Shooting on Natural Resources Wales land: Briefing Paper



Natural Resources Wales (NRW) was established in 2013. Some of its predecessor bodies (Countryside Council for Wales, Environment Agency Wales and the Forestry Commission Wales) had, in years past, entered into agreements with five shoots to operate on land they owned or managed. Shoots included areas made up in whole or in part of ancient woodlands, some of which fall within or border spaces that enjoy protected status under the Sites of Special Scientific Interest (SSSI), Special Areas of Conservation (SAC) or Areas of Outstanding Natural Beauty (AONB) regimes.


NRW, despite its key objective to act as a good steward to the countryside of Wales and its wildlife, sought to lease out additional sites for shooting. The decision to expand those activities were despite increasing awareness of the role of pheasant shooting in the degradation of natural habitat and the decline in biodiversity, as well as concerns over public access, animal welfare and the lack of economic benefit for local communities.


Issues with shoots on NRW land

Shooting tenants annually release thousands of factory-farmed, non-indigenous pheasants into the woodlands.  The standard ‘rear and release’ model employed by pheasant shoots involves birds being intensively bred at external sites before being transported to release pens located where shooting takes place.  Industry figures indicate that a substantial proportion of the released birds will die of disease, of predation or under the wheels of a vehicle. When the shoots themselves are taking place, around 40 per cent of pheasants are shot down but not retrieved. An uncounted number will remain injured, without veterinary attention to alleviate their suffering, until death overcomes them.


Research conducted by The James Hutton Institute suggests that the ‘rear and release’ approach can also have many negative impacts on the natural environment. These include habitat changes that affect flora, hedgerow structure on the woodland fringe and soil composition.


Pheasants, furthermore, reduce the biomass of groundactive invertebrates, causing a decline in carabids, all of whom are important food resources for breeding birds. The parasite loads carried by purpose-bred ‘gamebirds’ such as pheasants are very much higher than is found in their wild equivalents. The spread of disease by released birds not only increases mortality in wild birds, but may also reduce their reproductive potential and make them more vulnerable to disease.



Land purged of native wildlife

Shoot tenants employ a variety of vicious predator control devices to ensure high stocks of pheasants on shoot days. Traps, designed to crush and immobilise are used on foxes, stoats, weasels and other animals who present a perceived threat. Many of these targeted animals will sustain painful and stressful injuries, which they might be forced to endure for up to 24 hours before, as demanded by the law, they are despatched. Animals’ distress, however, can continue for much longer, where a trap-setter fails to check the device within the required time limit. Corvids are invariably shot or cage-trapped. In the case of the latter, the standard method of despatch is a blow to the back of the head of the trapped bird.


Lead ammunition

Toxic lead ammunition is also used at each of the sites. The impact is particularly stark with respect to birds of prey, especially when they consume shot ‘gamebirds’. Studies have shown increased levels of sickness, death and reproductive failure in birds of prey and other predators. The Oxford Symposium on lead poisoning estimated that between 2,500 and 6,700 tonnes of lead shot is fired at ‘gamebirds’ each year in the UK. It further stated that ‘lead ammunition now appears to be the only significant, geographically widespread and common source of unregulated environmental lead contamination to which wildlife is exposed.’ It is because of the loss of biodiversity as set out above that the production of birds for sport shooting has been made illegal in the Netherlands.


NRW’s shooting agreements

Animal Aid first became involved in this issue in October 2015, after a well-placed source told us that NRW wanted to rent out some of its land in Myherin for the ‘sport shooting’ of pheasants. As our research progressed we discovered that at least five other parcels of land managed by NRW are rented out for shooting. While NRW did not initiate these shoot agreements – one or more predecessor bodies was responsible – NRW could have wound down the operations. Instead it wanted to expand them. The current situation (April 2018) is that there are three shoots currently operating on NRW land.


NRW staff concerns:

A number of problems were highlighted in internal consultation documents – an exercise undertaken prior to new shoots being tendered. In those reports, senior NRW staff warned against going ahead with the new leases. They outlined the problems they foresaw, that seemed to be without an obvious solution. As an example, [an] NRW Conservation Manager, wrote: ‘My considered opinion is that Myherin is not suitable for a leased shoot as things stand, and that any intention to take this proposal forward should require wider NRW and partner body consultation and an Ecosystem Appraisal of the likely effects of these shooting lease proposals.’ In terms of the income that could be expected to be generated against that which could be lost, [a] Programme Manager, said: ‘In my view the financial-, employment- and environmental impacts to harvesting by letting shooting rights here, will far outweigh the monetary income generated by a let. I note that no financial comparison has been carried out as part of this exercise.’ [The Conservation Manager] also challenged a claim that the land earmarked for shooting was in ‘inconsistent use’ by the public. He pointed to Nantsyddion Bothy, which ‘is currently leased/ loaned to the Mountain Bothies Association and is well used by walkers and well maintained at no cost to NRW. It forms part of a chain of bothies through Wales and often used in conjunction with Nant Rhys in Tarenig. Both Nant Rhys and Nantsyddion are well used. Does NRW really want the negative publicity of evicting MBA in favour of creating a shooting lodge.’


Public consultation

One key issue with expanding shoot operations was that NRW had failed to engage public opinion on the matter. A statement made in a 30 March 2016 letter from Trefor Owen, Executive Director for National Services, to a local resident, stated that ‘NRW activity has not attracted significant stakeholder interest in the past; it is for this reason that the new leases were not identified as being of ‘High Public Interest’.


Animal Aid sent a dossier to the then Minister for Natural Resources, asking him to intervene to ensure that current contracts were not renewed when they expired in March 2016. The Minister said in a statement that he was going to keep the matter ‘under review’.  This Review process began in 2017 with the Public Consultation closing tomorrow, 25 April 2018.


Financial issues

NRW spent a considerable amount of time and money tendering the new shooting arrangement to prospective clients. In return, it receives a mere £5,965 (not £30,000 as stated in NRW’s Briefing to the Minister) for the renting out of all shooting rights – a total that is likely to be comprehensively eclipsed by the cost of administering the deeds, by economic loss to the local communities through the impact on recreation and tourism, and by damage to NRW’s reputation as a custodian of public land.


Animal Aid’s investigations

November 2015:

Animal Aid investigators visited four sites over a weekend in late November 2015. We found numerous pheasants drifting up and down country roads near Maesmawr and Llanfair woods, vulnerable to being hit by vehicles. The evidence we collected pointed to several contract breaches, including the illicit release of birds; laying traps for animals; and the introduction of feeders onto land where it was not permitted to do so.


June 2017

On 19 June 2017, when temperatures in the UK had nudged 30ºC, an Animal Aid investigator visited the land leased for shooting by NRW at Cwm Gwnen.Our investigator saw an estimated 35-40 young pheasants, dead on the ground inside a release pen.


Equally disturbing were the four birds who had become stuck in between two sections of wire mesh. We believe they must have died from either dehydration or strangulation.

Another three birds were trapped in between the two sets of wire mesh but were still alive. Animal Aid’s investigator managed to free them so that they could return to their pen.


Public opposition

More than 12,000 people have signed an Animal Aid petition which calls for an end to the shooting of birds on public land that is managed by NRW on behalf of the people of Wales.


A YouGov poll, commissioned by Animal Aid and the League Against Cruel Sports, found that 76 per cent of people in Wales thought that shooting birds should be made illegal and the same figure also oppose the shooting of ‘game’ birds for sport on public land in Wales, after learning that game birds used for breeding are often permanently kept in small, mesh-floored cages and their chicks are later released for sport shooting.