Environment Audit CommitteeWritten evidence submitted by the Remembrancer of the City of London

This letter responds to the recent call for evidence for this inquiry. The City of London runs the Animal Reception Centre (ARC) at Heathrow Airport, which receives around 80% of imports of live animals which enter the UK from non-EU (third country) states. The main remit of the ARC is to enforce the animal health and welfare legislation as it relates to the animals passing through the airport. The City of London is also responsible, under the Animal Health Act 1981, and Trade in Animal and Animal Product Regulations 2011, for imported animals for the Greater London area.

By way of background, the ARC has a very close working relationship with the UK Border Force Convention on International Trade in Endangered Species (CITES) team and four senior ARC staff are also Animal Health and Veterinary Laboratories Agency (AHVLA) Wildlife Inspectors. The ARC conducts training courses for police wildlife crime officers and UKBF officers and is involved in the one week CITES training course, run by and for UKBF and Police and is a member of the Partnership Against Wildlife Crime, chaired by Defra.

A major problem in tackling wildlife crime is that trends in the trade of exotic animals changes over the years in response to external factors. The banning of the import of wild caught birds in 2005 in response to the threat of avian influenza lead to an increase in the illegal trade of birds. Similarly, since the increase in airport security following the attacks on the World Trade Centre, the level of smuggling by airline passengers has dipped, although the perception is that this has moved smuggling to other routes particularly by post and courier. The internet has also caused a large shift in patterns. It is now easier for individuals in the UK to find suppliers in third countries, with enforcement agencies lacking the resources or capacity to address the problem. Whilst there have been some successful prosecutions of online traders, the size of the problem means that often only large and persistent offenders are dealt with.

Imports from within the EU also cause difficulties. Many of the very rare species found in trade in the UK have been imported via the EU—this presents a major problem as the UK cannot stop internal movement from other EU Member States. Whilst there is no easy solution, an increase in intelligence gathering would help AHVLA officers to target smuggling networks. Fellow Member States should also be actively encouraged to enforce EU legislation at their own borders to help stem the problem. From contact with people and agencies abroad it is clear that the UK does have a large role in influencing EU and International agreements on illegal wildlife trade.

In the view of the ARC, domestic legislation is generally fit for purpose, except the requirement in the Control of Endangered Species (COTES) legislation for a veterinarian to take a sample of all biological imports. This should be amended to allow a more practicable and sensible approach to sampling, especially with regards to plants or non-living imports.

Potentially the single biggest factor that would contribute to a reduction of wildlife crime is the introduction of a possession or registration scheme. There is already a possession licensing scheme within the Habitats Directive and CITES listed species could be combined with this. There could also be a secondary benefit to such a system as CITES licensing is moving to full cost recovery. This has made the UK one of the most expensive EU Member States to apply for CITES permits, driving business from the UK to other EU States. For example, a plant permit which costs 10 euros in some EU states can be anywhere from £60–200 in the UK. By having a full and proper scheme for possession, it could, by dint of volume, reduce the cost of the individual permits to a more publicly accessible and acceptable level. Overly expensive licensing schemes will also tend to encourage evasion.

Some wildlife crime fits within existing local or regional action/initiatives, whereas some has a more national or international scope. From the City’s viewpoint, the UKBF and CITES team have done well in helping police forces to enforce the regulations on such national and international crime. However, wildlife crime is not a reportable offence—if it became reportable, it would potentially increase the priority given to it by individual police forces and the resources they allocate to it.

The introduction of the National Wildlife Crime Unit (NWCU) in 2006 had a very positive impact on the policing of wildlife crime. Its method of working, whereby officers on the ground support local forces (the latter may not have expertise and specialist knowledge), is one that has achieved demonstrable results. The City thinks that these arrangements should not be changed. The NWCU’s main issue is uncertainty over its future. The temporary nature of the Unit’s funding is wholly unsatisfactory and currently there is little information available on how the proposed National Crime Agency (NCA) will work in this field, how the NWCU would potentially fit into the NCA, or if it will sit elsewhere. To improve its effectiveness the NWCU should be properly resourced and put on a permanent footing, whether that is as a stand-alone unit, as now, or within another organisation.

If the Committee would care to visit the Animal Reception Centre to see its work first hand and raise any issues or queries that they may have with the staff, please do not hesitate to contact my office.

7 June 2012

Prepared 16th October 2012