BASC has insisted there is no justification for a site-wide ban on the use of lead shot in its response to Natural England’s consultation on the proposed confirmation of the West Pennine Moors as a site of special scientific interest.
The West Pennine Moors is the largest new site of special scientific interest (SSSI) notified by Natural England (NE) since 2004, covering a total of 76 square kilometres between Chorley, Blackburn, Bolton and Haslingden in Lancashire and Greater Manchester.
Following the notification last Novemner, NE began a four-month consultation with landowners, occupiers and other interested parties as part of the process of confirming the area’s SSSI status.
BASC’s official submission to the consultation seeks written assurance that NE will withdraw a clause which stipulates that the use of lead ammunition over any part of the site would require NE consent.
In support of its submission, BASC cited Defra’s decision last year not to ban lead ammunition as the available evidence had shown no impact at a population level. BASC also referred NE to the Regulator’s Code, which seeks to avoid imposing unnecessary regulatory burdens.
BASC north director Duncan Thomas said: “BASC recognises the important role SSSIs play in the conservation of species and habitats. However, having consulted on the SSSIs that are listed to qualify as wetland SSSIs, BASC can see no justification to put in place a site-wide ban on the use of lead shot over this proposed SSSI.
“We are sure NE is aware of the current policy in England – The Environmental Protection (Restriction on Use of Lead Shot) (England) Regulations 1999, as amended in 2002 and 2003. This prohibits the killing of water birds with lead shot and allows the listing of certain wetland SSSIs where lead shot cannot be used for any purpose. This is to address the evidence of the risk to water birds from lead shot.”
NE’s consultation document also says there is a need to prevent disturbance in woodland where herons nest. It recommends discouraging recreational use of woodland between late February and early August and banning game shooting completely in areas where birds are nesting.
BASC seeks a written assurance that game shooting will not be banned in woodlands where herons nest.
John Thornley OBE, BASC vice-chairman, said: “The West Pennine Moors is a spectacular upland area of national significance and its conservation value is thanks to centuries of sustainable land management by local communities. Shooting has played a key role in that conservation effort and this SSSI designation should not be to the detriment of shooting.
“BASC hopes Natural England will see shooting as crucial to the ongoing conservation of this remarkable place and will take on board our views before confirming the SSSI designation.”