Countryside Alliance Ireland - love the countryside

A response by Countryside Alliance Ireland

Introduction

Countryside Alliance Ireland (CAI) is an expert and informed rural campaigning organisation. We have 15,000 members throughout Ireland and reflect the views of a further 50,000 people, through a series of formal agreements with a number of other countryside organisations. (CAI) promotes the sustainable use of our countryside, and we believe that the sustainable and productive use of land is the defining characteristic of our countryside.

Countryside Alliance Ireland and our members take our conservation commitments very seriously. Collectively we have a vested interest in the well being of our endemic hare population and have been working closely with a broad range of statutory and voluntary organisations to deliver meaningful conservation action for many years, principally through our membership of the Irish Hare Group.

We embrace the principles of partnership and local community involvement as enshrined in the Rio Convention (Earth Summit) and in the UK and Northern Ireland Biodiversity Strategies.

Countryside Alliance Ireland pursues it objectives through it's full-time professional staff based at it's Ireland headquarters, at Larchfield Estate, Lisburn, and in partnership with a broad range of rural organisations.

Background

In Northern Ireland there are 3 beagle packs, 17 packs of foot harriers, 10 mounted harrier packs and two coursing clubs all of whom have an interest in hare hunting. There are also a number of individuals who may hunt hares, without belonging to an organised club. A significant number of shooters in Northern Ireland (of which there are 80,000) also have an interest in hare conservation, and although the shooting of hares rarely takes place, the future opportunity to do so is an important conservation incentive.

Irish Hare Group

Countryside Alliance Ireland is an important and enthusiastic member of the Irish Hare Group, set up by a former Environment Minister to oversee the delivery of conservation action as envisaged under the Irish Hare Species Action Plan. To date the group has focussed on gathering the appropriate information before attempting to direct conservation effort, and officials from the DoE's Environment and Heritage Service, who are members of the group, have supported this approach. As a member of the Irish Hare Group we are deeply disappointed that Parliamentary Under-Secretary of State for Northern Ireland, Angela Smith has not only acted prematurely by publishing plans to introduce a Special Protection Order for Irish Hares, but also has not formally consulted the very group set up to advise the Minister, because of their collective expertise.

Consultation

Although an announcement of the Minister's intention to introduce the Special Protection Order was placed in the Belfast Gazette on 31st October, it did not appear in the national printed media until Monday 3rd November. With objections to the proposal expected no later than 28th November this effectively allowed little over three weeks for response.

Consultation guidelines, drafted by the Northern Ireland Executive state that "sufficient time should be allowed for considered responses from all groups with an interest. Twelve weeks should be the standard period for a consultation with eight weeks being the minimum.

Furthermore, in the ‘Proposals for Additional designations under The Freshwater Fish Directive', also published by Environmental Policy Division it states "It is government policy that all government Departments and Agencies intending to exercise statutory powers and make rules with a general effect on others should produce a Regulatory Impact Assessment." In the same document also states "It is Government policy that all government Departments and Agencies intending to introduce a new policy should subject that policy to Rural Proofing."

It is clear that the Minister intends to exercise statutory powers, make rules and introduce a new policy so therefore she must produce a Regulatory Impact Assessment and subject her proposals to Rural Proofing. We in Countryside Alliance Ireland, and the members we represent are deeply disappointed by the fact that no consultation documentation whatsoever has been published in relation to these proposals as this is not only undemocratic but also inhibits quality contribution. We are also deeply concerned that the Minister has so far flouted her Department's stated policy and appears to have little regard for consultation or indeed the entire democratic process. It is widely known that the Minister is a former employee of the English extreme animal rights group, League Against Cruel Sports and there is widespread concern that this disregard for consultation and proper, inclusive dialogue is fuelled by the Minister's personal views.

Political opinion

Three of the leaders of our main political parties have also expressed strong concerns at the absence of proper and inclusive consultation and the apparent disregard for current government policy in relation to the introduction of new rules or the exercising of statutory powers. I know that many candidates for election to the Northern Ireland Assembly, from all four main political parties have also expressed similar concerns.

The timing of the Minister's announcement has also been greeted with amazement. The period provided for objections to the proposal coincided with the election period, when the Northern Ireland Civil Service traditionally observes a period of ‘purda', or relative political activity. Politically there is almost a unanimous view that the entire issue of Irish Hare conservation and the status of Irish Hares on the Wildlife (Northern Ireland) Order 1985, is best deal with by a devolved institution, who can deal with it in a more holistic and impartial way.

Scientific evidence

There is neither scientific evidence nor any leading scientific figure that supports the proposal to introduce a Special Protection Order for Irish Hares.

The Minister has referred to the Irish Hare Survey 2002, erroneously on a number of occasions recently. The reality is that there are no reliable population estimates for Irish Hares and there is no evidence that they are currently declining. In the Executive Summary of the 2002 Irish Hare Survey it states "The only comprehensive survey of the population of the Irish Hare throughout Northern Ireland was carried out in the mid-1990s by Dingerkus (Queens University Belfast)".

This survey used a method known as Day Walked Squares (DWS), the accuracy of which has been subject to much criticism and indeed the 2002 report also recognises that "Observations in the field suggest that Hare surveys may significantly underestimate overall numbers". Additionally in the repeat survey of 2002, where the DWS method was used it took place at a different time of year and at a time when vegetation height differed greatly from the 1997 survey making any accurate scientific assessment of hare population dynamics impossible.

In its conclusions the 2002 report notes "There is no solid evidence to suggest that hare numbers have declined since the mid 1990s. Therefore the population appears stable..."

The Minister has also made much of what she perceives as Professor Ian Montgomery's call for Irish Hares to be removed from the quarry list. In the 2002 report Professor Montgomery merely reiterates the recommendations made by Dingerkus in 1997, notes that none of them have been implemented and suggests that these recommendations should be considered.

I know that Professor Montgomery has written directly to the Minister and clearly pointed out that he does not support the addition of Irish Hares to Schedule 5 of Wildlife (Northern Ireland) Order 1985, nor does he support the introduction of the Game Preservation (Special Protection For Irish Hares) Order (NI) 2003. His opinion is apparently based on the fact that he believes that the various forms of hare hunting make a positive contribution to their conservation, through participation in important research, predator control and sympathetic habitat management.

Furthermore I believe that Professor Montgomery has also drawn the Minister's attention to the fact that the introduction of the Special Protection Order will also make some current research impossible.

Dr. Declan O Mahony, who is also a leading expert on Irish Hare ecology, and who provided over 80% of the Irish Hare sightings obtained during the Irish Hare Survey 2002 has also formally objected to the introduction of the Special Protection Order, for similar reasons as Professor Montgomery. Dr. O Mahony has also highlighted the fact that current research is "A redundant and inaccurate basis for management of the species as Northern Ireland is only part of the natural range and distribution of the Irish Hare."

It is clear that there is no creditable evidence to support the imposition of the Special Protection Order and that the established experts on Irish Hare ecology believe it to be a serious impediment to current research techniques.

The way forward

Anecdotal evidence suggests that there has been a decline in Irish Hare numbers in Northern Ireland from the beginning to the latter part of the last century. This decline has been attributed to environmental changes, notably loss of plant species richness, associated with intensification of agriculture (Dingerkus & Montgomery 1997). There appears to be unanimous agreement amongst all the relevant statutory, scientific and voluntary bodies that environmental change associated with more intensive methods of agricultural production are the major cause of this apparent decline.

Of the 8 recommendations made by Dingerkus in 1997, 7 of them (over 90%) related to agricultural practice, these included;

1.The production of a more species rich grass sward to allow Hares a more varied diet and promote survival of leverets.

2.Controls on livestock grazing levels to prevent disturbance to ‘nesting' Hares.

3.Controls on the timing of silage cutting to prevent leveret and adult Hare deaths during the breeding season.

4.Changes in the method of silage cutting - working from the inside out would allow ‘nesting' Hares and leverets to escape.

5.The provision of Hare refuge sites or buffer areas within farmland that allow rough vegetation to flourish.

6.Hare friendly agricultural practice in ESAs and CMS schemes.

7.Increased awareness of the plight of the Irish Hare by liaison with farming groups, the rural community and the Department of Agriculture (DARD).

The Irish Hare Survey 2002 re-emphasised these recommendations and concluded by saying that to date "none of them have been implemented."

If we are serious about trying to achieve the targets set out in the Irish Hare Species Action Plan then greater efforts must be made to fully implement these recommendations in the immediate future. It is a waste of valuable time and resources to focus on the status of the Irish Hare on the Wildlife (Northern Ireland) Order 1985, as all available evidence points to the fact that current hunting practices make a positive contribution to the conservation of Hares and any steps to remove it from the quarry list will remove the vested interest that many people have in the well-being of Hares.

If we are to strive to create greater awareness of the plight of the Irish Hare with farming groups and the rural community we will not do it by alienating them or imposing legislation without proper consultation.

Furthermore, Countryside Alliance Ireland believes that predation is also an extremely significant factor in the distribution of Irish Hares. Predation also affects the survival rates of leverets (Dingerkus & Montgomery 2002). There is also evidence to suggest that Foxes play a major role in the population dynamics of the Brown Hare in many environments, for example in the UK the Game Conservancy estimate that a family group of Foxes can consume 33 adult Brown Hares annually.

Conclusion

Countryside Alliance Ireland object in the strongest possible terms to the imposition of the Game Preservation (Special Protection Order For Irish Hares) (NI) Order 2003. Because there is no evidence to support it and no established benefit in its introduction the Special Protection Order is not seen as an attempt to conserve Irish Hares, rather an attempt by the Minister to control the activities of people, where she does not personally approve of them.

There is widespread political and public concern at the undemocratic way that the introduction has been handled. Environmental Policy Division have breached government policy in relation to consultation and we firmly believe that the Minister has ignored a considerable amount of information from a range of informed sources, as it does not concord with her own prejudiced views. We will not accept this type of government, and fully intend to challenge it in every way we can.

Should the Minister proceed with the imposition of this legislation without proper we believe it will seriously undermine the cohesive and collaborative conservation efforts of all those who have a genuine interest in the well being of Irish Hares. We remain committed to the conservation of Irish Hares and are prepared to play a full and enthusiastic part in all initiatives that can be demonstrated to deliver real conservation benefits.

Ronan Gorman Chief Executive, Countryside Alliance Ireland 25th November 2003