The Countryside Alliance is encouraging everyone with relevant knowledge and first-hand experience to respond to the Government’s Call for Evidence on the rearing, release and shooting of gamebirds in England, which closes on Sunday 1 November. To help those submitting evidence we have prepared guidance in conjunction with other Aim to Sustain partner organisations, and the GWCT as its scientific advisor.

The Call for Evidence is not a policy consultation. Defra has stressed that no policy decisions have been taken at this stage on whether changes are needed, and that any future proposals would be subject to a public consultation. Should that subsequently be the case we will ensure that everyone has the opportunity to raise their concerns with any proposed changes to their MP and Defra ministers.

The purpose of the Call for Evidence is allegedly to give Defra a better understanding of the potential benefits and adverse impacts of game shooting, and to identify important gaps and uncertainties in the Department’s knowledge. However, the use of the word ‘potential’ when referring to benefits is in itself telling.

Defra is interested in evidence relating to environmental impacts, including biodiversity, protected sites and habitats, animal health and disease risk, wildlife crime, housing and welfare of gamebirds and mallard during breeding and rearing prior to release, the use of natural resources, the effectiveness of current regulatory and voluntary approaches, relevant environmental or social impacts, and any ‘blockers’ for adoption. In seeking that evidence, many of the questions in the Call for Evidence lead with a negative, only to then follow with a request for positive information. An independent assessment of the economic value of the gamebird sector is being commissioned separately.

The types of evidence being sought by Defra includes peer-reviewed research and published studies; official statistics, monitoring data and datasets; well-documented operational or practical experience; and information identifying gaps in the current evidence base. It is therefore unfortunate that Defra has also seen fit to include unpublished evidence, reports, working papers and other grey literature, with the high probability that these may contain figures and claims that are unverifiable, such as those in the RSPB’s annual Birdcrime Reports.

Opponents to game shooting are fully expected to use the Call for Evidence as an opportunity to promote their anti-shooting agenda. This includes the RSPB, the Chief Executive of which wrote to Defra Secretary of State in January expressing disappointment that licensing of shooting and gamebird release had not been included in the Government’s Animal Welfare Strategy. Calling for licensing, she made an unsubstantiated claim with the clear intention of attempting to influence government policy in order to further the RSPB’s own agenda.

It is essential that any future policy decisions are informed by the best available science and evidence, and that they are justified and proportionate. It is therefore essential that all those with the relevant knowledge and first-hand experience respond to the Call for Evidence.  Submissions need to be analytical, and supported by evidence, and the guidance that has been compiled by the Countryside Alliance, Aim to Sustain partner organisations and GWCT will hopefully be of help when doing so.

The Call for Evidence is in two parts. Section A is focussed on gamebird release and shooting with Section B covering the rearing of pheasant, red-legged partridge and mallard. There are a total of 106 questions many of which are technical. Only those questions for which one has the relevant evidence need be answered, using the online form when doing so. For those unable to respond online, responses may be submitted by email to Gamebirds@defra.gov.uk, with "Call for Evidence" included in the subject line. If responding by email it is important to reference the question numbers being addressed.