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Maladministration ruling on EU lead restriction consultation


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Any doubters about the BSAC agenda should have noticed two things in the latest edition of their advertising rag -

1 - the lead article was by written by none other than the prominent fieldsport non-enthusiast - by name Tony Juniper, a lead member of Wild Justice

2 - a life award to ....yuk, pass the sick bag .... that well known fielsport antagonist - J Swift

 

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6 minutes ago, harkom said:

Any doubters about the BSAC agenda should have noticed two things in the latest edition of their advertising rag -

1 - the lead article was by written by none other than the prominent fieldsport non-enthusiast - by name Tony Juniper, a lead member of Wild Justice

2 - a life award to ....yuk, pass the sick bag .... that well known fielsport antagonist - J Swift

 

Interesting. Strange bedfellows indeed. 

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1 hour ago, harkom said:

Any doubters about the BSAC agenda should have noticed two things in the latest edition of their advertising rag -

1 - the lead article was by written by none other than the prominent fieldsport non-enthusiast - by name Tony Juniper, a lead member of Wild Justice

2 - a life award to ....yuk, pass the sick bag .... that well known fielsport antagonist - J Swift

 

Tony Juniper isn't a member of Wild Justice and to my knowledge never has been - he's the head of Natural England. Despite the fact that he isn't someone who can be described by any means as a field sports enthusiast - the fact that BASC have got him writing in their magazine at all is proof of their political bridge building.

Would you rather BASC boycott the man in charge of the department largely responsible for issuing the general licences?

Edited by PeterHenry
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Natural England are a very very poorly run department, ill informed waste of oxygen. The regulations they’ve instigated have done more harm than good to the countryside. This is were all this is heading one big government department for environment, farming and climate policies and the BASC etc. employees are putting there CV on the table for a ride on the gravy train 

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15 hours ago, clangerman said:

only have to Google him to answer that clearly a raving anti linked to wj 

But not a member of Wild Justice though. And regardless of his views, is the man in charge of the department that put the effort into the current general licences - you know, the ones that haven't been successfully challenged. 

I understand that Natural England is also the body responsible for the badger cull. Strange that hasn't been knocked on the head, seeing that he was appointed in 2019....

Frankly, I have given up trying to understand you. There are other people on here who I disagree with, but they all at least show some form of reason or aptitude for self reflection. You, on the other hand are a crank.

Not everything is a conspiracy against you.

Edited by PeterHenry
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1 hour ago, 8 shot said:

Natural England are a very very poorly run department, ill informed waste of oxygen. The regulations they’ve instigated have done more harm than good to the countryside. This is were all this is heading one big government department for environment, farming and climate policies and the BASC etc. employees are putting there CV on the table for a ride on the gravy train 

I won't dispute the first part - but they are an important department from the perspective of the pigeon shooter - and one we have to deal with. 

I won't comment on the second half - but I don't see how basc could ever merge with it, unless I have missed your point?

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11 hours ago, PeterHenry said:

Tony Juniper isn't a member of Wild Justice and to my knowledge never has been - he's the head of Natural England. Despite the fact that he isn't someone who can be described by any means as a field sports enthusiast - the fact that BASC have got him writing in their magazine at all is proof of their political bridge building.

Would you rather BASC boycott the man in charge of the department largely responsible for issuing the general licences?

He may not be a member of Wild Justice - but is so closely aligned he may as well be. He was also single handedly responsible for cancelling the General Licences when Wild Injustice challenged them. A more anti-shooting bunny hugger you could not find….!!

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40 minutes ago, Fellside said:

He may not be a member of Wild Justice - but is so closely aligned he may as well be. He was also single handedly responsible for cancelling the General Licences when Wild Injustice challenged them. A more anti-shooting bunny hugger you could not find….!!

I know he has links to the Green Party as well - and - if I was the person charged with picking someone to head up Natural England, it would not have been him.

What you say about the dropping of general licences may be true - but I won't presume to infer the reasoning. Although I am not disputing that they were dropped awfully quickly. That aside, the old general licences look to have been a weak spot just waiting for someone to exploit - more of a political smudge bought in to appese the (predecessor of the) EU and people who shot. Like any smudge, no one cared until it was noticed by someone who wanted to tidy it up. Regardless, the GL's were sorted out, and they now do conform to the law, while for the large part allowing us to continue as before - so I will give him marks for that. The badger cull is still going on - as far as I am aware - so marks to him on that also.

I know when he was appointed in 2019 there were fears that it would be like Chris Packham at the wheel, but those fears - as of 2022 - remain largely unfounded as far as I can tell.

Edit - I know that this is digressing again, and is not specifically in relation to your point, but I'd just like to point out that BASC can either be incredibly standoffish about things and achieve nothing, or they can build bridges and achive something. BASC are not the American NRA - and despite some pepole wanting them to act like it, won't, because they know it would be entirely futile and counterproductive..

Edited by PeterHenry
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The new general licences are pages longer than the previous ones, with new clauses and additions, and minus the collared dove etc. etc. only because Mr Juniper insisted on these amendments. That is why the new licences caused so much initial confusion. Thankfully as the dust settled we realised they are also full of legal contradictions and ‘get out clauses’ primarily due to direct intervention from DEFRA (often at a ministerial level). Thus we can use them without fear of crossing legal red lines.

If Mr Juniper, a close friend and associate of Mark Avery, had entirely got his way, let me assure you, we would be in a very different boat - a very leaky one. 

It is understandable that for these and other reasons, BASCs recent association with Juniper is surprising. This isn’t BASC bashing by the way, as in many respects the Org’s have had no choice but to ride the green wave or be swamped by it. Many of us acknowledge this. However BASC have some explaining to do re Juniper. 

As for the badger cull, I freely confess to knowing little about it. 

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1 minute ago, Fellside said:

The new general licences are pages longer than the previous ones, with new clauses and additions, and minus the collared dove etc. etc. only because Mr Juniper insisted on these amendments. That is why the new licences caused so much initial confusion. Thankfully as the dust settled we realised they are also full of legal contradictions and ‘get out clauses’ primarily due to direct intervention from DEFRA (often at a ministerial level). Thus we can use them without fear of crossing legal red lines.

If Mr Juniper, a close friend and associate of Mark Avery, had entirely got his way, let me assure you, we would be in a very different boat - a very leaky one. 

It is understandable that for these and other reasons, BASCs recent association with Juniper is surprising. This isn’t BASC bashing by the way, as in many respects the Org’s have had no choice but to ride the green wave or be swamped by it. Many of us acknowledge this. However BASC have some explaining to do re Juniper. 

As for the badger cull, I freely confess to knowing little about it. 

My understanding - and I am, genuinely, happy to be proved wrong on this point - is that the general licences are longer and more complicated as a direct result to them being made watertight. Owing to our continued adherence to the Birds Directive, and the subsequent Wildlife and Countryside Act 1981, to be considered legal the General Licences had to be far more specific in relation to what would be shot and when. Obviously, they also had to be usable in practice - which is why we are where we are, and they are tempered with reasonableness clauses. That's just the way it is with a lot of law.

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1 hour ago, PeterHenry said:

I won't dispute the first part - but they are an important department from the perspective of the pigeon shooter - and one we have to deal with. 

I won't comment on the second half - but I don't see how basc could ever merge with it, unless I have missed your point?

Reference my second point, is the BASC,NGO, CLA, etc. and NFU to an existent etc, will cease to  exist there will be no voice/representation for shooting agriculture etc. It would be swallowed up in one government body.it has already started with shooting with its own version of the Red Tractor scheme. It will also control environment scheme along with conservation projects. All these people employed in the above organisations will be looking employment within.

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15 minutes ago, PeterHenry said:

My understanding - and I am, genuinely, happy to be proved wrong on this point - is that the general licences are longer and more complicated as a direct result to them being made watertight. Owing to our continued adherence to the Birds Directive, and the subsequent Wildlife and Countryside Act 1981, to be considered legal the General Licences had to be far more specific in relation to what would be shot and when. Obviously, they also had to be usable in practice - which is why we are where we are, and they are tempered with reasonableness clauses. That's just the way it is with a lot of law.

The 1981 Wildlife and Countryside Act was there all along and the previous GLs allowed for an exemption, as do the current GLs. What changed primarily, after the WJ attack, was that Juniper was stubbornly obstinate re the need for evidence before shooting. It was pressure from the House of Commons Committee and Gove as the DEFRA minister, which resulted in the GL ‘get out clauses’ and wording which is difficult to legally challenge….watertight as you would say. We don’t have Juniper to thank for this however. It is for these, and other anti shooting stances that Juniper has taken, which make him an odd bedfellow for BASC….very odd. 

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On 25/05/2022 at 10:32, Conor O'Gorman said:

The ruling was made following a complaint by the European Federation for Hunting and Conservation (FACE), supported by BASC, to the ombudsman that the European Food Safety Authority did not supply key evidence on lead concentrations in game meat.

UK modellers Rhys Green and Debbie Pain reported that they “used observations from two studies of Greenland adults (Bjerregaard et al. 2004; Johansen et al. 2006) to derive an empirical relationship between the mean daily intake of dietary lead from the meat of shot birds and mean B-Pb”, omitting to mention that the Greenland scientists found lead concentration in one species (eider) to be 8.3 times as high as in the other species (thick-billed murre).

Anybody who has actually looked at the various papers from the Greenland studies can hardly fail to have noticed that the numbers of samples were small and the variability within each species was also very large, leading to:

  • an eight-fold range in the 95% confidence limits for the 25 carcases of eider;
  • a twelve-fold range in the 95% confidence limits for the 32 carcases of thick-billed murre.

I assume that HSE staff who prepared the Annex 15 Restriction Report might have been unaware of small sample sizes and great variability of data on which the mathematical model was founded, otherwise they might not be presenting it to government as a basis for legislation.

 

Ornithologists issuing predictions about child health have excluded any mention of data published by the UK Health Security Agency’s Lead Exposure in Children Surveillance System (LEICSS) or Public Health England’s Surveillance of Elevated Blood Lead in Children (SLiC).   Why?   Could it be because real data does not agree with the model?

The ornithologists predict that 48,000 children may be at risk solely as a result of eating game meat.   By contrast, health professionals have recorded on average fewer than 40 cases per year in which UK children suffered elevated blood lead concentration from any source.   The most common cause was ingestion by very young children of non-dietary objects, and no cases at all were identified as resulting from food intake.  

Publications cited by HSE indicate that high-level consumers of game meat tend to be people with higher income and higher position in society, whereas health professionals report that cases of elevated blood lead concentration in children were mostly found in areas of considerable deprivation.

The HSE consultation refers to official records in relation to animals under the Veterinary Medicines Directorate National Surveillance Scheme, but excludes any mention of the equivalent records relating to children (LEICSS and SLiC).  

I can only assume that modellers and HSE staff:

  • considered official surveillance information to be irrelevant, OR
  • examined the data recorded by health professionals and decided that it was incorrect, OR
  • were ignorant of the existence of surveillance schemes relating to child health.

 

Presumably the papers published in scientific journals would have been subject to peer-review.   The reviewers might have been insufficiently familiar with the subject matter, and failed to notice the omission of surveillance data;  alternatively, they may have regarded it as perfectly acceptable.  

 

Predictions about effects of lead ammunition on human health have often been written by the same people who assert enormous damage to wildlife and the environment.   If they have withheld or distorted information relating to human health, anything they have written on other topics might be equally unreliable.  

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3 minutes ago, McSpredder said:

UK modellers Rhys Green and Debbie Pain reported that they “used observations from two studies of Greenland adults (Bjerregaard et al. 2004; Johansen et al. 2006) to derive an empirical relationship between the mean daily intake of dietary lead from the meat of shot birds and mean B-Pb”, omitting to mention that the Greenland scientists found lead concentration in one species (eider) to be 8.3 times as high as in the other species (thick-billed murre).

Anybody who has actually looked at the various papers from the Greenland studies can hardly fail to have noticed that the numbers of samples were small and the variability within each species was also very large, leading to:

  • an eight-fold range in the 95% confidence limits for the 25 carcases of eider;
  • a twelve-fold range in the 95% confidence limits for the 32 carcases of thick-billed murre.

I assume that HSE staff who prepared the Annex 15 Restriction Report might have been unaware of small sample sizes and great variability of data on which the mathematical model was founded, otherwise they might not be presenting it to government as a basis for legislation.

 

Ornithologists issuing predictions about child health have excluded any mention of data published by the UK Health Security Agency’s Lead Exposure in Children Surveillance System (LEICSS) or Public Health England’s Surveillance of Elevated Blood Lead in Children (SLiC).   Why?   Could it be because real data does not agree with the model?

The ornithologists predict that 48,000 children may be at risk solely as a result of eating game meat.   By contrast, health professionals have recorded on average fewer than 40 cases per year in which UK children suffered elevated blood lead concentration from any source.   The most common cause was ingestion by very young children of non-dietary objects, and no cases at all were identified as resulting from food intake.  

Publications cited by HSE indicate that high-level consumers of game meat tend to be people with higher income and higher position in society, whereas health professionals report that cases of elevated blood lead concentration in children were mostly found in areas of considerable deprivation.

The HSE consultation refers to official records in relation to animals under the Veterinary Medicines Directorate National Surveillance Scheme, but excludes any mention of the equivalent records relating to children (LEICSS and SLiC).  

I can only assume that modellers and HSE staff:

  • considered official surveillance information to be irrelevant, OR
  • examined the data recorded by health professionals and decided that it was incorrect, OR
  • were ignorant of the existence of surveillance schemes relating to child health.

 

Presumably the papers published in scientific journals would have been subject to peer-review.   The reviewers might have been insufficiently familiar with the subject matter, and failed to notice the omission of surveillance data;  alternatively, they may have regarded it as perfectly acceptable.  

 

Predictions about effects of lead ammunition on human health have often been written by the same people who assert enormous damage to wildlife and the environment.   If they have withheld or distorted information relating to human health, anything they have written on other topics might be equally unreliable.  

Most interesting - thanks.

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52 minutes ago, Fellside said:

The 1981 Wildlife and Countryside Act was there all along and the previous GLs allowed for an exemption, as do the current GLs. What changed primarily, after the WJ attack, was that Juniper was stubbornly obstinate re the need for evidence before shooting. It was pressure from the House of Commons Committee and Gove as the DEFRA minister, which resulted in the GL ‘get out clauses’ and wording which is difficult to legally challenge….watertight as you would say. We don’t have Juniper to thank for this however. It is for these, and other anti shooting stances that Juniper has taken, which make him an odd bedfellow for BASC….very odd. 

In that case I agree - strange bedfellows indeed. I did know about his stance pre appointment to Natural England, but had - possibly mistakenly - presumed that he had taken up his role with a more charitable governing for all approach. But perhaps not....

I still hold that it's better to foster good general terms with someone you disagree with in principle - perhaps even more so in this case. I very much believe in dialogue between parties.

1 hour ago, 8 shot said:

Reference my second point, is the BASC,NGO, CLA, etc. and NFU to an existent etc, will cease to  exist there will be no voice/representation for shooting agriculture etc. It would be swallowed up in one government body.it has already started with shooting with its own version of the Red Tractor scheme. It will also control environment scheme along with conservation projects. All these people employed in the above organisations will be looking employment within.

Ah, I see what you are trying to say. I think sadly that more government oversite of our sport (and everything else) is the way things are going. That's the problem with Parliments - they have to be seen to do things to make themselves look busy.... but in the mean time, I don't think a stab at self regulation is a bad thing to do. Fellside put it very eloquently when he talked about a green wave. My view is the destruction of the environment is going to be at the forefront of everyone's mind for a very long time, that gives (as we have seen) governments carte blanche to do what they *need* to fix it. Hence untold meddling in all aspects of everything. Sadly I can't see things going any other way any time soon, so we need to do what best we can to carve out a niche for our sport in this new world.

Edited by PeterHenry
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2 hours ago, PeterHenry said:

 

Frankly, I have given up trying to understand you. There are other people on here who I disagre with, but they all at least show some form of reason or aptitude for self reflection. You, on the other hand are a crank.

Not everything is a conspiracy against you.

i on the other hand will continue to try and understand your refusal to accept the truth some self reflection of your own might help you not insult those who’s opinion you don’t like 

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7 minutes ago, clangerman said:

i on the other hand will continue to try and understand your refusal to accept the truth some self reflection of your own might help you not insult those who’s opinion you don’t like 

It's a remarkable coincidence that you have chosen this moment for such a change of heart - and I look forward to your first constructive post.

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On 25/05/2022 at 12:39, udderlyoffroad said:

I assume all the BASC bashers on here will be formerly responding to the UK's consultation with well-reasoned, evidence-backed, arguments against the proposals?

Or will you just moan on internet forums?

Hate on BASC all you like, I'm sure Conor's a big boy, but are you lot actually going to do anything yourself other than **** and moan like grumpy old men?

Is that not the point of BASC and other shooting orgs though? To represent the voice of their memberships on matters such as this on a larger scale? Why would you pay membership if they weren't representing you? Why would you not bash them for taking your money and making decisions that don't sit right with those keeping the lights on?

I agree that people should be taking matters into their own hands (I don't think any of the shooting orgs are fit for purpose, except maybe the NSRA), I have, but the paid-for organisations shouldn't escape criticism just because you don't like the bashing.

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1 hour ago, Demonic69 said:

Is that not the point of BASC and other shooting orgs though? To represent the voice of their memberships on matters such as this on a larger scale? Why would you pay membership if they weren't representing you? Why would you not bash them for taking your money and making decisions that don't sit right with those keeping the lights on?

I agree that people should be taking matters into their own hands (I don't think any of the shooting orgs are fit for purpose, except maybe the NSRA), I have, but the paid-for organisations shouldn't escape criticism just because you don't like the bashing.

We are in agreement.

But, I'm heartily sick of people on here moaning how terrible the organisations are, they won't be getting a penny from me, and so forth, then proceeding to do nothing constructive.

"What did you do when they came for lead ammo, grandad?"

"I had a good moan on PigeonWatch, son"

That said, I'm pleased see several members on here are working on their individual responses to the HSE Consultation.

 

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15 minutes ago, udderlyoffroad said:

 

 I'm heartily sick of people on here moaning how terrible the organisations are, they won't be getting a penny from me, and so forth, then proceeding to do nothing constructive.

"What did you do when they came for lead ammo, grandad?"

"I had a good moan on PigeonWatch, son"

 

 

🙂👍

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2 hours ago, udderlyoffroad said:

We are in agreement.

But, I'm heartily sick of people on here moaning how terrible the organisations are, they won't be getting a penny from me, and so forth, then proceeding to do nothing constructive.

"What did you do when they came for lead ammo, grandad?"

"I had a good moan on PigeonWatch, son"

That said, I'm pleased see several members on here are working on their individual responses to the HSE Consultation.

 

I agree with you on that pal

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