SNH is seeking input as it prepares to make changes to the 2013 General Licences.
This is a welcome move. The 2012 General Licences are not really fit for purpose, to say the least. We’ve blogged before about certain aspects of these licences, particularly those relating to the use of crow cage traps (see Crow traps: what you should know Part 1 here, Part 2 here, and Part 3 here) as well as clam traps (see here and here).
However, when you have a look at the consultation letter put out by SNH (see here) you’ll notice that they’ve carefully avoided many of the most concerning issues.
To better understand some of these issues, please read Crow Traps: What you should know Part 2 (here is the link again). These issues include (but are not limited to) compliance (or not) with European environmental legislation; welfare concerns; poor trap design that allows indiscriminate species trapping; year-round use (as opposed to seasonal use); ineffective regulation of crow trap users; ineffective monitoring of crow trap use (i.e. number and species caught/killed); inability to identify an individual trap user; and a lovely get-out clause for any General Licence user with an unspent criminal conviction.
The highly contentious issue of the ‘clam trap’ (also known as ‘Larsen mate trap’, ‘snapper trap’ and ‘butterfly trap’) has been raised in this consultation, although SNH’s plans for how to deal with it are astonishing. They recognise that welfare concerns remain about the use of these traps, but instead of banning them until independent research shows they are safe to use, they’ve decided to continue their use and commission research on their use “shortly”. They do suggest that they’ll require clam trap users to notify them of intended use, but really, what’s the point of that, other than being able to identify users as potential participants in their future ‘evidence gathering’ exercise?
When you consider the high level of training and accreditation required by those who want to trap wild birds for scientific research (i.e. bird ringing) and compare this with the very low standards required for those who want to trap wild birds to kill them (sorry, ‘control them for conservation purposes’), you realise what a joke the current system is.
The consultation is open until 9th November 2012. You can fill in the form (here is the link again), or, if you think that there are important issues that haven’t been addressed on the consultation form, why not write directly to SNH and explain your concerns? Email your comments to Robbie Kernahan, Head of Wildlife Operations, SNH: licensing@snh.gov.uk
SNH plan to publish a revised suite of General Licences for 2013 by early December.