NRW is currently consulting on the terms of a proposed licensing scheme for pheasants and red-legged partridges which are released into the wild for sport.  The Society has responded to the consultation, which runs until 20 June 2023, but Members may also wish to respond individually – especially in those parts of the Cambrian Mountains most affected by pheasant shoots (the Trustees are not aware of any partridge shoots, but do let us know if there is one in your area).

Note that the consultation does not address the question of banning game bird releases, only potential licensing terms.  For those who wish to respond, the survey is at NRW Game Birds.

The text of the Society’s response to the substantive questions is below:

Q4. Do you agree that common pheasant and red-legged partridge should be added to Part 1 of Schedule 9 of the Wildlife and Countryside Act 1981 in Wales? This change would mean that releasing those species in Wales would need to be carried out under licence. Please give reasons for your views.

Yes.  The RSPB reported in 2016 that at the point of their release, the combined biomass of all the gamebirds in the UK (released and naturalised) was more than twice the spring biomass of all native UK breeding birds. This clearly represents a significant threat to the ongoing populations of native birds which compete with the game birds for food.  Further, artificially abundant prey sources, such as released gamebirds, may allow numbers of generalist predators to increase, particularly since the UK lacks the larger predators (such as wolves and lynx) that may formerly have limited the numbers of generalist predators. Positive relationships have been found between the number of gamebirds released in a locality and the density and growth rates of avian predators. Such enhancements of generalist predator populations could have negative impacts on other sensitive native prey species, including ground-nesting birds such as waders.

In ecologically sensitive areas such as the Cambrian Mountains, where vulnerable or endangered bird species live on what may be termed marginally sufficient land, there is a real risk of damaging the sustainability of those populations beyond repair even by the dispersal of a relatively low density of reared birds. Pheasants released in the Cnyffiad valley, for instance, are regularly seen in the Irfon valley with its multiple SSSIs and National Nature Reserve, while birds released on the Tregaron side of the uplands are seen around Nant-y-Maen in the middle of the Elenydd.  Though few relative to the total numbers released, these represent a significant addition to the low density populations of native birds surviving in this harsh environment.  Unlimited and unregulated releases of game birds must not be permitted to drive our native upland birds, already under stress from avian flu threats and environmental changes due to Molinia spread and climate change impacts on wetlands, into local extinction.

Q5  If these species are added to Schedule 9, please give us your views on whether our proposed licensing approach would be effective and proportionate?

No.  A precautionary approach must be used, and the proposed licensing approach does not adequately recognise the distance to which large birds such as the species named can and will travel once released. In the US, reared pheasants dispersed 1.6–3.2 km (Burger 1964; Harper et al. 1951; Kabat 1955; MacNamara and Kozicky 1949; Wilson et al. 1992). In the USA, pheasants that dispersed post-winter on average 3.2 km moved to areas with more open ground (Leif 2005). In the UK, pheasants moved an average of 30 m further from the release pen each day after release into the wild (Robertson 1986). Pheasants released on areas with poor food and cover disperse more widely than those released in good pheasant habitat (Burger and Oldenburg 1972; Leopold et al. 1938; MacNamara and Kozicky 1949)

A distance of 500m from an SSSI, proposed to be permitted under general licence before a specific licence is necessary, is within a single brief flight for either species, and numbers of birds (which appear to scatter randomly into the landscape once released) do and will enter these supposedly protected areas despite their initial release at such a distance.  Naturally, those birds which scatter furthest are precisely those which are least likely to be subsequently removed through being shot.  A distance of at least 1 km would be more effective in reducing the proportion of the released birds  (some shoots releasing 10s of thousands of them into the wild) which actually settle in the vicinity of fragile habitats.

Further, the general licence should apply only where the total number of birds to be released in any season is 1,000 or less i.e. applicable to small family run enterprises rather than larger commercial operations.

  1. We have based the proposed general licence conditions for pheasant release on the recommendations in the GWCT guidelines for sustainable gamebird releasing. However, the guidelines do not include specific density thresholds for red-legged partridge and there appears to be less evidence on which to base conditions relating to partridge. We have used what evidence is available, and expert opinion, to propose conditions for partridge releases. These are either based on a density threshold linked to the area of cover crop provided, or on density per hectare of release pen (as with pheasants), depending on how the birds are released. We would welcome views on whether these proposals are appropriate and workable and whether they could they be improved.

No comment.

  1. The GWCT guidelines include a recommendation that no more than one third of woodland with game interest should be used for release pens. This is to ensure sufficient woodland remains that can benefit from habitat management activities. We would like to include this recommendation in our proposed general licence. However, we would prefer to be able to define what can be included in the calculation. Do you have suggestions for how this might be achieved?


In our view, the area used for release pens should be calculated by reference to the nature of the woodland concerned, as this affects both the value of the woodland for habitat management/ restoration, and the extent of subsequent spread of the birds. Where the woodland is a small patch in an otherwise open landscape, the proportion used for release pens should be further limited to ensure the remaining area is sufficient for good habitats to develop or be maintained.  Ancient semi-natural woods (defined as having been under continuous woodland cover without replanting since 1600)  should not be included in the calculation of area for putting pens in.

The licence should specifically require the shoot manager to choose sites within the woodland with the least sensitivity i.e minimum risk of loss of biodiversity.  For instance, wood edges and stream sides often carry greater biodiversity, and should not be included in the pen.  If the poults are to be medicated with water-soluble drugs at any stage such drugs can easily end up water-borne to affect populations of other organisms far downstream of the shoot.

  1. Location and density appear to be the main factors influencing the environmental impact of releases, but we recognise that smaller releases in less sensitive areas are likely to present reduced risks. It may be appropriate that small gamebird releases taking place away from sensitive protected sites and their buffer zones are not subject to the same general licence conditions that apply to larger releases. Do you think this is something we should consider? Please give reasons

No.  The problem with permitting ‘small’ unlicensed releases away from sensitive protected sites is that it is virtually impossible to monitor compliance effectively without installing (for example) public CCTV to monitor year-round what is actually being released and where.  For commercial operators whose appreciation of the conservation and biodiversity impacts of their activities is secondary to their profit motive, the temptation to increase the number released in reliance on this permission – safe in the knowledge that such breaches are extremely unlikely to have any consequences – is likely to prove irresistible.  The potential cumulative impact of only a few bad actors increasing the numbers released by say 50% every so often outweighs the social and administrative value of setting the minimum threshold.

  1. Could the proposals affect opportunities for people to use the Welsh language?

No.  The general and specific licences and any explanatory notes can both be provided in both Welsh and English language versions, with no impact on people’s ability to operate in Welsh.