Support grey squirrels and other ‘non–native’ wildlife!

These are general questions about you and your contact information etc. If you do not wish for any of this to be shared, please state this in response to question 1.

View Appendix B

• We strongly oppose the inclusion of “the use of approved, humanely conducted, lethal control measures including targeted culls, trapping and shooting”as a general management measure.
• The EU legislation that this is based on makes no requirement for lethal methods to be used, and no obligation for any country to eradicate particular species using lethal methods.
• There is a clear ethical duty to take animal welfare into account here, which is not compatible with use of lethal measures.  

View Appendix A

• You may choose to use this section to discuss a particular animal, but there are a few you could address in more depth here.
• We disagree with the aim of eradicating the animal species listed.
• Grey Squirrels – We believe that the UK government has misinterpreted EU regulation 1143/2014 and failed to take note of the European Commission’s published clarifications on the legislation. In particular, the UK government seems to be ignoring parts of EU legislation clarifying that management should be ‘proportionate’ and that ‘there is no obligation for the UK to eradicate the grey squirrel from its territory.’
• We strongly reject the notion that grey squirrels are responsible for the low levels of red squirrels in the UK. Red squirrels exist in low numbers for a combination of reasons, including culling, climate change, industrialisation, deforestation etc. Grey squirrels should not be persecuted and used as a scapegoat.
• Muntjac deer -The European Commission’s Risk Assessment in relation to EU Regulation 1143/2014 for Muntjac deer in the UK states that eradication would be “impossible even if it were desirable”.
• Egyptian goose – The European Commission Risk Assessment states that “expansion of the English population has been fairly slow since its establishment more than 300 years ago.” To include an animal in these proposals that has been established for this long is extremely dubious, and we would question why any well-established animals have been included in these proposals at all. 

• We recommend that these general management measures should include explicit reference to taking full regard of animals as sentient beings and therefore include welfare measures that take this into account. 
• We also advocate for strict action to curb international transportation of exotic animals for the pet, fur, zoo and vivisection trades. This is a vital step to prevent non-native species being introduced to the UK.

• We wholly object to the use of lethal measures to manage non-native species. 
• We also object to restrictions being placed around rescuing and releasing established species into the wild, and feel that this is disproportionate and counterintuitive. 

Question 10- Are there any actions that you think should not be used as part of a general management measure for a particular widely spread species?

Question 11- What are your views on the proposed licensable management measures set out in Appendices C & D?

View Appendix C & D

• We have some concerns over the example: ‘the removal of populations from the wild, and their subsequent keeping under licence at a facility as part of non lethal eradication efforts, where the total removal of a small population from the environment could be assured’.
• We advocate for the use of non-lethal methods, but are concerned that the removal of individual animals from the wild into captivity will be detrimental to their welfare.
• We believe the impact that forthcoming legislation will have on wildlife rescue centres will be extremely negative. This is relevant to Appendix C licensable measures, as some rescue centres may seek participation under license for non-lethal activities such as administering contraception to rehabilitated animals before wild release.
• We are extremely concerned about the disproportionate action of revoking rescue and release licences for non-native species, around the entire country. 

It is very important to be careful with how you word the response, as certain things may result in your response being excluded. Please see the below warning from the consultation document:

Please note, responses that either:

1. Propose that we make exceptions for particular species from the requirement to have in place effective management measures for widely spread species of Union concern, or
2. Propose that we make exceptions for particular species from the restrictions of the Principal Regulation,

Would not be consistent with our obligations under the Principal Regulation. Suggestions of this nature would therefore fall outside the scope of this consultation.