3 Domestic Wildlife Crime |
25. We received evidence during our inquiry covering
wildlife crime in relation to a wide range of UK species. Some
of those points relate to the legal framework and enforcement,
which we cover in Part 4. This Part focuses on two areas where
we believe that change is needed and could make a real difference:
on birds of prey, where action is needed to prevent an extinction
in England and where clear legislative remedies are available;
and on invasive non-native species, which are a growing problem
with high costs that require a more strategic response.
Birds of prey
26. Fifteen species of birds of prey
breed in the UK, and the Government is required to protect them
all under the European Commission Birds Directive and the Wildlife
and Countryside Act 1981.
Of those 15 species, the hen harrier and the golden eagle are
included in the 'Red List' of most threatened species in Birds
of Conservation Concern,
and the red kite, peregrine, goshawk and white-tailed eagle are
also threatened by persecution.
There is clear public and political support for governmental action
to address bird of prey persecution. In 2010, more than 210,000
people signed the Royal Society for the Protection of Birds (RSPB)
bird of prey pledge, which called for an end to the illegal killing
of birds of prey, and more than 160 Members of Parliament signed
Early-Day Motion 654, which urged the Government to accord greater
priority to addressing raptor persecution.
More generally, in August 2011 the Government published Biodiversity
2020: A Strategy for England's Wildlife and Ecosystem Services,
which includes a commitment to end human induced-extinctions by
POSSESSION OF CARBOFURAN AND OTHER
27. It has been an offence to poison birds of
prey under any circumstances anywhere in the UK since the Protection
of Animals Act 1911, but the practice has nevertheless continued
over the past century, with a consequent effect on overall bird
of prey populations. Figure 1 illustrates the consistent level
of bird poisoning over the past decade and the extent to which
bird poisoners used in particular the pesticide carbofuran. The
statistics are drawn from the Government's Wildlife Incident Investigation
Scheme, which records investigated and confirmed incidents of
wild bird poisoning and which therefore covers only a fraction
of the actual number of poisonings.
Figure 1. UK wild bird poisonings 2002 to 2011
28. As Figure 1 demonstrates, carbofuran is currently
the toxic substance most used by bird poisoners. From 2002 to
2011, there were 633 confirmed bird-poisoning incidents in the
UK, of which 316 cases50%involved carbofuran.
Carbofuran, which is marketed under the trade name Furadan, is
a carbamate insecticide, and its approval for use as such was
withdrawn in the UK in 2001.
There is therefore no legal purpose for which anyone might possess
carbofuran in the UK. Carbofuran is especially toxic to birds,
and a single grain would kill a large bird of prey such as a golden
eagle by breaking down its central nervous system.
Carrion-feeding raptors are especially susceptible to carbofuran
poisoning, where the poison is administered via a laced bait.
A gamekeeper who was convicted of poisoning birds of prey in Skibo,
Scotland, in 2011 was found to possess 10 kilogrammes of carbofuran,
which would have been sufficient to kill every bird of prey in
29. Bird poisoners are clearly targeting a range
of birds of prey. The RSPB's Birdcrime 2010 lists poisoning
cases involving 20 red kites, 30 buzzards, two goshawks, eight
peregrines, five golden eagles, one white-tailed eagle and one
sparrowhawk, and 36 of those poisoning cases in 2010 involved
2 sets out the number of confirmed cases of bird of prey poisoning
over the past decade, showing the species that were targeted and
the extent to which those cases involved carbofuran.
Figure 2. UK bird of prey poisonings 2002 to 2011
30. After our predecessor Committee's wildlife
crime inquiry in 2004, Defra has acknowledged the environmental
impact of illegal wildlife poisoning and the need to introduce
controls by enacting new primary legislation. Section 43 of the
Natural Environment and Rural Communities Act 2006 allowed the
Secretary of State to proscribe the possession of banned pesticides
in England and Wales, but no Order listing the proscribed substances
has been made. Given that the power to proscribe possession already
exists in primary legislation, this is an inexplicable omission
and a failure to follow through on the logic of the 2006 Act.
There is a broad consensus on that point, because the RSPB, the
Countryside Alliance, other NGOs and the police support the introduction
of an Order under the 2006 Act making it an offence to possess
31. An offence of possession could drive culture
change by sending a clear signal on bird of prey poisoning as
well as directly helping to protect the environment by curtailing
the activities of the most serious offenders through prosecution
and conviction. Carbofuran is so toxic that even a lone poisoner
who possesses a relatively small quantity of it has the capacity
to cause irreparable environmental damage. An Order made under
the 2006 Act would also allow magistrates to impose custodial
sentences in the most serious cases.
32. It is an offence to possess carbofuran and
other named substances in Scotland under the Possession of Pesticides
(Scotland) Order 2005. Bearing in mind that evidence from Scotland,
there might not be a significant number of prosecutions in England
and Wales if an Order making it an offence to possess carbofuran
were introduced under the 2006 Act, because such an Order could
act as a powerful deterrent to wildlife poisoners and promote
behaviour change. The then Home Office Minister Lord Henley acknowledged
that the threat of custodial sentences had effectively eliminated
the practice of egg collecting without large numbers of prosecutions.
33. When we raised the idea that it might be
beneficial to proscribe possession of carbofuran in England and
Wales with the Defra Minister Richard Benyon MP, he replied, "In
view of the legislation already in place, an order under section
43 of the [Natural Environment and Rural Communities Act 2006]
will not be pursued at this time".
In subsequent correspondence, he set out two reasons why Defra
was not minded to introduce an Order making it an offence to possess
the Minister pointed out, "The intentional use of poisoned
bait to kill any wild bird is already prohibited under section
5 of the Wildlife and Countryside Act 1981".
However, we took evidence that highlighted the difficulty of securing
convictions under that legislation, which consequently lacked
a deterrent effect as evidenced by the statistics in Figures 1
and 2. Such crimes
mostly took place in physically isolated locations, which made
it difficult to ascertain who had set the poisoned bait and to
gather other evidence. The case in Skibo in Scotland (paragraph
29) was investigated following the discovery of the carcasses
of several golden eagles and other birds of prey poisoned by carbofuran.
Although the manager of the estate was convicted of possession
of carbofuran, no one was charged with poisoning offences under
Section 5 of the Wildlife and Countryside Act 1981, which illustrated
the difficulty of obtaining convictions under that legislation
and the value of an offence of possession.
34. Secondly, the Minister stressed the advantages
of a voluntary approach and raised the issue of proportion:
We are carefully considering the laws surrounding
possession of pesticides that are harmful to wildlife but so far
conclude that an Order may not be a proportionate course of action
and that there could be alternative ways to handle the issue.
These might include voluntary codes of practice
participation in amnesty initiatives such as that run for farmers
through Project SOE (Security of the Operational Environment).
Under the first phase of that project nearly 1,000 stores were
cleared of 40 metric tons of redundant and unapproved pesticides.
It seems doubtful to us that those who are responsible
for poisoning of birds of prey would voluntarily surrender their
stocks of carbofuran, because, as far as they are concerned, carbofuran
is not a redundant substanceindeed, it is highly effective
for its purpose. Furthermore, the Scottish experience, where 10
convictions for possession have occurred in the past seven years,
does not suggest the disproportion that the Minister fears. In
any case, the Crown Prosecution Service (CPS) should be capable
of distinguishing between farmers who possessed redundant and
unused pesticides and serious wildlife criminals. One factor would
be evidence of actual use, such as the presence of carcasses of
poisoned birds, in deciding whether to pursue prosecutions. Designating
and training specific CPS wildlife crime prosecutors (paragraph
60) would provide further reassurance on that point.
35. Substances other than carbofuran, such as
aldicarb, alphachloralose, aluminium phosphide, bendiocarb, mevinphos,
sodium cyanide and strychnine, have also been used illegally to
poison birds of prey in the UK.
Some of those substances have also had their approval for use
withdrawn, while others have legal applications as pesticides.
If Defra accepted the logic of utilising the 2006 Act to proscribe
possession of carbofuran, it would make sense to proscribe possession
of other substances used to poison birds of prey in the same Statutory
Instrument, with appropriate derogations in relation to the Food
and Environment Protection Act 1985 and the Biocidal Products
Regulations 2001 to allow legal use of approved substances by
appropriately licensed individuals working in pest control or
laboratories. Tackling any new wildlife poisons could be readily
taken forward in further secondary legislation, which would allow
a rapid, tailored response to the evolution of offending.
36. To discharge its obligations
under the EC Birds Directive, to demonstrate its commitment to
addressing raptor persecution and to send a clear signal that
it regards poisoning birds of prey as wholly unacceptable, we
recommend that the Government immediately introduces an Order
under Section 43 of the Natural Environment and Rural Communities
Act 2006 proscribing possession of carbofuran and other similar
substances in England and Wales.
37. Raptor persecution involves not only poisoning,
but nest disturbance or destruction, egg theft, chick theft and
Species such as the hen harrier feed on live prey and are not
vulnerable to poisoning by eating carrion laced with poison. Instead,
the Joint Nature Conservation Committee's Conservation Framework
for Hen Harriers found that the most common form of persecution
of that species was deliberate nest disturbance.
Given the isolated physical locations, often on private land,
where offences are committed and the ease with which evidence
such as carcasses could be disposed of, the precise extent of
such persecution in the UK is unknowable, although an RSPB log
of reported incidents indicates a consistent level of persecution
over the past decade.
In addition, scientific analyses of the total number of birds
of prey in the UK, such as the comprehensive Conservation Framework
for Hen Harriers, have consistently found that persecution
has a measurable impact on population size.
38. An offence of vicarious liability would impose
criminal liability on those whose employee or contractor committed
an offence against a bird of prey, unless they could show that
they were unaware of the offence and had exercised due diligence.
It could make landowners take responsibility for the activities
of gamekeepers and others who work on their land. The introduction
of such an offence in England and Wales would, like tougher legislation
on pesticide possession (paragraph 37), send a clear signal that
the Government regarded the persecution of birds of prey as wholly
unacceptable. In practical terms, vicarious liability would encourage
responsible landowners to make it clear to their employees and
contractors that raptor persecution was unacceptable and to check
that such practices were not occurring on their land.
39. Addressing hen harrier persecution is especially
necessary because it is on the brink of extinction as a breeding
species in England with only four successful nests in 2011, and
it is arguably the most vulnerable of all indigenous species.
Persecution has been identified as a factor affecting the distribution,
abundance and productivity of the hen harrier in five academic
studies conducted over a number of years.
The National Gamekeepers Organisation questioned this proposition
in its oral evidence,
but it did not adduce any factors not addressed in the modelling
that underpinned the Conservation Framework for Hen Harriers.
The persecution of birds of prey on moorlands used for shooting
is not only illegal and highly damaging to biodiversity, but ineffective
in terms of increasing the stock of game birds, because research
indicates that only between 1% and 2% of pheasant poults are taken
by birds of prey.
40. The golden eagle is also threatened by extinction
due to persecution. The most recent national survey in 2003 found
a British population of about 440, with all but one or two pairs
in Scotland. A recent Scottish Natural Heritage report found that
persecution was the most severe constraint on golden eagle populations
and that incidents of persecution were more common where grouse
moor management predominated. The report also concluded that the
rarity of golden eagles in England was probably a result of persecution
limiting potential recruits from Scotland and to raptor persecution
in upland areas of England.
41. The buzzard is also persecuted, but it is
thriving in the UK. The buzzard population increased from an estimated
31,000 to 44,000 pairs in 2000 to between 72,000 and 90,000 pairs
in 2009. The National
Gamekeepers Organisation told us that this population growth is
a symptom of "over-protection" and expressed its frustration
licence applications for buzzard control to prevent
serious damage to gamebirds and other wildlife have so far all
been declined by Natural England
Illogicalities like this
bring wildlife law into disrepute and build frustrations in the
countryside among the farmers, gamekeepers and others who are
normally among the most law-abiding sections of society but who
are driven to distraction by such over-protection
route to limited control where it is proven necessary already
exists but licences are not forthcoming.
Despite the increasing buzzard population, buzzards
are still subject to illegal persecution, and 290 buzzards were
poisoned in the UK between 2002 and 2011.
Natural England told us:
We see it as a great success in many respects, that
buzzards and some other raptors have been recovering, after a
time in the past when clearly their populations plummeted and
were very lowpesticides, persecution and so on. The buzzard
recovery story is a great one
Although, in truth, there
are still not the numbers that there were historically, but that
is a great, great story
We do not think they are too numerous.
42. On 23 May 2012, Defra announced a £375,000
research scheme to explore management techniques to curb the supposed
predation of pheasant poults by buzzards; it announced that the
scheme had been dropped in the light of widespread public concern
on 30 May 2012. Its
total funding for the National Wildlife Crime Unit was £136,000
in 2012, so £375,000 is a relatively large sum in the context
of overall Government spending on wildlife crime. When we asked
the Defra Minister Richard Benyon MP whether he would be interested
in our suggestions on how that money might subsequently be allocated,
Certainly, yes. None of us has a sum total of all
the knowledge on these matters. I recognise the sensitivity of
this, and I know the Committee does as well, but we want to ensure
that the recommendations that we take forward, as well as being
mindful of that sensitivity, push Government to make the right
decision for biodiversity.
In Part 4, we have set out recommendations on enhancing
the NWCU's database and internet monitoring capabilities where
even a fraction of that money might make a significant difference
for wildlife conservation, both nationally and internationally.
43. On the introduction of vicarious liability
in relation to raptor persecution, Richard Crompton, the former
Association of Chief Police Officers (ACPO) wildlife crime lead,
told us that "any gamekeeper who is not in the business of
illegally persecuting raptors would have absolutely nothing to
recognise the commitment of the law-abiding majority in the gamekeeping
community to tackling wildlife crime, as exemplified by the contribution
of the National Gamekeepers Organisation to the Partnership for
Action against Wildlife Crime (PAW). Unfortunately, some gamekeepers
persecute birds of prey. One study found only five successful
hen harrier nests on the 3,700 square kilometres of
driven grouse moor in the UK in 2008, an area which has the potential
to support 500 pairs.
Of the 152 people who have been convicted of offences against
all birds of prey under the Wildlife and Countryside Act 1981
since 1990, some 70% were gamekeepers employed on shooting estates.
The maximum penalty for such offences is a £5,000 fine and/or
six months in prison, but the RSPB told us that most of those
cases were sentenced with a small fine and that only three custodial
sentences, all suspended, had been issued.
scale of ongoing persecution of birds of prey, the current law
appears to carry insufficient deterrent weight.
44. An offence of vicarious liability in relation
to the persecution of birds of prey has been introduced in Scotland
under the Wildlife and Natural Environment Act (Scotland) 2011,
and the National Gamekeepers Organisation pointed out that more
evidence from the Scottish experience would be helpful before
introducing such a provision in England and Wales.
We recommend that the Government
evaluates the effect of the introduction of an offence of vicarious
liability in relation to raptor persecution in Scotland and considers
introducing a similar offence in England and Wales in that light.
We expect the Government to report to us, or otherwise publish,
the results of that review within the next 12 months.
Invasive non-native species
45. Failing to control invasive non-native species
(invasive species) is a wildlife crime. Defra defines invasive
species as "species whose introduction and/or spread threaten
biological diversity or have other unforeseen impacts".
Section 14 of the Wildlife and Countryside Act 1981 sets out offences
around releasing or allowing the escape of non-native animals
and the planting or sale of the invasive non-native plants listed
in Schedule 9 to the 1981 Act.
46. In recent decades, the global impact of invasive
species has increased significantly, mainly due to increased world
trade and the movement of people. Almost 2,000 invasive species
are currently established in Britain, some 15% of which have a
negative environmental impact. On average, six new invasive species
become established every year, the cumulative extent of which
is captured by the UK Biodiversity Indicators 2012.
In Britain, several endangered species are threatened by invasive
species, including the red squirrel, which has declined due to
the introduction of the American grey squirrel, the Tansy beetle,
which is threatened by the spread of Himalayan balsam, water voles,
which are subject to predation by American mink, and various indigenous
tree species, which are damaged by pests and diseases such as
the Asian Longhorn beetle.
47. In addition to their negative impact on biodiversity,
invasive species impose significant economic costs. The Centre
for Agricultural Bioscience International has estimated the direct
cost of invasive species to the UK economy at £1.3 billion
a year in control and eradication measures, damage to infrastructure
and loss of production.
It has been estimated that developers spend more than £150
million a year on tackling Japanese knotweed, which was originally
introduced in Britain as an ornamental plant.
Those figures do not take into account knock-on socio-economic
costs, which can be particularly significant in relation to the
aquatic environment. Signal crayfish, for example, decrease the
overall fish population, which has an impact on the amenity and
economic values of fisheries, and floating pennywort can prevent
angling by starving water of oxygen.
The Angling Trust told us that "these problems are not new,
but there is a lack of co-ordinated action to address them".
48. As an island, Britain is protected by water
against the spread of some invasive species from continental Europe.
This natural advantage has, however, been undermined by third-country
plant imports from Europe, where plants which may be invasive
in themselves or which may carry invasive pests have been imported
into EU countries before being re-exported into the UK.
Such third-country plant imports evade biosecurity checks at the
UK border, because they are classified under EU trade rules as
internal trade. The EU has been working towards the development
of an invasive species strategy since 2008, and its latest consultation
on the subject closed in April 2012. There is, however, no agreement
to introduce a directive on invasive species, and even if one
were introduced, the Law Commission noted that it might not address
third-country imports, leaving the UK to deal with this unilaterally
while hamstrung by EU rules.
49. Given the environmental and financial costs
imposed by invasive species and the difficultyin some cases,
impossibilityof eradication once invasive species are established,
preventing invasive species arriving in Britain in the first place
is likely to be the most effective policy option. One way to reduce
risk would be to decrease imports of garden plants, vegetables,
cut flowers, houseplants and trees by encouraging purchasers to
source such products locally along the lines set out in our recent
Report on Sustainable Food.
Another option would be to impose a levy on imported plants to
address the environmental and financial cost of invasive species,
although this approach might contravene EU and World Trade Organisation
50. The Wildfowl and Wetlands Trust told us that
invasive non-native plants that cannot be legally imported into
the UK because they are listed in Schedule 9 to the Wildlife and
Countryside Act 1981 were sometimes deliberately misidentified
by retailers on internet sites in order to evade the law.
Tighter controls are also needed on plants purchased online from
overseas. Fuchsias ordered from South America online were, for
example, imported via Jersey with no checks, which led to the
introduction of the Fuchsia gall mite into Britain.
It is possible that the deterrent effect of even a modest amount
of online enforcement activity, which would be entirely new, could
produce a broad change in behaviour across the online plant importation
sector. This adds force to our recommendation on policing wildlife
crime on the internet (paragraph 69).
51. Once invasive species are established in
the ecosystem, eradication is expensive and difficult.
For example, the Environment Agency told us, "top mouth gudgeon
is one of our top priorities, and we have eradicated them from
nine of 34 known sites now",
which means that it has managed to remove this invasive species
from less than one third of known sites in a top priority case.
That illustrates the difficulty of successfully eradicating an
established invasive species, which prompts the question whether
funds spent on eradication might more usefully be disbursed on
prevention. The Royal Botanic Gardens, Kew believed that, "we
must not dissipate already inadequate resources on species where
there is no possibility of eradication".
The least-worst option may be learning to live with established
invasive species by ameliorating their impact and concentrating
the limited available resources on prevention.
52. Attempts to eradicate invasive species usually
involve chemical pesticides or physical extraction, which is expensive
and often unsuccessful. The more radical option of "biocontrol"fighting
fire with fire by introducing another non-native species that
predates a particular invasiveis potentially more effective
than conventional methods, but it is also more risky. The Royal
Botanic Gardens, Kew, pointed out:
Introducing predators and parasites is fraught with
dangers unless there is lengthy and comprehensive testing and
the timescales involved would likely mean the target organism
is well established in large areas before release is licensed.
The extensive testing associated with biocontrol
may be too lengthy for it to be an effective policy response to
new invasive species, but it could be the most effective option
for already established invasive species. Comprehensive research
will help to prevent mistakes such as the introduction of the
cane toad in Australia, which itself became an invasive pest.
Biocontrol has been used successfully to control invasive species,
such as the control of Azolla with the Azolla weevil, and ongoing
trials of the psyllid bug to control Japanese knotweed have apparently
achieved promising early results.
AN INVASIVE SPECIES STRATEGY
53. The governmental responses to invasive species
in the UK are organised on geographical rather than national lines.
The Invasive Non-Native Species Framework Strategy for Great
Britain was launched in 2008 and was a joint endeavour between
Defra, the Scottish Government and the Welsh Assembly Government.
It was set up to co-ordinate the actions of departments, agencies
and key stakeholders, and the Northern Ireland Executive and the
Republic of Ireland have agreed a similar strategy covering the
island of Ireland. The 2008 strategy is due for review in 2013,
which is timely given the burgeoning environmental and financial
costs imposed by invasive species.
In addition, the Law Commission is considering the law in relation
to invasive species and has published a consultation document,
which may lead to the publication of a draft Bill in 2014.
Those reviews might consider the evidence received in our inquiry.
54. In the meantime, in 2011 the Scottish Government
amended the Wildlife and Countryside Act 1981 in Scotland to make
it an offence to release any plants or animals "outwith their
Such an overarching precautionary approach might overcome the
inherent inflexibility of maintaining a list of banned speciesspeed
is of the essence in banning the sale of invasive species before
they can establish themselvesbut it may prove difficult
to define the "native range" of an invasive species.
Indeed, this concept might lead to adverse unintended consequences,
where the native range of a species is not clear, but there would
be a clear threat if it were released.
The Scottish provisions also allowed Scottish Natural Heritage
to make Species Control Orders to control or eradicate invasive
species, and a similarly innovative approach might prove effective
in England and Wales.
55. On the other hand, Scotland's unilateral
action on invasive species somewhat undermines the concept of
the 2008 joined-up British strategy, and it could be ineffective
to operate two different regimes on either side of a land border
that invasive species neither recognise nor respect. Defra
should examine with the Scottish Government and the Welsh Assembly
Government how their commitment to joint strategic action on invasive
non-native species in Britain could be refocused, with an emphasis
on bolstering a strategy of prevention and setting clear milestones
for implementation. In its 2013 review of The Invasive
Non-Native Species Framework Strategy for Great Britain, Defra
should study (a) the impact of the Wildlife and Natural Environment
(Scotland) Act 2011; (b) the impact of third-country imports
via other EU countries; (c) the scope for promoting sustainable
domestic production of plants and vegetables in the UK to minimise
the risk of importing invasive non-native species. We intend to
further examine invasive species in the future.
61 Buzzard, Kestrel, Peregrine, Osprey, Merlin, Hobby,
Sparrowhawk, Montagu's Harrier, Marsh Harrier, Honey Buzzard,
Goshawk, Hen Harrier, White-Tailed Eagle, Golden Eagle and Red
Council Directive 79/409/EC Back
A review of the status of birds published by 12 conservation organisations
and five statutory agencies. Back
Ev 141 Back
Ev 134 Back
RSPB, Birdcrime 2011. Back
RSPB, Birdcrime 2011. Back
Carbofuran was banned across the European Union in 2008 in light
of concerns about its possible carcinogenic qualities. It is also
banned in Canada and the USA. Back
Scottish Raptor Study Groups, website, 18 April 2012. A quarter
of a teaspoon of carbofuran will kill a human or, as a recent
case in Kenya demonstrated, a lion. Back
Ev 135; The Guardian, 27 May 2011. Back
RSPB, Birdcrime 2010. Back
RSPB, Birdcrime 2011. Back
Ev w3 Back
Ev 171 Back
Qq 5, 414 Back
Qq 418 Back
Ev 170 Back
Q 35; Ev 140 Back
The Guardian, 27 May 2011. Back
Ev 170 Back
Ev 136 Back
See RSPB Birdcrime 2010 for a full log of recent cases
involving poisoning by various substances. All the substances
mentioned in Paragraph 25 are listed in the Schedule to the Possession
of Pesticides (Scotland) Order 2005, and it is therefore an offence
to possess them in Scotland without good reason. Back
Ev 170 Back
Joint Nature Conservation Committee, A Conservation Framework
for Hen Harriers in the United Kingdom, para 8.1.3. Back
Ev 134 Back
Q 1; Ev 134 Back
RSPB, Parliamentary Briefing, January 2012. Back
Redpath et al 2010, Anderson et al 2009, Natural England 2008,
Summers et al 2003 and Etheridge et al 1997. Back
Q 59 Back
Joint Nature Conservation Committee, A Conservation Framework
for Hen Harriers in the United Kingdom, para 8. Back
DS Allen et al, Raptors and the rearing of Pheasants:
problems and management needs, ADAS unpublished report to
British Association for Shooting and Conservation. This report
found that predation by foxes and vehicle impacts are the significant
factors in pheasant poult mortality. Back
Ev 141 Back
HC Deb, 7 December 2010, col 346W. Back
Ev 86 Back
See Figure 1. Back
Q 271 Back
The Guardian, 30 May 2012. Back
Q 426 Back
Q 198 Back
Joint Nature Conservation Committee, A Conservation Framework
for Hen Harriers in the United Kingdom, Introduction. Back
Ev 136 Back
Ev 171 Back
Q 46 Back
Defra, The Invasive Non-Native Species Strategy for Great Britain,
para 3.3. Back
Law Commission, Wildlife Law, Consultation Paper 206, para
8.8; Defra, UK Biodiversity indicators in your pocket, 2012. Back
Law Commission, op. cit., para 8.9. Back
Centre for Agricultural Bioscience International, The Economic
Cost of Invasive Non-Native Species on Great Britain. Back
Centre for Agricultural Bioscience International, op. cit.,
p 33. Back
Q 84 Back
Ev 145 Back
Ev w88-89 Back
Law Commission, op. cit., para 8.53. Back
Ev w89; Environmental Audit Committee, Eleventh Report of Session
2010-12, Sustainable Food, HC 879. Back
Ev w89 Back
Ev w87 Back
Ev w89 Back
A non-native fish that has somehow made its way from aquariums
into rivers. Back
Q 222 Back
Ev w89 Back
Ev w87 Back
Ev w88 Back
Wildlife and Natural Environment (Scotland) Act 2011. Back
Law Commission, op. cit., paras 8.88 to 8.93. Back
Ev w87 Back