Natural England: apologists for nest robbers

The news came to me in a tweet:

Natural England - Screenshot 2020-04-18 at 09.13.21

Now, I love Peregrine Falcons, and yet I rarely see them. A glimpse of one as I cycle past, or some rare behaviour as they stoop and attack a Buzzard or maybe a distant view of one perched high on a church is all I’ve seen. I’ve never been lucky enough to see one close and I’ve never approached a nest site. You wouldn’t, would you? Peregrine Falcons were almost all killed in the UK by farmers spraying toxic DDT on their crops, to increase their profits at the expense of wildlife. They are only just recovering. That recovery has depended upon an army of passionate volunteers recording each nest, protecting it from harm, monitoring its productivity and informing on illegal persecution.

Peregrine - The Hall of Einar
Illustration by Raymond Sheppard

Natural England’s principal apologist for legalised wildlife crime is Dave Slater, although they refer to him as their Director for Wildlife Licensing. I thought his publicly-funded justification was so poor I decided to analyse it. Here is his post in full and my responses:

Yesterday (15 April) we granted licences for three falconers to permit the taking of a small number (six in total) of peregrine falcon chicks from the wild for use in falconry. Each falconer intends to take one male and one female chick to form a breeding programme with the other licensees.

Immediately, Dave is on the defensive. I understand the number six. Most adults and even most children do. We don’t need to be told it’s a ‘small number’. I know how big six is. Don’t patronise us. You’re trying to manipulate your audience and diminish the impact that this will have. Perhaps you should stick to the facts rather than trying to persuade us? We pay you, after all.

Surely you can’t have a viable long-term breeding population with six peregrines. There isn’t enough genetic diversity in six individuals. How will it be sustained? Surely inbreeding will be rife? Where is the evidence that it’s possible to have a self-sustaining population of captive-bred Peregrines without ever needing to add new genetic diversity to the population. How will the studbook they intend to set up deal with future generations being far closer than cousins? I suppose it will cope if they sell all of the captive-bred falcons. Then, will they be responsible for keeping track of the breeding of British falcons after they have been exported to the Middle East? What’s the point of a studbook where the animals disappear from it when they are out of the country?

Is the licence transferrable? What if one or more of the six die? Can they take replacements? Will their requests to take more because of their losses be accepted? Under what conditions? How likely is it that all six will survive?

Surely they’ll have to rob more nests and capture more wild Peregrines in the future, won’t they?

We understand that some people may have questions and concerns over the taking of birds from the wild and so I wanted to outline more about our decision.

Saying ‘We understand’ is classic bureaucratic English. He could almost have written ‘We are cognisant of the fact that’. You can tell he knows he’s in for a storm of controversy.

Dave says he wants to ‘outline’ more about the decision. What follows is not a description of the licensing process, but a defence of the people doing the nest-robbing:

We issue wildlife licences for a range of purposes, and falconry and aviculture are listed as purposes for which licences can be granted under the legislation. This includes the potential to take a small number of birds from the wild for these pursuits – but only if strict welfare and conservation conditions are met. The taking of birds from the wild for these purposes is also practised in a number of other European countries.

Okay, to summarise:

  • Taking birds from nests for falconry is legal;
  • Including taking them from the wild;
  • Other European countries do it.

I’m happy for Dave to say they are licensing a legal activity, but saying other countries do it? That’s not his job to tell us. If he’s the bureaucrat responsible for licensing in England, he only needs to tell us it’s lawful and he’s chosen to license it. He’s meant to represent our Government and through them, the people, not be defending people in the captive falcon business by explaining that other countries do it. What’s that got to do with his job?

And just because it’s legal doesn’t mean that they have to issue a license. They can just say ‘No’. That’s why they’re there.

Our expert staff have taken care to ensure the strict legal tests have been met, and that there will be no negative conservation impacts to the population. To ensure this is the case, the licence holders need to meet a number of conditions before they can take any chicks from the wild. We have also put in place strict conditions to safeguard the welfare of any chicks taken, and we will be closely monitoring the operation throughout.

Oh your staff are ‘experts’ are they? And the legal tests are ‘strict’? And there are ‘a number of conditions’. Have you noticed how everything Dave says is qualified to persuade us?

“There will be no negative conservation impacts
to the population.”

Except that there will, if the licence holders don’t meet ‘a number’ of conditions, then it will have negative conservation impacts on the population. So, ‘It will be detrimental to the population of Peregrines unless it’s done properly’ would be another way of putting it.

Peregrine falcons have a conservation status of green which means they are widespread and their numbers are not under threat. In fact, the species’ current range and numbers are greater than at any time since detailed recording began in the 1930s. The peregrine population has particularly increased over the last 50 years – there were just 47 breeding pairs in England by the 1970s but by 2014 this number had increased to 826 breeding pairs.


  • They’re not threatened;
  • There are more of them than since the 1930s;
  • There are more than when the Government legalised a farming poison which nearly made them extinct.

So what? 826 breeding pairs is nothing. We live in wildlife poverty and have no understanding at all of the abundance of wildlife which ought to surround us. Dave should be defending his decision on the basis of the law and not defending the applicants or trying to persuade us that the licensees are right. I just want to know whether his decision is right, not whether the licensees are right.

I admired this tweet from Andy Hirst:

Peregrine Falcons - Screenshot 2020-04-18 at 11.04.24

Part of the licence assessment process is to consider the expertise of the applicants and those involved in any field work. The applicants have also had to demonstrate that they will appropriately consider, and provide for, the welfare of any chicks taken.

The ‘expertise’? In what? Nest robbing? The welfare of a chick would be best served by being kept with its parents, wouldn’t it? And tell me all about how being hooded, tethered and brutalised by constant threat and then exported to the Middle East for profit is providing for the welfare of the chick.

We are only permitting a chick to be taken from a nest where three or more chicks are present. We know from detailed studies that peregrines typically lay 3-4 eggs and that only two of these are likely to survive to adulthood. We have specified that the smallest (weakest) chick must be taken from the nest and so are only permitting the taking of a chick which would ordinarily not survive in the wild.

Here we are again with the persuasive language, which I think is inappropriate. ‘Only’. Give me a break. ‘Detailed’. Save me.

Smallest and weakest? How do you know this to be true? What data is being used?

If Peregrines lay 3-4 eggs and only two are likely to survive, why aren’t we taking one or two eggs or chicks from every nest, hand rearing them and releasing them into the wild to restore their collapsed population? Oh yes, that would be because there’s no money to be made from it.

I live near the Exeter Peregrines. Here’s what the scientific paper on their behaviour says about their breeding success: “Whilst there have been changes of both adult falcons at this site, breeding has occurred every year, fledging 57 young between 1997 and 2017 (mean 2.7 chicks per year).”

Saying ‘only two of these are likely to survive to adulthood’ is very likely to be misleading. Surely breeding success will increase with age and experience? And be different across the country? Especially in areas with widespread persecution of raptors for the profit of landowners running driven grouse shooting. Surely the average breeding success will increase with age and by reducing persecution? The Exeter ones produce nearer to three successfully fledged birds. Is it exactly ‘only two’ or two point something? Where can I find the statistics?

Is the reason that the average is ‘only two’ because of illegal persecution. In which case, the argument fails. I’d love to see up to date statistics on laid – hatched – fledged – survived first winter, together with reasons, like ‘having a parent shot dead on a grouse moor’ or ‘eggs stolen by collectors’ or ‘chicks removed by suspected falconers’.

We will be closely monitoring the operation including through asking the applicants for evidence to ensure compliance, whilst staying within the government guidelines around Covid-19.

How much will we, the taxpayer be paying to monitor ‘the operation’? What evidence? And I’d suggest that this isn’t essential work, nor permitted exercise, so how, exactly can they rob nests whilst staying within the Government guidelines around Covid-19?

We have limited the licence period to two years and retain the power to suspend or revoke any licence if necessary.

And is that six chicks a year? Can’t you even be clear about that? You’re so busy trying to persuade me it’s a small number, you’ve forgotten to be clear. Six chicks over two years or six chicks a year for two years?

Falconry is an ancient tradition which has been practised in England for centuries and is recognised as an ‘intangible cultural heritage of humanity’ by UNESCO. The applicants wish to breed verifiably British peregrines for use in their falconry activities, and the European Commission’s (EC) Wild Birds Directive includes reference to the sustainable use of species to fulfil cultural requirements, providing this does not affect their conservation status.

Appealing to culture is perhaps the most disappointing part of this briefing from Dave. Everything we do is culture. That has nothing to do with whether it is ethical or legal. Plenty of things have been practised in England for centuries. Slavery, capital punishment and subjugation of women have been important parts of our culture and, in some cases, still are.

Falconry is medieval brutality and has no place in a modern, civilised society. How similar is modern falconry to the image of chivalrous knights hunting? It’s a far cry from modern industrial raptor farming for export to the Middle East. A bird can fetch £6,000 and be used as part of falcon racing. Having pure-bred native Peregrines means they’ll fetch the highest prices. There’s an insatiable demand and surely they intend to supply it for a profit, to the detriment of the UK’s Peregrine population? Here’s the Daily Telegraph, How falcon-racing became the new sport of kings:

Park that Range Rover, forget the country pile and lead your racehorse back to the stable – there’s only one status symbol worth owning this year, and it’s a bird of prey. But not just any bird of prey: it has to be a falcon, and a particular species at that.
News last week from the RSPB that Britain’s falcon population was being threatened by poachers won’t be a surprise to those who know how lucrative the falcon market has become. Six years ago the birds, which reach up to 200mph chasing prey and are mainly used for hunting in the UK, came with price-tags of around £800. Now, you’ll be lucky to find a peregrine for £4,000, experts say, and in the Middle East they swap hands for up to £250,000….

Is it really Dave’s job to give us excuses on behalf of applicants? UNESCO regularly make ridiculous decisions, such as recognising the destroyed landscape of the Lake District as a World Heritage Site, with its sheep-wrecked hillsides devoid of life. I wouldn’t mind if Dave said “the applicants successfully argued that…” to explain the decision, but to present it as if Natural England is an enthusiastic supporter of, and defender of, outdated and cruel practices is unforgivable.

I’m much happier with the performance of Gary Wall, one of the three falconers who successfully applied for the licence. He had the good grace to write a guest blog for Mark Avery detailing his reasons. I disagree profoundly with him based upon what we value and yet I respect his honesty. I also admire him for engaging with the rest of the wildlife community with such openness and being willing to answer questions and reply to comments. Here’s his view from one of his well argued comment replies:

“…there is degradation of natural instinct in captive population so the further you get away from wild populations the less influence natural selection has making it important that keep that connection close.”

Peregrines become domesticated from selective breeding and lose their hunting instincts. They become docile and lose their hunting and financial value. They need a constant supply of wild falcons.

I have no problem with Gary Wall applying for a license. I disagree with Natural England’s decision to approve it because of a fundamental difference in our values; the things we hold most dear. And what has incensed me most is the feeble justification given by Natural England.

Following comprehensive discussions, we concluded that birds already held in captivity cannot provide verifiably British birds. This is because it is incredibly difficult to definitively establish the provenance of birds held in captivity due to poor documentation.

Discussions? (and we have the word ‘comprehensive’ to qualify it again) How about just doing genetic testing? You don’t need documentation. The birds are carrying their own genetic documentation inside every cell. Get the falconers to pay for comprehensive genetic testing of all their birds and get them to pay for comparisons to the wild population. If the science isn’t there yet, get them to develop it.

‘Difficult’, you say? But not impossible. I assume that just means expensive.

So what if captive falcons are not verifiably British Peregrines? What business is that of Natural England? Domestic dogs aren’t verifiably British wolves either? Why should that concern them?

If poor documentation is a problem, then shouldn’t there be a licence to keep a falcon and shouldn’t that pay for the documentation needed, with legal penalties?

If you own a Bird of Prey, you need to register it if it’s listed under Section 7, Schedule 4 of the Wildlife and Countryside Act 1981. That includes Peregrines. That’s to stop poaching. Except Peregrines and falcons don’t need to be registered if you hold an Article 10 certificate for the bird, and it’s ringed or microchipped. How, then have we got to the situation where there are hybrid birds in captivity and no knowledge of their origins?

One possible future is that wild Peregrines will eventually go the way of Rock Doves in their demise into the equivalent of Feral Pigeons. There’ll be different colours, sizes, and shapes of domesticated, feral half-breed Peregrines. We urgently need to outlaw all non-native birds and hybrids and stop their breeding and release. The logic of “Let’s capture wild Peregrines to reduce the number of non-natives and hybrids lost to help conservation” is perverse. Why not just reduce the number of non-natives and hybrids lost in the first place? Then we can leave wild Peregrine chicks where they are.

Wild peregrine falcons which have arrived in captivity due to injury are also not likely to be suitable as breeding from a bird from the wild is much more difficult than one reared by humans – they are simply not used to humans and are not as likely to breed successfully as a chick taken from the wild and reared by a human.

‘Much more difficult’ is it? How much more? Where’s your factual evidence? Do you mean more expensive? So the Natural England licensing decision was made to reduce the costs to a wildlife cruelty business? Why is the cost to a falconry business of interest to Natural England? Why do Natural England exist?:

“We’re the government’s adviser for the natural environment in England, helping to protect England’s nature and landscapes for people to enjoy and for the services they provide.”

The services England’s nature and landscapes provide? Services? As if wildlife is there to do our bidding and its only purpose is to provide us with services. This is fundamentally about values and Natural England’s values stink. There’s no evidence of a view that nature should exist outside our needs from it. Nature is there to be exploited for profit by rich landowners and nature abusers, and Natural England is there to facilitate it. It’s a childish hangover from religious days where people believed that nature had been created for them to exploit.

The above alternatives have been carefully considered by Natural England when reaching a decision. This has included the need to consider the alternatives and evidence in a manner proportionate to the likely conservation impacts which could occur from the licensable activity. In concluding our decision we have noted that there are likely to be some minor conservation benefits to the peregrine falcon population as a result of these licences; for instance in reducing the likelihood of non-native and hybrid birds escaping into the wild during falconry.

‘Carefully’ considered. ‘Minor conservation benefits’? There should be no non-native or hybrid birds in the country, never mind escaping to breed with our wild population. What is the legal penalty for allowing a captive non-native bird or a hybrid to escape and interfere with out native population? It should be an offence under the Wildlife and Countryside Act 1981:

Penalties that can be imposed for criminal offences in respect of a single bird, nest or egg contrary to the Wildlife and Countryside Act 1981 is an unlimited fine, up to six months imprisonment or both.

It isn’t.

Increasing the number of falcons kept and increasing the popularity of falconry will result in more bird escapes. Do we keep statistics of the number of escapes? How will they verify their assertion? Who will be held responsible for it if it proves to be wrong?

It’s the lies I can’t stand. Trying to make out that robbing Peregrine Falcon nests would be good for them is as pathetic as saying robbing the nests of Hen Harrier chicks in Natural England’s ‘brood-meddling’ scandal is protecting them.

These licences are intended to provide birds for a specific breeding programme and the issuing of a licence does not mean that Natural England will issue licences for further taking of wild birds in future.

It also doesn’t mean that Natural England won’t issue licenses either, does it? Where is the evidence that six birds will create a viable breeding population and never need further birds to add to the gene pool. If it’s not a sustainable population, then that statement is a lie, isn’t it Dave?

It’s a very emotional area to those who have given considerable time to Peregrine conservation:

And it’s not just conservation in the UK we have to be concerned about. What will British Peregrines be used for in the Middle East?

This is a UK Government which has licensed the sale of £15 billion of arms to Saudi Arabia over the time of its assault on Yemen, with over 12,600 people killed, including by indiscriminate bombing.

This will provide UK native peregrine falcons to falconers and potentially limit the amount of peregrines taken from the wild in the future, and it will also have the added benefit of creating a captive population on known provenance which we have never had before and would give us options in the future

Ah, here we have it. “Potentially limit the amount of peregrines taken from the wild in the future.”

Potentially? Being able to buy a pure-bred British Peregrine for £6,000 or more will reduce the number of people taking Peregrine chicks from nests illegally and for free will it? Where is your evidence? People can already buy a Peregrine and that hasn’t stopped the crime.

It’s as if the Police are licensing burglars to steal from easy targets with guaranteed hauls to reduce the number of break-ins and improve the crime statistics.

In summary, while we do understand that many will find taking these magnificent birds from the wild uncomfortable – our rigorous approach has ensured that this will have no impact on populations, will be done humanely and will support legitimate and responsible falconry practices.

Uncomfortable? It’s outrageous. ‘Our rigorous approach’?

It’s doublespeak. George Orwell, author of 1984, described political speech as similar to the contemporary definition of doublespeak:

In our time, political speech and writing are largely the defence of the indefensible … Thus political language has to consist largely of euphemism, question-begging and sheer cloudy vagueness … the great enemy of clear language is insincerity. Where there is a gap between one’s real and one’s declared aims, one turns as it were instinctively to long words and exhausted idioms,…

Dave Slater is employed to license the killing and taking of wildlife. It’s a deeply political job. As the licensing authority’s representative he should be explaining Natural England’s process to the public, not attempting to justify, defend or even promote the licensee.


What do you think?

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