BASC finds bias in a third of Defra’s gamebird review questions

Almost a third of the 106 questions in Defra’s call for evidence on gamebird release contain methodological bias, 47 faults across 31 questions, according to an analysis published by the British Association of Shooting and Conservation (BASC) on 14 September. Dr Patrick O’Reilly, the association’s head of social science, says the exercise presents itself as open and balanced while its structure and wording steer respondents towards particular answers, and he is urging the shooting community to submit evidence before the call closes on 1 November.

What does BASC say is wrong with the questionnaire?

Dr O’Reilly’s analysis works through the Call for Evidence on Gamebird Release, Shooting and Welfare during Rearing in England question by question. “Almost a third of its 106 questions (31 in total) contain 47 methodological biases between them,” he writes. “That includes questions that assume an effect rather than test for it, leading phrases, emotive language and uneven levels of detail across topics.”

The sections on welfare and environmental impact are singled out. A high level of detail is sought on the negative effects linked to release, he says, without equal attention to the environmental benefits of shooting, including predator control and habitat management, which he calls “a classic form of questionnaire bias”. In many places, he argues, the questionnaire “simply re-hashes a hit list of anti-shooting talking points in question form”.

He gives examples of steering. “On pathogens, respondents are asked to comment on ‘highly infectious’ avian flu. On rural policing, you are restricted to commenting on raptor killings associated with bird release,” he writes, with no room for the crime-prevention work of people involved in gamebird release. The economic and wellbeing benefits of shooting are excluded altogether, because Defra says it is commissioning separate research on the economy “in the form of a Master’s dissertation project”.

Bias built into the architecture

Beyond individual questions, Dr O’Reilly identifies what he calls architectural biases running across the whole document: binary framing, negative priming and sequencing bias, where one question sets up the answer to the next. Even a question that reads as neutral on its own, he argues, cannot be treated as neutral in practice once the questions before it have shaped the respondent’s frame of mind.

He also points to the description of the exercise. The call states that the current regulatory framework is limited and outdated, then says evidence is needed to assess it. “In other words, the conclusion comes before the evidence meant to substantiate it,” he writes. Respondents are told the evidence will be thoroughly examined, but not how, nor how it will feed into policy.

“Good policymaking depends on all the affected stakeholders trusting that decisions are based on credible data, gathered and analysed fairly,” he concludes. “On the basis of Defra’s document, it is hard to say that the test has been met.” The call, he says, has loaded the dice “so blatantly” that support for BASC’s push for high-quality evidence “has never been more important”.

How did the call for evidence come about?

Defra opened the two-month call on 3 September, presenting it as a way to improve the evidence base on the positive and negative impacts of gamebird release, shooting and rearing in England. BASC described it the same day as a “fight for the future of shooting”. It followed the High Court’s July ruling in BASC’s favour over Natural England’s approach to licensing gamebird release near protected sites, a judgment that took full effect on 3 September when Natural England was refused permission to appeal.

The Moorland Association has already told Defra to keep grouse out of any licensing scheme, and the Game & Wildlife Conservation Trust has said it looks forward to engaging with the department over the coming weeks. BASC’s own position is that the questionnaire’s flaws make it more important, not less, that shoots, keepers and game farmers answer it with their own evidence.

What happens next

The call for evidence closes on 1 November 2026. Defra has said it will examine the evidence submitted before deciding whether and how to change the regulation of gamebird release, shooting and rearing in England. BASC has published guidance on how to submit evidence and is asking every shoot, keeper and game farmer to respond with specific, first-hand information on the conservation, welfare and community work they do. Dr O’Reilly’s full analysis can be read on the BASC website.