On 22 March this year, the Wildfowl & Wetlands Trust (WWT) Council met in London. One of the items on the agenda was an ?Update on the lead gunshot position and advocacy plan approved by the Council in December 2011?. This ?update? runs to nine pages of detail on the aims, objectives and actions of a campaign to ?ban the use of lead gunshot [sic] for all shooting in the UK?. It is a frustrating and alarming document, but the overwhelming feeling it leaves is one of sadness ? sadness that an organisation that was founded by a wildfowler, is supported by so many in the shooting community, and which shares exactly our aim of conserving duck, geese, waders and the habitats they rely on, should engage in what is (despite the many protestations) a blatant attack on shooting.
The WWT?s cynical misrepresentation of the position the shooting community takes on lead; the extraordinarily patronising way in which wildfowlers and gameshooters are described; and the attempt to create a health scare, which would have a devastating effect on hundreds of businesses and jobs, betray the campaign as more than just a reasonable response to concern over lead shot.
Let us be clear what the position of the shooting community is on lead shot. Far from being ?innately conservative?, as the WWT?s paper suggests, we are absolutely willing to consider relevant evidence of environmental and human health concerns linked to lead shot. Likewise, if such evidence is forthcoming, we will support any practical proposals to ameliorate such concerns. The shooting community, through BASC, the Countryside Alliance (CA) and the CLA, sits with the WWT and other interested organisations on the Lead Ammunition Group (LAG), which was set up in 2010 to advise DEFRA and the Food Standards Agency. LAG is in the process of considering what evidence is relevant, and if there are real concerns ? either in relation to the environment or human health ? it will advise the Government on any steps that could be taken to meet them.
What the WWT Council papers reveal, however, is that while this careful process is taking place (analysing what evidence is relevant, what the real risks are, and, if they do exist, how best to address them), the WWT plans to engage in a sensationalist campaign on the issue. The aim ? banning lead shot for all shooting ? preempts any findings the LAG might make. In effect, the WWT is saying it is not interested in the careful consideration of evidence being carried out by LAG. It has made up its mind, found lead guilty of multiple crimes and decided on the sentence. Whatever the science might say, the WWT, apparently, knows best.
Despite the breathless tone adopted in the WWT papers, the LAG process and the evidence it is considering could not be more open. There is no secrecy, and no conspiracy. If you have the time and the patience, you can read the submissions, papers and reviews from the WWT and others on the LAG website, visit www.leadammunitiongroup.co.uk.
The WWT is not only usurping the LAG process and making premature judgements, but the papers unfortunately reveal that it is making those judgments from a position of ignorance. The WWT?s consistent use of the word ?hunting? to describe what anyone engaged in the pursuit of birds with shotguns in the UK would call ?shooting? can be passed off as a linguistic quirk, but ignorance of the law as it currently applies to the use of lead shot cannot be passed over in this context.
The paper states that: ?It has been illegal to use lead gunshot [sic] over wetlands in England since 1999,? which is, of course, incorrect. Legislation in England (and Wales) bans the use of lead to shoot duck and geese. It also bans its use on the foreshore and on some SSSIs. Scotland has a more logical restriction on the use of lead over wetlands regardless of species. The paper also claims that ?there has been very little compliance? with current restrictions on lead shot in England, which will come as a surprise to fowlers from Cornwall to Cumbria. True, studies of duck bought from gamedealers have shown a level of non-compliance, but to suggest that such a narrow study shows there is ?very little compliance? betrays a basic ignorance of the subject.
The sale of duck is, of course, anathema to fowlers, and the idea that compliance among wildfowling club members is not at, or very close to, 100 per cent is plainly unsupportable. It is simply not possible to suggest non-compliance by the vast majority of wildfowlers and duck shooters who consume their own bag, on the evidence of a few mallard bought from gamedealers.
And then there is what the WWT paper calls the ?circulation of persistent myths regarding the suitability of alternatives? to lead shot. Is it suggesting that it is a myth that steel shot is less dense than lead shot? That it is a myth that Bismuth and other similarly performing non-toxic shot is at least 10 times more expensive than lead? That it is a myth that the majority of guns currently in use for gameshooting in the UK are not suitable for use with steel cartridges? I am afraid these ?myths? are more examples of the unfortunate mixture of ignorance and prejudice which pervades the paper.
The question remains as to why the WWT is considering such a virulent campaign against lead shot. The story starts in 2009, when the WWT and RSPB jointly wrote to the then Secretary of State for Environment, Food and Rural Affairs, Hilary Benn, claiming that there was new evidence about the risk to the health of humans and wildlife in the UK caused by the use of lead ammunition for the hunting of wild game. The letter concluded with a recommendation that a wider group of interested stakeholders be convened by the Government to address the evidence for lead poisoning of both wildlife and humans, with a mandate to make whatever recommendations it sees as necessary for the protection of the environment and human health.
The Secretary of State, who we can assume was not surprised by the letter, took that advice and set up the aforementioned Lead Ammunition Group. That group has been assiduously going about its business, so why would one of the organisations that called for its creation now pre-empt its recommendations? Logically, the WWT campaign can only be an admission of the weakness of its case. If the WWT was confident that there was relevant evidence of harm to environmental and human health, which must lead the LAG to advise a ban on lead shot, then its ?advocacy plan? would be redundant. The only reason to depart from the process that the WWT itself initiated is to create public and political concern on the basis of evidence not considered relevant or persuasive by the LAG. The WWT asked to play the game, but now that it is not going its way it wants to take its ball home.
So where will all this lead to? If the WWT does manage to engage celebrities and the media with its heartfelt concerns about the health of people who eat game, it may encourage the Government to give the issue further scrutiny and cause some in our community to calculate that the threat to the sale of game outweighs the considerable problems of a prohibition on lead. The WWT also knows that a successful publicity campaign would probably have an impact on the LAG?s eventual advice for those and other reasons. Speaking for the CA, we will maintain our position that further restrictions on lead shot will only be acceptable if they address proven concerns in a practical way. We will respond robustly to the WWT?s campaign not by ?aggressively attacking the WWT?s activities? as it suggests, but by pointing out that it is unfounded and subverts a proper scientific process.
The WWT?s paper outlines the ?risks? it might create for the charity. It lists the risk of ?attack by the hunting community?, but is unconcerned, as ?few of our members are hunters, and most negative press is likely to be in shooting magazines?. It is more concerned, bizarrely, at being exposed for ?limited lethal control of feral wildfowl at our centres?. The paper is particularly, and tellingly, defensive about potential criticism for going beyond the WWT?s remit and getting involved in issues of human health. It is difficult for the WWT to maintain the position that it has simply ?become aware of risks to human health while studying lead poisoning in wildfowl? when it has been involved in a study on potential hazards to human health from exposure to fragments of lead shot in game animals.
Strangely, however, the real risk to the WWT is hidden away in a footnote to the ?success criteria?. It will be a ?success?, apparently, if the ?backlash from our activities does not materially affect the Trust in a negative way?. This should have been the first, not the last, thing the WWT Council considered. It is one thing for noisy animal rights organisations to launch emotive campaigns, but another thing altogether for an organisation with the standing of the WWT to indulge in such dubious behaviour. Credibility is hard earned, but easily lost. I hope the WWT Council has thought long and hard, and been properly advised, before embarking on such a dangerous path.
Tim Bonner is director of campaigns at the Countryside Alliance.