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Wild boar, beaver, and the Infrastructure Act 2015 |
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On a Monday night around 8.30pm, early in last November, Baroness Kramer, Minister of State, Department for Transport, came forward with a bunch of amendments to the part of the Infrastructure Bill that that would itself amend the Wildlife and Countryside Act 1981 (WACA) so that it contained provisions for the control of invasive animal and plant species. In a sparsely attended House of Lords, due to the lateness of this first sitting of the Report Stage of the Bill, the Baroness gave a succinct and compelling explanation of what was hoped to be achieved by the amendments, and how they met criticisms raised during the Lords Grand Committee Stage and by stakeholders outside the house (1). I would recommend a reading of Baroness Kramer’s speech for the way she systematically worked through the implications of each of her amendments to the Infrastructure Bill, such as how the native animal species listed in Part 1 of Schedule 9 would be removed entirely from the provisions for Species Agreement and Control Orders - “Although it was never our intention to use these provisions for these species, these changes will make this clear”; how former native species were distinct from non-native species; and how the powers to control species were only going to be applied to former native species “when they have been reintroduced into the wild unlawfully, without the appropriate licence from Natural England or Natural Resources Wales” (2). On the other hand, Kramer assured the House that the amendments would leave animals that had been “reintroduced lawfully following full consideration of their likely impacts by the licensing authority” outside of the powers of control. A number of the amendments clarified what a non-native species was, as well as a “species of animal that is no longer normally present in Great Britain”, these being the two categories that a Species Control Agreement or Species Control Order could be applied to. Since the latter was defined as a species of animal “whose natural range includes all or any part of Great Britain, and which has ceased to be ordinarily resident in, or a regular visitor to, Great Britain in a wild state”, then it also defined a former native species. There was, however, another aspect given to that definition of a former native species, which was listing in a proposed new subdivision of Part 1 of Schedule 9. In fact two new subdivisions of Part 1 were proposed in the amendments: all the native animal (and bird) species would be stripped out of the original Part 1 and listed in a new Part 1A entitled Native Animals; and a new Part 1B entitled Animals No Longer Normally Present would include “reintroduced former natives now considered to be resident whose release into the wild still requires consideration and regulation”
Kramer noted that only wild boar currently
fell into this latter category from listing in the original Part 1,
although she thought it possible that other species could be added to Part
1B in the future. She explained that a reason for wild boar being put in
the category of a former native in Schedule 9 Part 1B was that, although
they once lived extensively in the British Isles, they disappeared due to
hunting and were re-established in the wild as a result of unlawful
releases - they did not come by themselves. The concern was for an orderly
reinstatement of former native species, through the process of the
licensing system established by Natural England (2): The feasibility of reintroducing wild boar in England
I wonder if Kramer had been briefed about
the support that English Nature (Natural England as was) had given in 2005
to the reinstatement of wild boar in response to a DEFRA consultation?
With some clarity, its response was (3): There is a well-worn argument that since there have been colonies of wild boar living free in England for over 20 years, then they should be considered as reinstated. This would carry some weight if it were not for the questionable origin of the animals. This is not an argument about whether the boar came from populations in the wild in Europe that most closely matched those lost from Britain, as was argued before about the unsanctioned beavers on the River Tay (4). It is about the fact that some farmers who started keeping wild boar for meat in the UK would cross pure wild boar males with domestic pig sows (usually Tamworths) to produce an increase in litter size, from an average of 5 in pure animals to 9 in hybrids (5). Since the free living wild boar originated from inadvertent or deliberate releases, and because no official records are kept of boar breeding, then there can be no certainty at the degree of hybridism with domestic animals. Attempts at reinstatement of former native species cannot with any integrity be based on animals that while they may mainly look right, have an inauthentic ecology compared to the wild type. This is the situation with the state of hybridism of the wildcat with feral cats in Scotland that I recently wrote about (6) and where nobody would seriously consider bolstering the wildcat population with animals bred with anything less than wild purity. A recent study monitored the establishment and presence of wild boar in England by collating reports of escapes or releases, and then ground-truthing the evidence of animals in the wild (7). In the 20 years to 2009, there were an average of one to two escape/release incidents each year, involving from one to 50 animals. None of the escapes/releases of five or less animals led to the establishment of a new population. However, there are now at least four distinct populations, the largest of which in Kent/Sussex probably has a pre-breeding population of more than 200. The next largest is likely to be that in the Forest of Dean, Gloucestershire, where the Forestry Commission and private landowners cull wild boar ostensibly to keep the population to about 100 animals (7). There has been criticism of the culling, which occurs in all population areas, because of the lack of sound science on population dynamics (8) or in fact any real effort to monitor wild boar ecology. Nor was there much evidence of the state of hybridism, other than a few obvious cases that didn’t look right (5). However, a study in 2012 provided evidence that the wild boar in the Forest of Dean were not genetically purebred (9). A high frequency of genetic material was found that clearly showed the presence of domestic pigs in their ancestral line, leading the authors to conclude that the wild boars in the Forest of Dean did not fulfil the criterion of genetic purity that really should be the aim of reinstatement programs. There are no published studies examining the feasibility of reintroducing wild boar in England, but in the late 1990s, two modelling studies looked at possible reintroduction in Scotland (7). The monitoring study described above did some broad calculations that arrived at a potential future population of wild boar in England of around 30,000-41,500, based on known densities in both coniferous and mixed/broadleaf woodland (7). Thus it really is time that a feasibility study is done for England, especially since the reinstatement of wild boar makes a strong argument for the need to reinstate the wolf as well (10). It will have to consider the suitability of existing free-living populations of wild boar, as well the possibility that in contemporary Europe, where wild boar populations have been around for much longer, it is not easy to have a free-living wild boar population alongside a domestic pig population, and expect that introgressive hybridization of gene pools will not occur. Studies have shown hybridism with domestic pigs in wild boar in both Germany and the Netherlands (11) as well as in Belgium, western Germany and Luxembourg (12). Native, former native, and non-native species
Returning to the debate over amendments to
the Infrastructure Bill, after our excursion around wild boar, the mention
of beaver by Kramer was in response to proposed amendments from Lord
Davies, the first would have excluded from control, former native species
that were listed for strict protection as species of Community Interest
under the habitats directive, and the second adding beaver, a species of
Community Interest, to the list of native species in Part 1A. Discussion
of these amendments were illustrated with mention of the Scottish beaver
trial, the unsanctioned presence of beavers on the River Tay in Scotland,
and the unsanctioned beavers on the River Otter in Devon. In the end,
these amendments were not moved, but in relation to beavers, the Baroness
stressed that there was a proper process for lawful reintroduction (2): With these adjustments in listing into new parts of Schedule 9, it then became possible to define non-native species, both plant and animal, as a species “whose natural range does not include any part of Great Britain, and which has been introduced into Great Britain or is present in Great Britain because of other human activity”. Additionally, a non-native species was also defined as being listed in a Part 1 now shorn of its native species, such as capercaillie, chough, corncrake, common crane, white-tailed eagle, goshawk, red kite and barn owl, and of the former native species in the wild boar. An unchanged Part 2 of Schedule 9 listed non-native plant species. As the Baroness made clear, the amendments to Part 1 of Schedule 9 separated it into three distinct categories of species—native, former native, and non-native, thus allowing removal of all native species entirely from the control provisions, and ensured that they may be applied to former natives only where they are present without the necessary licence. Section 14 of the 1981 Act would thus continue to apply to all these species, and therefore a licence would still be required for their release into the wild. To make doubly sure for former native species, two further amendments were proposed. These required the environmental authority to satisfy itself, before making a control agreement or control order, on whether the presence of a former native species was licensed or not, and that there was no appropriate alternative way of obviating its adverse impact. I have remarked before that there was no definition of a non-native species in the WACA, in spite of “invasive non-native species” appearing in the headings of Section 14ZA on sales of species and 14ZB on codes of practice (1). Since these sections dealt with species that must not be released into the wild unlawfully, then as Kramer pointed out, the scope of both sections already extended beyond non-native species to both former natives and those native species on Schedule 9 (2). Thus she brought forward an amendment to substitute “invasive non-native species” in these headings to “certain animals and plants included in Schedule 9”. The only other changes to the WACA proposed in the amendment were consequential changes to Sections 14 and 22 so that they would both additionally refer to the new Parts 1A and 1B of Schedule 9. Licensing the release of former native species
I have previously concluded that the Bill as
originally written would have no consequence for Section 14(1) or 16(4c)
of the WACA as it applies to England, and thus the existing conditions for
licensing release of former native species under Section 16(4c) would
obtain even if the Infrastructure Bill was passed without amendment (1).
This conclusion would still hold after Kramer’s amendments, since the
amendments to Sections 14 that were brought forward at Report Stage had no
consequence, as Kramer confirmed in relation to wild boar and beaver, and
that they would not be subject to control where they were lawfully
released. Earlier in her speech, she had recognised that concern had been
expressed that the provisions for control would extend to other former
native species such as the wolf, lynx or brown bear. In this, Kramer was
referring to the contributions in the debate from Lord Davies and Baroness
Scone, who had concerns about whether the proposed amendments would
undermine the strict protection under the habitats directive that should
be afforded to these former native species (2):
In meeting this criticism, Kramer pointed
out that if she had followed through with the “generic” language
that had been requested, then there would be no limit (through licensing)
on bringing back lynx, bear and wolves. Instead, where there were species
like wolf, lynx or brown bear that were formerly native, then they should
go through the “appropriate process where bodies can make the
appropriate judgment for reintroduction” and, if brought in lawfully,
“control orders would not apply” (2): Well, since nobody to my knowledge has asked “ordinary people” in England what they do think, then Kramer may be on less firm ground there. As I noted recently, 76% of people polled in 2013, 21 years after their voluntary return to France, supported the presence of wolf (10). A survey of attitudes to reinstatement of wolves and other former native species in Scotland showed a positive score in both urban and rural populations, the lower score for the rural population being due to the negative attitudes of the subsample of farmers (13). Reaction to the Lords amendments I would have thought that the conservation industry would have been claiming a massive success after these amendments by Baroness Kramer were accepted. If it did, then I overlooked it, but there was some criticism from the Woodland Trust. The Trust was thankful for the clarifying amendment that was accepted which meant that the Infrastructure Bill would no longer facilitate a backdoor privatisation of the Public Forest Estate in England (14). The Trust also welcomed the amendments to the designation of species classes. However, the Trust had some reservations about the proposed species control provisions, because it envisaged a shortfall in sufficient funding being given to environmental authorities to carry out the provisions. Environmental blogger Alasdair Cameron had seen the amendments tabled before the Lords sitting, and picked up on the proposal of creating a class of animal called “not normally present” and that wild boar would be the only animal in that class (15). Without benefit of Baroness Kramer’s explanation, Cameron interpreted the amendment as a means to specifically target wild boar for control. He did, though, allow that this classification of wild boar could just be a precaution, and that the Government may have had no intention of trying to wipe out boar populations. ClientEarth, a group of environmental lawyers, were more extensive in their criticism of the amendments as accepted, producing a detailed “legal report” (16). While ClientEarth had agreement with the new definition of a non-native species, and with the removal of the native species from the original Part 1 of Schedule 9, it rejected the new definition of species “no longer normally present in Great Britain” as well as the provisions that allowed species control agreements and orders to apply to them, as it also rejected creation of the new Parts 1A and 1B of Schedule 9. The charge was that the latter amendments created superfluous legislation and were a breach of EU law in respect to EU protected species.
It would be tedious to go through all the
logic failures in this document, but it would appear that ClientEarth has
no understanding of why there should be controls on the further release of
former native species that had been reinstated in licensed locations
(those listed in Part 1A) and which I have explained previously (1). It
also seems to have a presumption that existence in the wild, irrespective
of how that existence arose, regularises the presence of a former native
species, especially in relation to species of Community Interest listed
for strict protection in the habitats directive. On the latter, I used to
make that case myself (4,17). However, the realpolitik of the
situation, as chased up by the Scottish Wild Beaver Group, is that the EU
will support any Government in denying that strict protection if the
presence of the species was at the hands of a human intervention that was
unsanctioned. Here is the relevant sentence from the guidance on strict
protection under the habitats directive (18): ClientEarth regarded it as “completely illogical” to treat the wild boar in the same way as an invasive non-native species, when they “already exist in Britain as a native species”. Unfortunately, it gave no indication that it was aware of, or even understood, the implications of the free living presence of a former native species that was derived from escapees that were a hybrid with a domesticated animal, as is likely the case with wild boar currently in England (see earlier). A serious program of reinstatement of wild boar would not have started with the release of hybrid animals. It would not anyway be likely to have been sanctioned because of that hybridism. Lastly, I am not sure which version of the EU birds directive that ClientEarth had read, since the report referred twice to the words "naturally occurring" in relation to Article 5, when these words are actually in Article 1 (19). Asserting that the amendments were in breach of the birds directive, ClientEarth spun a scenario whereby a former native species of bird, as a result of natural processes, had recolonised Britain, but since it was not reintroduced under licence, then it could become subject to Species Control Orders. ClientEarth should have tested its scenario with recent examples that revolve around the issues of former native species and natural processes. Little egret (Egretta garzetta) and eagle owl (Bubo bubo) are both listed in Annex I of the birds directive, which requires EU member states to designate Special Protection Areas (SPA) for these species. In the case of little egret, it has been accepted as a native species lost to the onset of the Little Ice Age (21) but reinstated after its voluntary return of a low number of migrants over the twentieth century until 1989 when there was a significant influx. Three SPAs on the south coast of England that encompass 45% of the national population have been designated for the species under Article 4 of the birds directive (22).
On the other hand, while there are eagle
owls nesting and breeding in Britain, they are not regarded as a native
species. There is some evidence that a small population was
present around 10,000 years ago, as a result of slow recolonisation
following the glacial retreat, but it is thought to have died out when the
land bridge to mainland Europe was lost (23). Eagle owls are sedentary,
not prone to crossing large expanses of water, and thus they were not
thought to have subsequently naturally recolonised.
The eagle owls currently breeding in Britain are therefore likely to be of
captive origin, as they have been known here in captivity since at least
the 17th century, and a snapshot of escaped birds between 1994 and 2007
suggested that around 65 birds could be expected to have escaped during
each of those 13 years. In consideration of the implications of the
presence of this large raptor species, a risk assessment was carried out
at the request of the GB Programme Board for Non-native Species (24). In
its summary, the most significant impacts were considered to be intraguild
predation and competition with other raptors (goshawk.
buzzard)(25)
and an owl (tawny owl)
(26). Other native
species of conservation importance may also suffer from predation, such as
curlew, pine marten, red squirrel and capercaillie. The assessment
concluded that control was an option, but observed that there was an
element of public support for the species, and that its status as a
native/non-native was yet to be completely resolved. A few months before
this assessment was publicly released, the eagle owl was added to the list
of species in the original Part 1 of Schedule 9 that may not be released or allowed to
escape into the wild (27) and which must have happened with the tacit
agreement of the conservation industry. The fear of a possible cull as
result of the risk assessment was removed by the Government’s response to
it by Richard Benyon, Natural Environment Minister (28): Listing European beaver as a former native species Coming back to the passage of the Bill, ClientEarth stuck its neck out again when it supported an amendment put forward by Richard Burden, MP, at the Committee Stage of the Bill in the House of Commons that was another attempt to have inserted a reference to species of Community Interest. ClientEarth asserted that the amendment would “ensure that the provisions of the EU Habitats Directive is [sic] not breached” (29). Its argument was that “EU protected species, such as beavers (including for example the breeding family of beavers that are re-establishing themselves in Devon), could also be subjected to Species Control Orders under the Bill”. ClientEarth also returned to the issue of wild boar, describing them as “a native species that are currently re-establishing themselves in the wild in Great Britain”. They recommended that the Part 1B list on which only wild boars were listed was “unnecessary and confusing and should be removed”. More seriously, they alleged that it seemed that wild boar were being “specifically targeted as a species to be controlled, and potentially eradicated” through Species Control Orders.
No one at Committee Stage in the
House of Commons took up ClientEarth’s
recommendation to set down an amendment to remove Part 1B from Schedule 9.
Richard Burden’s amendment was defeated in Committee after extensive
discussion around the status of beaver (see Amendment 30 in (30)). John
Hayes, Minister of State, Department for Transport, noted that amendments
had already been made that removed former native species from control
provisions “where they had been reintroduced lawfully” and an
additional requirement on the environmental authority that it must be
satisfied that it has no appropriate alternative way before using the
provisions for any formerly native species (30): And consider they did, since an amendment to add beaver to Part 1B for England only, was accepted at Report Stage in the House of Commons (31) and confirmed after Third Reading when the House of Lords agreed with the Commons amendment (30). Welsh Ministers would have to consider whether to make a similar amendment in relation to beavers in Wales. In speaking to the amendment in the House of Lords, Baroness Kramer revealed that DEFRA had run a consultation exercise in 2013 on whether to add the beaver to the original Part 1 of Schedule 9 to ensure that licences for their release would continue to be required. The issue was that if the completion of the Scottish trial reintroduction resulted in a decision that the beaver could remain in the wild, then they would become “ordinarily resident” and thus would not require a licence to be released. Apparently, the majority of respondents supported listing the beaver on Schedule 9 to ensure that the current licensing requirements remained in place. This was seen against the backdrop of the then unsanctioned beaver presence in Devon on the River Otter. With an expectation that it would be licensed, Kramer explained that “..listing it in Part 1B of Schedule 9 will ensure that species control provisions cannot be applied to any beaver in the wild where its release has been licensed by Natural England. This, of course, includes the family of beavers on the River Otter in Devon, which are now subject to an approved reintroduction trial”(32) What has changed since the original draft Bill? The Bill was finally passed a couple of weeks ago on 12th February 2015 (33). Much of the rationale for Part 4 of the Act that covers species control (Articles 23-25) is succinctly conveyed in the Explanatory Notes that accompany the Act (34). So what has changed since June last year when the Bill first appeared? Well, there is now a definition of a non-native species, and a former native species. There has been no change in the process for licensing the release of former native species. There has also been no effective change for eight of the native species that were listed on the original Part 1 of Schedule 9 e.g. barn owl, capercailie, chough, corncrake, goshawk, red kite and white-tailed eagle. Movement of these into the new Part 1A still means a license is needed for their release and, even though a listing in Part 1A means they will not be subject to control orders, I pointed out before that it would be unlikely that they would be subject to these anyway as they were already strictly protected at all times under special penalty in Schedule 1 of the WACA (1). The one change is for common crane, a native species that was also moved to Part 1A, but which has no protection under Schedule 1 of the WACA (35). At least it is now recognised as a native species, currently resident, and will not be subject to control orders. What of wild boar and beaver? Well, at minimum, they are both know regarded as former native species. Having both included in a new Part 1B has not changed the fact that it is still unlawful to release them into the wild without a license. However, that listing does remove them from the provisions for control if they were lawfully released. Thus the Devon beavers on being released after being tested for Eurasian origin, and that they are free of a tapeworm parasite, cannot be controlled. It does mean, though, that any other unofficial releases of beaver in England will not be tolerated (10). We can, however, look forward to a time when beaver are sufficiently reinstated in England, through further sanctioned release and their own voluntary dispersal, so that they fall off any listing in Schedule 9. On the other hand, nothing has really been resolved for wild boar. There is currently no specific legal restrictions governing how wild boar can be controlled, other than they are given general protection against cruelty in certain circumstances by the Animal Welfare Act 2006 and the Wild Mammals (Protection) Act 1996, and there is guidance on what weaponry to use (36). Since none of the escapes or releases of wild boar now living free were sanctioned through licensing, then the provisions for species control will apply to them. Will this unleash attempts at eradication of wild boar as Alasdair Cameron and ClientEarth feared (see above)? Well, I guess it is possible that a voluntary Species Control Agreement is consistent with the DEFRA view in their action plan for feral wild boar from 2008 that “primary responsibility for feral wild boar management lies with local communities and individual landowners”(37), and especially since a compensation payment can be made. However, an imposed Species Control Order would be against the spirit of that action plan, derived as it was through public consultation. It would also provoke much public ire, over and above the objection that existing culling does, as is seen in the Forest of Dean (38,39). Putting effort into resolving species issues We are letting the situation with wild boar and eagle owl drift, rather than put some effort in to resolving their situation. There must be a proper feasibility study for the reinstatement of wild boar, and I will not pre-empt here the conclusions of that study. The status of eagle owl was not determined by the Risk Assessment (see earlier) and thus it also needs sufficient effort put into it to have that resolved. What we do not need is the paranoid speculation from the conservation industry that met the original draft of the Infrastructure Bill (1) or the poor misinterpretation of the effect of the amendments by lawyers in ClientEarth, who should have known better. As one who seeks reinstatement of former native species such as the beaver, wild boar, wolf and lynx, I feel it incumbent on me to fully understand the regulatory processes involved, irrespective of whether I necessarily agree with them. It is often the wilder speculations that come from those who have not looked closely at the regulatory processes, but vigilance is all. Miles King’s recent blog about the consequences of the Infrastructure Act contained polemical conjecture about eradication of badgers from areas of England under the Government’s culling program to reduce the incidence of infection of cows with bovine tuberculosis (40). He thought this could result in them being added to Part 1B as animals no longer present, such that if any do try to return to those areas, they can be killed under a Species Control Order. While I consider that far-fetched, if only because a voluntary return would not fall foul of the control provisions, vigilance is required. Badgers are a protected species under the Protection of Badgers Act 1992, but Article 10 of that Act allows Natural England to issue licences for their culling “for the purpose of preventing the spread of disease” (41). As I have pointed out, the problem is that these licences can be issued without any evidence that the consequences of ecological impact of removal of this predator formed any part of the process (42). The proposed roll-out of the culling to many more areas depends on who forms the next Government in May (43). As I noted when I first wrote about the Infrastructure Bill, the Law Commission may come up with recommendations for the complete replacement of the WACA (1). The extensive emphasis in the passage of the Infrastructure Bill on defining species categories in implementing provisions for species control has much wider implications than just those provisions, and will have made a significant contribution to a new wildlife Act. Mark Fisher 2 March 2015 (1) Misperceptions of the Infrastructure Bill - willful ignorance of the conservation industry? Self-willed land August 2014 www.self-willed-land.org.uk/articles/infrastructure_bill.htm (2) Clause 16: Invasive non-native species, Amendments Moved by Baroness Kramer, Infrastructure Bill [HL] - Report (1st Day) 3 November 2014 http://www.publications.parliament.uk/pa/ld201415/ldhansrd/text/141103-0003.htm#1411042000321 (3) Feral wild boar in England: A consultation by the Department for Environment, Food and Rural Affairs. Summary of responses. 2006, pg 13. (4) The Tayside beavers - living wild and free in Scotland, Self-willed land January 2011 www.self-willed-land.org.uk/articles/tayside_beaver.htm (5) Are the Free-living Wild Boar Pure Bred Wild Boar? British Wild Boar http://www.britishwildboar.org.uk/index.htm?purity1.htm (6) The third dimension is the last refuge of the wild, Self-willed land December 2014 www.self-willed-land.org.uk/articles/focal_species.htm (7) Wilson, C.J. (2014) The Establishment and Distribution of Feral Wild Boar (Sus scrofa L.) in England. Wildl. Biol. Pract. 10: 1-6 http://socpvs.org/journals/index.php/wbp/article/download/10.2461-wbp.2014.un.1/271 (8) Wild boar cull 'not based on scientific estimates', Camila Ruz, Guarduan 1 September 2011 http://www.theguardian.com/environment/2011/sep/01/wild-boar-cull (9) Frantz, A.C., Massei, G. and Burke, T. (2012) Genetic evidence for past hybridisation between domestic pigs and English wild boars. Conserv Genet 13:1355–1364 http://link.springer.com/article/10.1007%2Fs10592-012-0379-1 (10) Cry wolf - the return of Britain's top predator, Self-willed land February 2015 www.self-willed-land.org.uk/articles/cry_wolf.htm (11) Goedbloed, D. J., van Hooft, P., Megens, H. J., Langenbeck, K., Lutz, W., Crooijmans, R. P., & Prins, H. H. (2013). Reintroductions and genetic introgression from domestic pigs have shaped the genetic population structure of Northwest European wild boar. BMC genetics, 14(1), 43. http://www.biomedcentral.com/content/pdf/1471-2156-14-43.pdf (12) Frantz, A. C., Zachos, F. E., Kirschning, J., Cellina, S., Bertouille, S., Mamuris, Z., & Burke, T. (2013). Genetic evidence for introgression between domestic pigs and wild boars (Sus scrofa) in Belgium and Luxembourg: a comparative approach with multiple marker systems. Biological Journal of the Linnean Society, 110(1), 104-115. http://onlinelibrary.wiley.com/doi/10.1111/bij.12111/abstract (13) Nilsen, E. B., Milner-Gulland, E. J., Schofield, L., Mysterud, A., Stenseth, N. C., & Coulson, T. (2007). Wolf reintroduction to Scotland: public attitudes and consequences for red deer management. Proceedings of the Royal Society B: Biological Sciences, 274: 995-1003 http://rspb.royalsocietypublishing.org/content/royprsb/274/1612/995.full.pdf (14) Lords, Ladies and the Infrastructure Bill, Lorraine Mullally, Woodland Trust 21 November 2014 http://www.woodlandtrust.org.uk/blogs/woodland-trust/2014/11/lords-ladies-infrastructure/ (15) The Boar Wars - how the infrastructure bill is specifically targeting wild boar, Alasdair Cameron, The Mushy Pea 31 October 2014 http://themushypea.blogspot.co.uk/2014/10/the-boar-wars-how-infrastructure-bill.html (16) Legal report on the Infrastructure Bill and what it means for native species in England and Wales, ClientEarth November 2014 (17) Tay beavers to stay free and living wild, Self-willed land May 2012 www.self-willed-land.org.uk/articles/tay_beaver_update.htm (18) Guidance document on the strict protection of animal species of community interest under the Habitats Directive 92/43/EEC, (final version Feb 2007 ) http://ec.europa.eu/environment/nature/conservation/species/guidance/pdf/guidance_en.pdf (19) DIRECTIVE 2009/147/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 November 2009 on the conservation of wild birds http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32009L0147&from=EN (21) Bourne, W.R.P. 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