Memorandum submitted by British Association
for Shooting and Conservation (BASC) (BTB 21)
EXECUTIVE SUMMARY
1. Written response of the British Association
for Shooting and Conservation (BASC) to the Environment, Food
and Rural Affairs Committee inquiry in to the Defra consultation
on Controlling the Spread of Bovine Tuberculosis in Cattle
in High Incidence Areas in England: Badgers.
2. The Government will decide whether culling
badgers is the most appropriate method for controlling bovine
TB and is seeking comments on three methods of culling namely
shooting, snaring and gassing.
3. BASC supports and actively promotes humane
predator and pest control and have wide experience in providing
and delivering best practice guidance to practitioners.
4. BASC supports a range of culling methods
being made available to land managers to enable them to assess
which method or methods are most appropriate for their particular
set of circumstances.
5. SHOOTING OF
FREE RUNNING
BADGERS
5.1 Night shooting is a well-tried, safe
and humane method of fox control used by gamekeepers and other
land managers, which could be extended to control free running
badgers.
5.2 Badgers may be shot within the terms
of an appropriate license using firearms and ammunition that comply
with the Protection of Badgers Act 1992.
5.3 Potential licensees wishing to use firearms
will need to apply to their police firearms licensing department
for an appropriate variation on their firearm certificate to control
badgers.
5.4 BASC supports the proposal for a close
season for badgers extending from 1 February to 31 April to avoid
shooting lactating sows with dependant cubs.
5.5 Under the Wildlife and Countryside Act
1981 the following are prohibited:
(a) the use of an automatic or semi-automatic
weapon to kill a badger;
(b) any device for illuminating a target
or sighting device for night shooting, and any form of artificial
light to kill a badger; and
(c) use any mechanically propelled vehicle
in immediate pursuit of a Schedule 6 animal, which includes a
badger, for the purpose of driving, killing or taking it. Without
legislative changes the night shooting of badgers would remain
illegal.
6. BODY SNARES
6.1 Where night shooting is not feasible
snares offer an effective and humane alternative. Badgers are
largely nocturnal and predictable in their habits:
6.2 The consultation paper refers to the
use of "body snares" for catching badgers, as opposed
to the neck snare currently used in England for catching foxes.
This new type of snare will therefore be unfamiliar to operators
and the methodology used is fundamentally different from that
used to catch foxes.
6.3 Snares used for catching badgers would
need to be constructed differently from fox snares.
6.4 The Wildlife and Countryside Act 1981
requires snares to be inspected at least once every day, however,
snares used for badgers could be inspected at relatively shorter
intervals throughout the hours of darkness, for example three
to four hours after setting.
6.5 Badgers caught in snares would be despatched
quickly and humanely by a shot from a rifle, shotgun or pistol.
6.6 BASC recommends that where snaring is
permitted under license to control badgers it should be carried
out in accordance with an agreed, dedicated code of practice.
7. GASSING
7.1 Gassing should be considered as one
of a range of methods which could be made available to land managers,
however, there are currently no compounds licensed for use in
the UK other than for the control of moles, rats and rabbits.
7.2 BASC supports current research in to
the use of carbon monoxide to control badgers.
8. CARCASS DISPOSALS
8.1 The culling of badgers to prevent the
spread of bovine TB will be an action sanctioned by Government
therefore carcass disposal and any associated cost burdens must
be met by the State and not transferred to licensees.
8.2 Bovine TB is a notifiable disease. The
appropriate statutory agency should be responsible for organising
appropriate training, delivery of equipment for the safe collection
and storage of carcasses on site and for the collection and disposal
by incineration in approved establishments.
SUBMISSION
The Government is undertaking a consultation
on Controlling the Spread of Bovine Tuberculosis in Cattle
in High Incidence Areas in England: Badgers. The Environment,
Food and Rural Affairs Committee are seeking comments on the key
questions the Ministers must address in reaching conclusions on
the issues set out in the consultation paper. BASC welcomes the
opportunity to comment.
1. ABOUT BASC
BASC was founded in 1908 as the Wildfowlers
Association of Great Britain and Ireland and is the UK's largest
shooting association. BASC is constituted as an Industrial and
Provident Society and has a membership in excess of 123,000. BASC
is the representative body for sporting shooting in the UK. It
aims to promote and protect sporting shooting and the well being
of the countryside throughout the UK and overseas. It actively
promotes good firearms licensing practice, training, education,
scientific research and practical habitat conservation. BASC believes
that all who shoot should conduct themselves according to the
highest standards of safety, sportsmanship and courtesy, with
full respect for their quarry and a practical interest in wildlife
conservation and the well being of the countryside.
1.1 BASC's expertise in shooting matters
is widely recognised and it is routinely consulted by a variety
of government departments and agencies (including the Home Office,
Defra, LANTRA, The Health and Safety Commission) and other statutory
and non-statutory bodies.
1.2 BASC is a registered assessment centre
for the Deer Management Qualifications (DMQ) offered by Wild Deer
Management Qualifications Limited in association with the leading
organisations involved in the deer industry in the United Kingdom.
The Deer Management Qualification is a practical assessment standard,
which includes coverage of game meat handling issues and is used
as a basic bench mark for both professional and part time deerstalkers.
1.3 BASC's comments are set out below and
we have only commented on those aspects of the consultation that
we consider relevant to our membership and the wider shooting
community. We will of course be happy to discuss any aspect of
our response further, should it be required.
PROPOSED METHODS OF CULLING
The Government will decide whether culling badgers
is the most appropriate method for controlling bovine TB and is
seeking comments on three methods of culling namely shooting,
snaring and gassing. BASC supports and actively promotes humane
predator and pest control and has wide experience in providing
and delivering best practice guidance to practitioners.
BASC supports a range of culling methods being
made available to land managers to enable them to assess which
method or methods are most appropriate for their particular set
of circumstances.
2. SHOOTING OF
FREE RUNNING
BADGERS
2.1 Night shooting is a well-tried, safe
and humane method of fox control used by gamekeepers and other
land managers, which could be extended to control free running
badgers. In 1996 BASC produced a code of practice on the night
shooting of foxes, commonly known as "lamping", which
is widely regarded as the standard by which lamping should be
carried out. The code is also circulated by a number of police
firearms licensing departments with shotgun and firearms certificate
renewal forms.
2.2 Badgers may be shot within the terms
of an appropriate license using firearms and ammunition that comply
with the Protection of Badgers Act 1992. That Act specifies a
shotgun of not less than 20-bore, or a rifle firing ammunition
with a bullet weight of not less than 38grains and generating
a muzzle energy of not less than 160 ft/lb. Centre fire rifles
such as the .22 Hornet, .222Rem, .223, 243Win and .22-250 are
commonly used for fox control and are well within the limits required
by the Act for the control of badgers.
2.3 A 12 bore shotgun with a load of not
less than 36 grams of large shot such as No 1 or No 3 would be
an effective alternative to a centre fire rifle at short range,
up to 30 meters. The use of an automatic or semi-automatic weapon
to kill a badger is prohibited under the Wildlife and Countryside
Act 1981. Consideration would therefore need to be given as to
whether their use would be permitted under license.
2.4 Under the Wildlife and Countryside Act
1981 any device for illuminating a target or sighting device for
night shooting, and any form of artificial light to kill a badger,
or attempt to kill a badger, is illegal. These devices are an
integral part of lamping therefore measures will need to be put
in place to permit their use under license.
2.5 Potential licensees wishing to use firearms
will need to apply to their police firearms licensing department
for an appropriate variation on their firearm certificate to control
badgers. Currently a "good reason" for allowing someone
to posses a rifle is "vermin control" which means fox
and rabbit control or for larger centre fire calibers, controlling
deer. Given this are badgers to be classed as "vermin"
thereby requiring no variation to an existing certificate or would
licensees need to specify badger control as a new and separate
activity?
2.6 Will all police firearms licensing departments
in England be contacted by Defra to make them aware of any proposed
changes firearm certificates holders would require in order to
meet the new requirements?
2.7 If the Government requires badgers to
be culled by licensees using centre fire rifles (or by shotgun)
is the Government proposing to compensate license holders for
variations and amendments to current certificates holders or for
the granting of new certificates? The current cost of a renewal
is £40 and a grant £50.
2.8 Under the Wildlife and Countryside Act
1981 it is illegal to use any mechanically propelled vehicle in
immediate pursuit of a Schedule 6 animal, which includes a badger,
for the purpose of driving, killing or taking it. Lamping usually
takes place from the back of a stationary vehicle. BASC therefore
seeks assurances that the use of vehicles would be permitted under
any license conditions otherwise lamping, as a control method,
would be severely restricted.
2.9 BASC supports the proposal for a close
season for badgers extending from 1 February to 31 April to avoid
shooting lactating sows with dependant cubs, however, provision
needs to be made to enable control to be carried out during this
period should it be deemed necessary.
3. BODY SNARES
3.1 Where night shooting is not feasible
snares offer an effective and humane alternative. In 1994 BASC
produced a code of practice on fox snaring, which is widely regarded
as the standard by which fox snaring should be carried out. We
note the consultation paper refers to the use of "body snares"
for catching badgers, as opposed to the neck snare currently used
in England for catching foxes. This new type of snare will therefore
be unfamiliar to operators. Also the methodology used for catching
badgers in body snares would be fundamentally different from that
used to catch foxes, such as the height of setting and anchorage,
though some techniques would be applicable.
3.2 The majority of people using snares
within the UK will have had little formal training. A mentor would
initially teach snaring techniques and people quickly become proficient
through experience. Gamekeepers in particular use snares regularly
and have the necessary skills required to carry out the task to
a high standard.
3.3 Experience of snare use combined with
a good knowledge of the tracks, trails and signs of both target
and non-target animals are essential elements to successful and
humane snaring. Awareness raising through recognised codes of
practice play a major role in ensuring snares are used responsibly
and helps minimise the capture of non-target species'. BASC is
not aware of any reliable evidence to suggest that snares are
being routinely misused or that the accidental capture of non-target
species poses a significant threat.
3.4 BASC recommends that where snaring is
permitted under licence to control badgers it should be carried
out in accordance with an agreed, dedicated code of practice.
3.5 Snares used for badgers would need to
be made from strong multi-strand steel cable. For example, BASC's
fox snaring code of practice recommends wire with a breaking strain
of not less than 460lbs/208 kilos. Snares must also be "free
running", incorporate a swivel to prevent the cable from
twisting and fitted with a crimped "stop" to prevent
the loop closing completely. Snares must also be free of any sharp
or frayed edges, which might cause injury.
3.6 A free running snare is a wire loop
that relaxes when the animal stops pulling, whilst a self-locking
snare is a wire loop that continues to tighten by a ratchet action
as the animal struggles. Free running snares are used to restrain
an animal not kill it. The Wildlife and Countryside Act made self-locking
snares illegal in 1981.
3.7 Snares would need to be firmly anchored
in the ground and set in open sites. Sites cluttered by obstacles
such as saplings, fences or gates, which increase the risk of
injury and entanglement, should not be used.
3.8 A badger caught in a free running snare
would be despatched quickly and humanely by a shot from a rifle,
shotgun or pistol.
3.9 The Wildlife and Countryside Act 1981
requires snares to be inspected at least once every day. BASC's
fox snaring code of practice recommends snares are inspected at
least twice a day and as soon after dawn as is practicable. The
2005 Defra Code of Good Practice on the Use of Snares for Fox
and Rabbit Control, developed by the Independent Working Group
on Snares of which BASC was a member, recommends that during the
winter snares must be inspected as soon after sunrise as is practicable,
and should again be inspected near dusk. In summer snares must
be inspected before 9 am, and a further inspection should be conducted
in the evening.
3.10 Badgers are largely nocturnal and predictable
in their habits. Capture is likely soon after dusk when they are
on their way from the sett to feeding areas and again on their
return. Snares set for badgers could therefore be set as late
in the daytime as possible on well defined badger runs which minimises
the risk to any non-target species and inspected at relatively
shorter intervals throughout the hours of darkness, for example
three to four hours after setting.
3.11 Given the need for a different approach
to be taken when snaring badgers BASC would wish to discuss further
whether license holders would require additional skills, obtained
on a voluntary basis and at no cost to themselves, if snaring
is deemed an appropriate method of control.
3.12 A number of shooting organisations
and pest control companies currently offer voluntary training
courses on predator and pest control at various locations throughout
the year.
3.13 The introduction of any compulsory
training scheme to meet Government proposals may require many
thousands of people to undertake training even though they may
only occasionally use snares and would be unfairly penalised.
Compulsory training schemes tend to be both bureaucratic and costly
which may preclude many people from participating. Compulsory
testing should only ever be an option when evidence clearly shows
widespread abuse or misuse. Given the lack of any reliable evidence
to suggest this then there is little justification, at present,
for compulsory training.
4. GASSING
4.1 Gassing should be considered as one of a
range of methods which could be made available to land managers,
however, there are currently no compounds licensed for use in
the UK other than for the control of moles, rats and rabbits.
BASC notes reference to the use of carbon monoxide in the consultation
paper and supports current research in to its possible use to
control badgers.
4.2 Operators currently using pesticides
including gassing compounds for controlling moles, rats and rabbits
are required to have had appropriate training. Should carbon monoxide
or any other gassing compound become available to control badgers
BASC would wish to discuss further whether license holders would
require additional skills, obtained on a voluntary basis and at
no cost to them, if gassing was deemed the most appropriate method
of control.
4.3 A number of existing training providers
such as ADAS are already delivering training within the agricultural/land-based
sector in the safe use of pesticides.
5. CARCASS DISPOSALS
5.1 Bovine TB is a notifiable disease. The
culling of badgers to prevent the spread of bovine TB will be
an action sanctioned by Government therefore carcass disposal
and any associated cost burdens should be met by the State and
not transferred to licensees. The appropriate statutory agency
should be responsible for organising appropriate training, delivery
of equipment for the safe collection and storage of carcasses
on site and the collection and disposal by incineration in approved
establishments.
February 2006
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