“Wales’ shooting sector should be proud of the number and high quality of responses opposing NRW’s proposals to introduce a statutory licence and accompanying regulations in its consultation which ended in June,” says CLA Cymru’s Charles de Winton. “NRW’s still digesting the results, but all the signs tell us that the Welsh Government agency is set to go ahead with its plans despite the weight of expert evidence presented.”
“This suggests – directly contradicting the words of the consultation preamble – that the forces at work are ideological rather than objective and evidence-based. Convention suggests that a consultation exercise should be followed by a report of findings, including comment how the consulting body will learn from the responses – and possibly commitment to engage with expert bodies to achieve best results. I’m calling on the Welsh Government and NRW to commit to this proper process.”
“There ought to be a process of appeal: firstly against proposals which are not founded on clear and convincing evidence; and secondly if government fails to demonstrate how it learns, adjusts or even abandons poorly developed proposals in the face of convincing evidence. A possible option is judicial review.”
“If NRW proceeds, the statutory licence and regulations will come into force as soon as next season. The organisation which represents shooting interests, Aim to Sustain (A2S) – of which the CLA is part – is making it clear to government that the timeframe simply isn’t workable. It demonstrates again that the Government doesn’t really understand the industry. Poults are already ordered, pens are already positioned and release-areas have long been in preparation. Some shoots may need to change management practices to comply with the required GWCT Code of Conduct to meet the licence criteria – this may take time and add to costs. Additional special conditions will be required where game is released on designated land – or within half-a-kilometre of it.”
“Some game managers may discontinue – we’re already hearing of gamekeepers leaving Wales or giving-up their skilled profession. And we’ve explained to government that these uniquely skilled individuals are badly needed to manage a sustainable countryside.”
“We called on government to carry out a full impact assessment of its proposals. Clearly we’re about to learn their impact without the benefit of research, measurement and modelling which we would see in other industries.”
“Our advice is that in-advance of any formal regulations, shoot managers should assess how the licence criteria will affect them – and look to make changes as soon as possible and with least possible impact on the shoot.
“It could be worse,” Charles says. “Those shoots well-outside designated land and who can absorb the costs will be able to continue. Our concern, of course – and this point was made in many responses to the consultation – is that there’s no proposed safeguard against regulatory creep: Government (via its agency, NRW) – could make it progressively more costly and difficult to comply: a process of gradual banning. Many of Wales’ shoots’ clients will simply shoot elsewhere, relieving the rural community of a valuable part of the rural economy.