BASC’s response to Trophy Hunting Consultation

BASC's response to Defra’s consultation on the future of importing and exporting hunting trophies in the UK.

No, if the government chooses Option 4. This is because the UK regulation of hunting trophies under CITES and the EU Wildlife Trade Regulations will continue to operate as is the case currently.

Yes, if the government chooses Options 1 to 3. This is because there will be an innumerable number of definitions required to avoid unintended restrictions and trade barriers for UK import and export of animal products across food, farming and other sectors utilising animal products. This would include mitigating for unintended restrictions and trade barriers for animal products used in taxidermy such as deer skulls, antlers and skins; and for animal products used in angling such as bird feathers for fishing flies and lures.

No, if the government chooses option 4. This is because the UK regulation of hunting trophies under CITES and the EU Wildlife Trade Regulations will continue to operate as is the case currently. This current system works well and provides excellent protection for endangered species.

Yes, if the government chooses options 1 to 3. This is because the UK Border Force is already resource stretched trying to prevent illegal imports and exports of various goods; and would require a considerable bolstering of resources to undertake this additional task, which will surely come at the bottom of their priorities compared with existing restrictions and human trafficking and drug smuggling.

BASC’s preferred Option is 4: Do nothing – continue to apply current controls based on internationally agreed rules. BASC does not have a second preferred option.

Please add any comments on your preferred options, including any reasons for your preference.

The consultation is focused on ostensible benefits from further restrictions but does not consider detriments, nor does it inform those who are responding to the consultation that there could be downsides to the restrictions.  

The categorization of Option 4 as “do nothing” is concerning as it implies – to the unsophisticated members of the public who are being persuaded by anti-hunting groups to respond to the consultation – that nothing is being done.  The use of the phrase ‘do nothing’ may lead to people automatically not choosing Option 4 because it seems like it has no conservation benefits. 

The methodology of this consultation is also concerning as the survey appears to allow conservation decision-making by public opinion poll.  Conservation decisions need to be made based on science and not based on the number of members of the general public who don’t like the idea of trophy hunting.

BASC supports the sustainable harvest of wildlife in the UK and overseas and the import and export of trophies arising from such harvesting where they are clearly proven to be from a sustainable source; noting that well-regulated trophy hunting programmes play an important role in delivering benefits for both nature and people.

The existing regulations provided by CITES and the EU provide sufficient evidence of sustainable sourcing, so we see no need to change the current internationally agreed system.

There is a substantial body of evidence from international sources, including the IUCN, that supports the conservation credentials of well-regulated trophy hunting. We share the view that without local communities having a vested interest in the wildlife in their area then they will not protect it and may even destroy it. Trophy hunting is one of the few economic uses of much of this wildlife and if it is curtailed, we may see the demise of many more species, and not just those that are hunted.

Over one million people shoot live quarry in the UK and BASC is particularly concerned about unnecessary and disproportional restrictions on shooting that would result if the government were to choose Option 3 (a ban on all hunting trophies entering or leaving the UK).

Option 3 would have a major impact on the management of the UK’s deer population.

It is widely agreed by all, including Natural England and Forest Enterprise, that the UK deer population requires active management and that the only humane method available is lethal control using firearms. Without this active management the population will grow to levels that are not sustainable leading to widespread damage to agriculture, forestry, native flora and fauna and ultimately the deer themselves through starvation and disease.

Over most of the UK this management occurs on private estates and is not funded through government. Indeed, a lot of the money that funds the employment of professional deer managers on private estates is generated by selling trophy hunting. This in turn incentivises the landowner to manage their deer herd sustainably. Without this income from trophy hunting then the deer would probably either be perceived as pests and eradicated, or not managed at all resulting in unsustainable population increases.

The position of the International Union for Conservation of Nature (IUCN) is that “well managed trophy hunting can – and does – positively contribute to conservation and local livelihoods” and the IUCN has called for multiple steps to be taken before decisions are made that restrict or end trophy hunting programs.

Options 1-3 would have major impacts on the management of wildlife in other countries and the UK government should not be dictating to the governments of those countries how best to manage their natural resources.

Defra staff and ministers should not make any decisions arising from this consultation without first having direct conversations with governments in the range countries affected and without first making site visits to the conservation programs in those countries that the proposed restrictions would undermine.

None. The current legislative framework (EU/CITES) is based on scientific evidence which should be the only basis for decisions of this nature. Therefore, BASC’s preferred option is 4: Do nothing – continue to apply current controls based on internationally agreed rules.

No. BASC’s preferred option is 4: Do nothing – continue to apply current controls based on internationally agreed rules.

Do you have additional information or evidence on:

A reduction in income to landowners as a result of a ban on trophy exports from the UK will potentially reduce the level of active deer management across the UK resulting in an increase in the density and distribution of the UK deer herd. This would result in further destruction, through browsing and fraying, of natural habitats, but particularly woodland communities.

The PACEC report on country sports tourism in Scotland (2015) estimates that shooting and stalking attract 130,000 visitor trips per year resulting in 280,000 visitor nights accommodation worth an estimated £69m to the local economy. With a further direct Gross Value Added (GVA) attributable to the activities of shooting and stalking visitors of £21m. Most of this expenditure takes place within 10-15 miles of the country sports site.

Unfortunately, there are no similar figures for England and Wales, but it is likely that they are at least equivalent to those of Scotland.

If trophy exports were banned from the UK then a significant proportion of this additional income would be lost to rural communities who rely on this often at times of year when other tourist activities have declined.

If the scope is increased to include all trophies as in Option 3 then there will be other issues which have not been considered:

  • Deer antlers are naturally cast annually so it will be impossible to determine if a derivative of deer antler is from a cast one or a hunted one.
  • Will this also include the feathers of birds? Some hunters will collect the ‘pin’ feathers of Woodcock (Scolopax rusticola) they have shot. Will these be classed as ‘hunting trophies’?

BASC supports the sustainable harvest of wildlife in the UK and overseas and the import and export of trophies arising from such harvesting where they are clearly proven to be from a sustainable source so our preferred option is 4: Do nothing – continue to apply current controls based on internationally agreed rules.

No. BASC’s preferred option is 4: Do nothing – continue to apply current controls based on internationally agreed rules.

No.

BASC’s preferred Option is 4: Do nothing – continue to apply current controls based on internationally agreed rules.

UK Border Force is already resource stretched trying to prevent illegal imports and exports of various goods; and would require a considerable bolstering of resources to enforce unnecessary and disproportionate prohibitions arising from this consultation, which will surely come at the bottom of their priorities compared with enforcing existing restrictions and human trafficking and drug smuggling.

Useful resources:

What can you do?

We need you to respond individually to the consultation and share your experience. Here are the two things you can do:

  1. Contact Defra as an individual stating your opposition to option three: A ban on all hunting trophies entering or leaving the UK. You can do this by emailing Defra here: huntingtrophyconsultation@defra.gov.uk 
     
  2. Fill in this template document providing your own personal experience and send it to Defra

Deadline extended until 25th February

Trophy Hunting

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