Joint letter to JNCC, Natural England, Natural Resources Wales and NatureScot
Dear JNCC, Natural England, Natural Resources Wales and NatureScot,
Re: 7th Quinquennial Review (QQR) of Schedules 5 and 8 of the Wildlife and Countryside Act (1981)
We are writing this open letter in response to the consultation about proposed changes to the eligibility and decision criteria to determine which species will be included on Schedules 5 and 8 of the Wildlife and Countryside Act 1981 as outlined in the 7th Quinquennial Review (QQR7) consultation document.
Since our previous letter sent in June 2021, we appreciate the extension made to the consultation period, the initiation of stakeholder meetings, the subsequent amendments made to the QQR7 proposals and the broadening of the consultation to include the eligibility and decision criteria. However, we stand by our original objections, notably that the definition of endangerment within the eligibility criteria must not be narrowed to exclude Vulnerable (VU) species.
• The use of the word ‘permanently’ is inappropriately restrictive given that many species depend upon multiple sites to rest or nest, moving frequently (e.g. dormice, harvest mice) or lack clearly defined territories (e.g. hedgehogs)
• The use of the word ‘regularly’ is unhelpful and ambiguous; without frequent and regular monitoring of sites, how will the regularity of the use of a site be established?
We would like formally to state our joint position that the proposed changes to the eligibility and decision criteria as defined for the 7th Quinquennial Review (QQR7) for adding species to Schedules 5 and 8 of the Wildlife and Countryside Act 1981 are not fit for purpose. If adopted these changes would inevitably weaken efforts to address the current Biodiversity Crisis and undermine the new aims of the Environment Act in England. We urge you to adopt a new approach that is unambiguous and supportive of efforts to reverse declines in biodiversity broaden these rather than making cases for exceptions.
We await your response.
Yours Sincerely,
Amphibian and Reptile Conservation Trust (ARC)
Amphibian and Reptile Groups of the UK (ARG UK)
A Rocha UK
Badger Trust
Bat Conservation Trust
Biological Recording in Scotland (BRISC)
Black2Nature
Born Free Foundation
British Dragonfly Society
British Ecological Society
British Hedgehog Preservation Society (BHPS)
British and Irish Association of Zoos and Aquariums (BIAZA)
British Trust for Ornithology Bumblebee Conservation Trust Butterfly Conservation
Citizen Zoo
CPRE Kent, the countryside charity
Dumfries and Galloway Pine Marten Group
Freshwater Habitats Trust
Friends of Glasgow’s Local Nature Reserves
The Froglife Trust
Glasgow Natural History Society
Hare Preservation Trust
Institute of Fisheries Management
Knepp Estate
The League Against Cruel Sports
The Mammal Society
Marine Conservation Society
Naturewatch Foundation
OneKind
People’s Trust for Endangered Species (PTES)
Pesticide Action Network UK (PAN UK)
Rewilding Britain RSPB
Royal Society for the Prevention of Cruelty to Animals (RSPCA)
Salmon & Trout Conservation Scottish Badgers
Scottish Wild Land Group (SWLG) Scottish Wildlife Trust
Trees for Life
Wales Environment Link
Whale and Dolphin Conservation (WDC)Wildlife and Countryside Link
Wild Justice
Wildlife Gardening Forum The Wildlife Trusts Wildlife Trusts Wales The Woodland Trust
The Zoological Society of London (ZSL)