12. We want to be certain that a gamekeeper
using legal traps and snares in accordance with other relevant
laws will not fall foul of offences under the Animal Welfare Bill
in relation to caught birds and mammals. We ask for the EFRA committees'
support on this point.
13. We have related concerns about the possible
(mis)application of the welfare and cruelty offences to gamebirds
released for shooting. Although the Government has assured us
that the Bill as drafted is not intended to prevent the shooting
of released birds, they have also said that the question of whether
a gamekeeper might still be deemed "responsible for"
his birds under Clause 3, and therefore guilty of a cruelty offence
under Clause 4 if he allowed someone to shoot them, is ultimately
a matter for the courts.
14. We do not think the passage of a Bill
which is open to question on this point is consistent with the
Government's oft-stated support for shooting and we ask for the
EFRA committees' support in tightening this up.
November 2005
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