The key basis of Sandwell Council’s arguments for goose culls.
Natural England “Guidance” in context
Sandwell council claim to have followed Natural England guidance. In a freedom of information request and in Adrian Scarrott and Steve Handley’s report they defend their actions by making this claim.
It is a fact that Natural England’s “guidance” stems from a DETR funded paper written by one man in 1999 by the name of “Dr” John Allan who appears to have worked for the quango (Central Science Laboratory) and latterly the Animal Health and Veterinary Laboratories Agency (AHVLA).
It has since appeared to be rewritten four times and the last edition has now been archived and is called TIN009.
This was entitled
Mr Allan’s credentials are not explored in his paper, and the conclusions he makes do not appear to have been peer reviewed by independent observers interested in animal welfare, rather than economic partisan industries.
“The aviation industry continues to express concern about the increasing numbers of Canada Geese on water bodies near aerodromes.” Cited from Mr Allan’s paper
Indeed Mr Allan’s involvement in “birdstrike” seminars involving planes and hosted by the aviation industry leaves one questioning to what extent his paper and conclusions were bought and paid for by the aviation industry lobby itself, especially when he amplifies their “concerns” into Government policy?
Canada geese are a scapegoat for this unsafe industry whose expansion, particularly with extended runways requires the demise of wildlife legislation protection, most usually through paper weight “licences” that are not worth the paper that they are written on. They have little enforcement, and Natural England have admitted that they are unlikely to ever prosecute anyone for breaching them.
Indeed in my own formal complaint against Sandwell council for breaching their General Licence criteria, I was merely told that I should contact my local Wildlife Liaison officer in West Midlands police.
The first criticism of Allan’s work comes from his estimates of geese in the UK.
In 1999 the paper opens
“The Canada Goose population in Britain numbers over 63,000 birds and is still increasing.”
In edition 4 it is stated
“The Canada goose population in southern Britain numbers over 80,000 birds and is still increasing. However, in recent years the overall rate of growth has slowed and in some areas numbers have stabilised or declined.”
So in just twelve years the entire population of the UK has suddenly appeared to have increased by 17,000 into just the undefined “Southern Britain.” Is it a surprise that this region is highlighted given the debate concerning extra runway expansion at airports in Southern Britain? I think so.
The admission that “the overall rate of growth has slowed and in some areas is in decline” totally undermines his 1999 estimates and later claims of increase- his figures are therefore a joke.
Similarly the cited causes of death in the birds in the two papers remains the same, and it is unclear as to where these figures even originated in 1999, or what agencies contributed to the findings. Many birds die in the wild, but many also die in rehabilitative care. Clearly not all geese are post mortemed or even found dead, and expressing deaths in terms of percentages rather than raw figures can of course be misused statistically.
1999 report states “The causes of death are:
- 67.2% shooting
- 4.3% hit power lines
- 5.5% redation (sic ) (predation)
- 23% unknown. “
The 2011 report states
“The causes of death are:
• 67% shooting
• 4% hitting power lines
• 6% predation
• 23% unknown.
Thus in twelve years the statistics we are supposed to believe have not changed, except they have just been rounded to the nearest significant figure.
IN SHORT THE “EXPERTISE” OF NATURAL ENGLAND ON THE MATTER OF CANADA GEESE AND THEIR MANAGEMENT IS HIGHLY QUESTIONABLE WHEN THEY CANNOT ACCURATLEY STATE THE NUMBER OF ACTUAL CANADA GEESE IN THE UK, AND APPEARS BASED ON ECONOMICS RATHER THAN CONSERVATION OR ANIMAL WELFARE. THE GEESE ARE LARGE BIRDS, AND THE AVIATION INDUSTRY DOES NOT WANT LARGE BIRDS IN THE VICINITY OF ITS AIRCRAFT OR RUNWAYS- PARTICULARLY IF IT THREATENS THEIR EXPANSION.
In following “guidance” therefore, local authorities and others are actually following flawed evidence. SANDWELL HAS NO AVIATION ISSUES, AND NO RUNWAYS.
It is clear that in his report John Satchwell selectively directly plagiarises certain phrases from Allan’s original 1999 report, and these are even echoed in Adrian Scarott’s/Steve Handley’s scrutiny meeting report. One could claim that this “follows” Natural England guidance yet set against the context of the guidance in general we argue that it is John Satchwell who misuses this paper to present a biased report which is not sensitive to public concerns for animal welfare, not relevant to the context of Sandwell itself or the two parks in question, and nor does it satisfy the criteria that Allan mentions within the paper.
It is noted that in John Satchwell’s April 2013 report, he makes no citations of Natural England Literature, which other council officers appear to have subsequently found on the internet and have attempted to use in defence of his findings and also claim to have followed “Natural England guidance”. The primary source they cite is actually guidance towards the rounding up of the geese, TINO46 rather than one which looks at relevant options for carrying out assessments.
This therefore appears to suggest that a decision was made to cull based primarily on the wrong guidance literature, as specified here. It is noted however that John Satchwell’s report directly plagiarises several phrases in another Natural England document TIN009 “The management of problems caused by Canada geese, a guide to best practice.” He does not cite this literature in his report, and strangely neither have the council in responding to my FOI requests or criticism regarding the cull. WHY?
NB this is not covered by the licence that SMBC are relying on to cull, yet John Satchwell included it anyway. Note there is little in his report which deals with the health and safety issues concerning human health.
The number of geese in the two parks was not “high” in comparison to numbers in previous years, if the council as they claim were undertaking egg pricking.
All suitable measures for potentially alleviating “the problem” as Sandwell council saw it were not explored before culling. John Satchwell makes claim that previous attempts had been made to reduce numbers, yet the council have had to admit they have no actual figures/data that there had been any “alarming increase” in adult goose numbers at the two parks- as their 1997 policy said may need to carry out lethal control measures and “total removal” of the birds.
The third of the licences “preserving public health and safety” (general licence WML-GLO5) is the one which the council are now relying on. This licence does not have to be “applied for” or “awarded to” anyone as the council have incorrectly stated.
The council do not appear to have asked the opinion of anyone externally that all appropriate non-lethal methods of control were either ineffective or impractical. Their cull relies on a one off count made in March 2013 by “park wardens”, without any previous data or knowledge that those birds counted were even resident on that day, or that birds culled in the two parks some months later in moult were even the same birds, or others that had just been unfortunate to have gone there and then would have left once resuming flying ability.
I do not believe that the officers of the council understand this licence. The initial claims made by the councillor who authorised this cull talks of reintroducing other non-native species (Muscovy ducks- a Central American native species) after the geese have been culled- not at all a valid reason under the general licence.
She also mentioned “nuisance” and complaints- which later were found to be false (just 8 formal complaints in the parks in 5 years, as well as unsubstantiated rubbish concerning members of the public being “attacked”. The nuisance/complaints are not valid reasons for lethal action under the general licence. The “attacks” are hyperbole without evidence. Similar hysteria made news concerning gulls over the summer last year- though not in Sandwell. Neither are arguments involving “damage” to sports pitches and amenity grassland under the GL05 licence to preserve public health and public safety.
The guidance states that a specific one off licence could be applied for. It is clear that this does not apply to the council, given they have stated which licence they are relying on. Natural England have also confirmed that they have no record of any correspondence with SMBC regarding the culls. They also did not request any recorded advice from the wildlife licensing unit. The 1981 Act is clearly set out here in terms of “preventing nuisance”. It states that these methods can be tackled using “non-lethal methods.” The council do not report or cite this in John Satchwell’s report.
“Overview of licence- This licence permits landowners, occupiers and other authorised persons to carry out a range of otherwise prohibited activities against the species of wild birds listed on the licence. This licence may only be relied upon where the activities are carried out for the purpose of preserving public health or public safety, and users must comply with licence terms and conditions. These conditions include the requirement that the user must be satisfied that legal (including non-lethal) methods of resolving the problem are ineffective or impracticable. “
The culls took place in the first weeks of July in both years at Victoria Park. The date of cull at Dartmouth Park in 2013 is unknown. WE WOULD LIKE TO KNOW THIS, AND IF ALL 100 BIRDS WERE KILLED ON THE SAME DAY? It therefore appears that the birds would shortly have been able to fly again- thus leave the site when the culls were carried out.
The operation witnessed by myself and also videoed at the time in 2013 involving Pestex was shambolic and disorganized. They asked me for my help in encouraging the geese over to the Heras fencing they had set up. A professional contractor would not require the help of members of the public, nor lie to them. As the holders of the licence, why were they even lying about their job if the council were so certain of the reasons for the cull being justified? I was told to go and see John Satchwell, which appears to confirm their knowledge of his home location, and some possible personal connection.
There is no clear integrated approach made in John Satchwell’s report. It relies on culling and then appears to talk about public reaction as a means for taking further action, rather than addressing the problem which they are claiming to be one. Public complaints are not a valid reason for culling, public health and public safety are the reasons for culling under the licence cited, yet his report is short on any detail as to what these concerns actually are. If he or the council understood the different types of licence, then why is there no specific reference/website links to them in his report. Why did the Cabinet member not ask for details on the licence or for further advice?
There appears to have been no consideration as to “adverse public opinion”, not a reason for culling in any case under the terms of the licence, nor about non-breeding birds filling the void. In fact the council claim to have carried out a further cull of birds at Victoria park in 2014 (70) because of more birds appearing, not those left when they had reportedly killed 50 in 2013.
It is not known what reconnaissance had been undertaken by pestex. No members of SMBC were present in the park.
The erection of the holding pen in 2013 appears to have been made on the morning itself. The geese were clearly alarmed by the actions undertaken as it witnessed on the video I took. Only 4 staff were present at the site. Less than stated in this guidance.
It is not entirely clear from the council’s own observations as to how the birds were killed given that none of their staff were present, despite them opening up one of their barns at Forge Mill Farm for the purpose.
This week is likely to see the revealing of the joke questionnaire results, which the council consider to be “consultation”, which was never publicly advertised by them. A showdown is looming, and it will not be the geese digging themselves into further embarrassment.