The Countryside Alliance has responded to the Welsh Government’s Wild Animal Welfare consultation which proposes to introduce a statutory close season for hares, firmly opposing the plans.
The measure attempts to prevent hares being shot during the breeding season, yet the consultation document does not provide any evidence that the current legislative framework and management of hares in Wales is at all problematic. The Welsh Government also notes that the hare is the only game species that does not have a close season, however the hare is also the only species that has a dual classification, being classed as both “game” and a “pest”.
The lack of data on hare shooting during most of the proposed close season raises the question as to how the Welsh Government can reasonably conclude there is a legitimate animal welfare interest in the proposed measure: in other words, that there is a problem that needs to be solved.
As the consultation’s own Impact Assessment highlights, there are numerous uncertainties around the proposal including “the scale of hare shooting activity during the proposed close season period” and “the magnitude of potential welfare benefits arising from the proposals”. It also states that:
“the assessment also assumes compliance costs will be limited because many individuals and organisations likely to be affected already operate in accordance with good practice guidance intended to…avoid the killing of hare during the breeding season.”
The Hares Preservation Act 1892 already creates an effective close season by prohibiting the sale of hare meat during their main breeding season. The Game and Wildlife Conservation Trust (GWCT) was made the Biodiversity Action Plan champion for Brown Hares in 1998. Its view is that the current combination of law and self-regulation means that the principle is already being followed that controlling species in their peak breeding should be avoided unless genuinely essential and unavoidable.
The GWCT has rightly noted that:
“Closed seasons are not appropriate in a pest control context. Where the aim is to reduce the numbers of a pest species in an area, allowing them full opportunity to reproduce is clearly counter-productive. That is why non-game wildlife species that are at least sometimes pests (e.g. fox, grey squirrel, wood pigeon) do not have closed seasons in the UK, whereas game species do.”
Not only do hares breed year-round, but those born in January and February have low survival rates due to factors besides culling, such as the weather. It is hard to see how introducing a statutory close season different from the de facto one currently observed will improve hare welfare at either the population or individual level. A statutory close season will create a situation that assists neither hares nor those who manage them. The current arrangements are flexible and, most importantly, they work.
The Countryside Alliance believes that, in prohibiting commercial sale throughout most of the breeding season, the Hares Preservation Act 1892 is already sufficient to meet the policy objective of a proposed close season. Introducing one in addition would only harm the legitimate interest of farmers in protecting their land and crops by controlling hares occasionally at need.
Director for Countryside Alliance Wales Rachel Evans said:
“We believe that the current situation allows for proper hare control while also protecting the health of the overall population and minimising the consequences for leverets during the breeding season. In practice a statutory close season would make little, if any, difference in terms of welfare but would result in additional burdens on land managers and risk the overall health of hare populations.
“However, if the government does proceed with a statutory close season, then it should follow existing practice, with any close season beginning no earlier than the end of February. Any exceptions or licensing for killing hares in the close season should be simple and easy for land managers to use.”
The consultation closes on 19 October and is available here.