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

Posted on the 20th August 2019

Please respond to the government consultation for 'Invasive Alien Species'

What’s happening?

The government recently launched a consultation on ‘management measures’ for widely spread ‘Invasive Alien Species (IAS)’ in England and Wales. They have invited interested parties to submit their responses to the consultation.  

Many of the proposals by the government are shocking, and suggest wide-ranging culls of ‘non-native species’. From December, a new law on ‘invasive species’ will also make it illegal to rescue and release non-native animals such as grey squirrels and Muntjac deer. The situation for these highly persecuted animals is therefore extremely grave.

No animal should be cruelly and pointlessly culled because of their origins. Wildlife rescue centres should not have to choose between subjecting wild animals to an unnatural life in captivity, or being forced to euthanise them because of the law. All wildlife deserves to be treated with respect and compassion. 

What you can do?

Animal Aid has submitted a response to the consultation, and you can too! This is a great opportunity to support animals such as grey squirrels, and demonstrate to the government that public opinion is against culling.

Below we have put together some guidance on how you may want to respond to the consultation, in order to give these animals a voice. Your submission may be more effective if the drafted answers are slightly amended and expanded, rather than copying and pasting. Please read through the consultation document carefully before submitting your answers. 

You can submit your response through the Defra website (linked at the bottom of the page) or by emailing invasivealienspecies@defra.gov.uk. 

The deadline for submitting your response is 12th September 2019.

Questions 1-5

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.

Question 7 - What are your views on the general management measures set out in Appendix B?

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.  

Question 6 - What are your views on the proposed aims for the management measures set out in Appendix A?:

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. 

Question 8 - Are there any additional actions you think should be used as general management measures for particular widely spread species?

  • 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.

Question 9 - Are there any actions that you think should not be used as part of a general management measure for a particular widely spread species?

  • 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. 

Questions 10 - 12

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?

Q12. Are there any actions that you think should not be allowed to be used as part of a licensable management measure for a particular widely spread species?

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. 

 

 

Important information

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.

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