Providing opportunities for formerly native species reintroductions

The onslaught of promotion of wild managed herbivores is more than concerning for its attention setting agenda that has to be exposed before it runs away with everything. The reinstatement of large carnivores will be drowned out in this, even dissuaded as troublesome for the herbivorists, yet it must be within the function of the England Species Reintroductions Taskforce to gather advice on this

I was badgered to write a chapter for a book about wolves. I relented when it was pitched to me that it could be an afterword as an appeal for action in returning wolves to Britain, one of the few countries in the Northern hemisphere where wolves are still missing. Amongst other things, I noted that I was envious of those countries in Europe that had recently seen the voluntary return of wolves as they moved steadily westward across the continent (1). I was also envious of the people of Colorado who succeeded in petitioning for a ballot in 2020 that would require the Colorado Parks and Wildlife Commission to create a plan to reinstate and manage grey wolves on Federally designated lands in the west of the state by the end of 2023. I‘ve been following this process in Colorado since before the vote (2) and after it was successful when the process of public engagement began on a Restoration and Management Plan, carried out by Colorado Parks and Wildlife (3). Alongside this, a Technical Working Group and a Stakeholder Advisory Group were convened and which reported on a range of issues that were deemed necessary in the Plan, such as outreach and education, conflict minimisation, restoration logistics, impact assessment, and livestock compensation.

The public’s comments had made a difference

Colorado Parks and Wildlife staff developed a draft plan and delivered it to the Commission in early December last year (4). It was then put out to the broader public during a series of meetings in January and February this year as well as for online comment (5). The draft plan was an adaptive management system over a phased recovery period of monitoring and evaluation for population viability, prey availability, ecosystem responses, wolf-livestock conflicts, public safety, and public tolerance (6). After initial releases were completed, the success of reintroduction efforts would be based on monitoring wolf abundance and distribution annually to evaluate progress towards meeting State wolf recovery objectives. The phases of the recovery period would be based on reaching thresholds for increasing number of wolves known to be present in the state, and transitions between the four phases would correspond with the status of the species on the Colorado Threatened and Endangered Species list: State Endangered; State Threatened; State delisted, nongame; and State delisted, game.

The Rocky Mountain Wolf Project (RMWP) provided guidance to responders on what would strengthen the Plan (7). Along with specific points relating to each chapter, it highlighted that the Plan must explicitly exclude any future wolf hunting by underscoring the fact that the electors of Colorado had supported a ballot that had classified wolves as “nongame wildlife” indicating that they had clearly intended to prevent sport hunting of wolves in perpetuity. Surveys had also shown that most Coloradans not only supported wolf restoration, but opposed trophy hunting and trapping of wolves. RMWP then noted that the Plan failed to fully address the legal requirement to “assist owners of livestock in preventing and resolving conflicts between gray wolves and livestock” Thus, it should clearly outline non-lethal deterrents and animal husbandry practices, encouraging ranchers to use them as the first line of defence to minimize conflicts between wolves and livestock. In addition, the Plan should tie receipt of compensation, after an initial incident, to implementing conflict reduction tools and strategies to prevent further losses of livestock. Defenders of Wildlife proposed three ways that would strengthen the Plan: the possibility of hunting should be removed; substantially raising the threshold in population at which wolves could be delisted from having a status of threatened; and Colorado Parks and Wildlife Commission to do more to promote coexistence and greater outreach to the state’s ranching community (8).

A text summary and a visual presentation of the 2,698 consultation responses on the Plan were produced (9,10) that reflected amongst other things the opposition to recreational hunting if wolves were reclassified as a game species in Phase 4 of recovery in the Plan (see pg. 38-40 in (6)). After hearing comments at the final public event, the Colorado Parks and Wildlife Commission provided guidance to Colorado Parks and Wildlife staff on final revisions to the Plan (11,12). That the public’s comments had made a difference was the requirement to remove Phase 4 from the Plan, although there was to be a statement added that it could be revisited only after wolves had successfully been recovered and removed from the State Threatened and Endangered list. Other guidance on revision covered livestock compensation, and various changes in the stringency of evidence on population numbers, population viability and geographical distribution before transitioning through the Phases.

Cutting across the state listed status

Strictly protected status was a key factor in the successful recolonisation of wolves across Europe, whether it was from the EU Habitats Directive or the Bern Convention (13). The protected status of wolves in America under the federal Endangered Species Conservation Act 1973 (ESA) has been subject to periodic attempts at delisting certain geographical areas and which has then resulted in litigation to prevent delisting, as has happened with implications for Colorado (6). At present, though, wolves in Colorado are listed as endangered under the ESA on the basis that they are in danger of extinction throughout all or a significant portion of their range (see Sec. 3(4) in (14)). As such, it is unlawful to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect wolves, or to attempt to engage in any such conduct (see Sec. 9(a)(1)(B) and Sec. 3(7)(14) in (14)). Under the State Threatened and Endangered list in Colorado, wolves are listed as State Endangered, defined as a species of native wildlife whose prospects for survival or recruitment within the state are in jeopardy (6). Thus, under state law, it is illegal for any person to hunt, take, or have wolves in their possession, and which is punishable by fines, imprisonment or both.

This protected status should have augured well for the reinstatement of wolves in Colorado, but paradoxically the Colorado Wildlife and Parks Commission requested the US Fish and Wildlife Service to develop a rule that would see the wolves be regarded as an “experimental population” during recovery. This is under a clause in the exceptions contained in Section 10 of the ESA (6). The clause, Section 10(j), was added in 1982 as an amendment in order to ease local residents' fears in reintroduction areas that wolves would damage wild game herds and kill livestock (15). The clause defines as experimental a population, and any offspring arising, that occurs from an authorised release and which is wholly spatially separate from existing populations (16). This allows for a relaxation of the prohibited acts under the ESA to permit, under limited conditions, harassing as well as lethal control in the removal of problem wolves. The Commission believed these operations gave it a management flexibility that was a critical component to the success of the Plan, but doesn’t it just look like it cuts across the state listed status in the phases of recovery in the Plan (6)? The US Fish and Wildlife Service has since developed a proposed rule for Colorado Gray Wolf, along with a required Environmental Impact Statement, and opened the proposed rule in mid-February to a 60-day period of consultation through a series of public meetings as well as online comment (17).

The same argument about management flexibility had been made years before when wolves that were being reinstated in Yellowstone in 1995 were classed an experimental population (18). It is being made now for the reinstatement of grizzly bears to the North Cascades Ecosystem in Washington State where the proposal is for the grizzlies be an experimental population (19,20) an action opposed by Wilderness Watch and with whom I agree is a gamble on a successful outcome (21). I find this attitude to management expediency very disappointing, as have respondents to the proposed rule for the Colorado wolves whose objections range from simple statements of despair to well worked arguments of why it is not necessary (22). Given the strong feeling in Colorado about ensuring a permanent return of wolves, and buoyed by citizen power being effective through the democratic route of the successful ballot on reinstating wolves, the voters of Colorado will want to take away responsibility for determining the protection of wolves from federal agencies, and decide for themselves as a state. The ESA provides for this when it says that any State law or regulation on the taking of an endangered or threatened species may be more restrictive than the exemptions or permits provided for in the Act or in any regulation which implements the Act (see Sec 6(f)(2) in (14)).

Code and good practice guidance for reintroductions

This is also possible under the Bern Convention, the supranational agreement that, as we have left the EU, would now protect wolves in Britain, and which says in Article 12 that contacting parties can adopt stricter measures for protection than provided under the Convention (23,24). However, as I have discussed before over the reinstatement of beaver, there is a prejudiced intolerance towards inconvenient species from entitled rural communities so that their compliance with any, let alone strict protection, is unlikely (25). Nevertheless, the 25 year Environment Plan for England made a vague commitment to providing opportunities for the reintroduction of formerly native species, as well as a firmer commitment to developing a code and best practice guidance for species reintroductions (26). A very recent first revision of the 25 year Environment Plan made a similar commitment to providing opportunities for translocations, as well as a hint to targets for species abundance by a commitment to explore the reintroduction and conservation translocation of native species to improve biodiversity (27). A new Species Reintroductions Taskforce was mentioned in this revision, with views being sought from it on potential reintroductions and conservation translocations (see later).

I saw a draft of the code and good practice guidance in 2020, and it seemed to be very similar to the Scottish Code and Best Practice Guidelines for Translocations (28). It had the same distinction of assisted colonisation to an area outside of a “natural range” - “native range in Scotland” - when it is unlikely that the species is able to colonise by natural dispersal. As far as I know, there are no indicative maps of “natural range” and this could lead people to argue that the distribution of a former native large carnivore was not universal in Britain, leading to restricting and confining reintroductions. The other thing that I was wary of was ecological replacement – taxon substitutions/proxies – as I feared that it wouldn’t be long before someone seized on this as an argument for letting bison loose (see later). The code was poor on indicators for success and could at least have pointed to the IUCN Green Status of Species that, as I have noted elsewhere, brings rigour to interpretation of “fully recovered” (29,30).

The finalised code was published in May 2021 (31). To my amusement, it had added what was probably an unintended rejoinder to those who have described fenced-off beaver as a reintroduction by saying “it is not a true reintroduction”, just a translocation as a “conservation management tool”. Removed was any acknowledgement of authorship, or recognition of the input provided by members of the “Code and Good Practice Guidance for Reintroductions and Conservation Translocations Sounding Board”. This Board included statutory agencies (DEFRA family) a sprinkling of wildlife NGOs and rural organisations as Full Members, and then a secondary layer of wildlife NGOs, rural organisations and some individuals as Corresponding members. The latter included unsurprisingly the usual suspects of the animal trader Derek Gow (3) and more usefully Roy Dennis (32). I suspected Gow may have been the source for an article by Helena Horton in The Telegraph newspaper a couple of months before the code was published that erroneously said a “rewilding task force” was being set up (33) as the quotations from Gow in a subsequent article seemed to suggest (34). However, given what had happened in Scotland, it would more likely be something similar to Scotland’s National Species Reintroduction Forum (32) that was said to have had significant involvement in development of the Scottish Code and Guidelines (35)

Parliamentary inquiry on Species Reintroduction

Sure enough, a few weeks later in May 2021, Natural England announced that it was to establish a species reintroductions task force, with itself as secretariat, and a with a membership of landowners and NGOs (36). The announcement tied species reintroductions to proposed legally binding targets for biodiversity. Thus, it was framed as being about the reintroduction of species lost from England but not Britain, as well as helping existing populations in England to recover, both as part of the Nature Recovery Network. (That Network doesn’t even get a mention in the Environment Act but which does mention targets for species abundance (37,38)). An analogy to the latter action will be the trial release of captive-bred wildcats into the Cairngorms National Park as a means of increasing its population and distribution in Scotland, as the result of a successful application to NatureScot for a licence under the Scottish Code for Conservation Translocations (39). What the announcement about the task force for England didn’t mention was any reinstatement of former native species no longer present anywhere in Britain. Subsequently, DEFRA announced in January last year that it had opened applications for the Chair of the England Species Reintroduction Task Force, although it was more equivocal about the focus of the species reintroductions it would be advising on (40).

The targets for species abundance were finally published in December last year, and those plus the species listed in the draft regulations seemed to confirm that limiting focus of being more about reversing declining species abundance (41,42). I searched for anything about the England Species Reintroductions Task Force, especially confirmation of its membership, and came up with a newspaper report from that same unreliable journalist (see above) which said that it met for the first time in February (43). It was alleged that one of the topics under discussion was how to "approach rewilding without causing conflict with local people". Is that really its remit, to get into some likely ill-informed discussion about an approach to species perpetuation that is totally misinterpreted, or was it more duff information being peddled by this journalist? Is it that this journalist is obsessed with calling species reintroduction rewilding when on its own it isn’t without other measures? Must everything be called rewilding?

I then found that Andy Clements, the new Chair of the England Species Reintroduction Task Force, had submitted written evidence last December to a parliamentary inquiry on Species Reintroduction by the Environment, Food and Rural Affairs Committee (44). As I suspected, Clements didn’t mention rewilding. The inquiry was launched last November to look at how species reintroductions could support delivery of government’s biodiversity and nature recovery goals; what role Landscape Recovery and Local Nature Recovery Schemes, under the Environmental Land Management Scheme, should have in supporting species reintroduction; and on ways of reducing conflict amongst different stakeholders to species reintroductions (45). The inquiry sought written evidence with a deadline for submissions of mid-January – it received 53 (46). This was followed by three oral evidence sessions from invited witnesses, the last session being with Clements as one of the witnesses (47).

Task force or taskforce?

In his written evidence, Clements explained that the Terms of Reference for the Task Force were still in draft form, but that initial membership of the Task Force had been approved by DEFRA (it was not revealed who they were) and that it would ultimately comprise 12-15 people, ranging from academics, staff from statutory agencies and NGOs, and land managers (44). The task force would provide technical assessments of the suitability of species for future reintroduction; build the knowledge base for informing future projects; have a strong role in maximising the benefits of species reintroductions, including benefits for communities and stakeholders; and provide advice to support the translocation and reintroduction of native or formerly native species at both regional and national scales. A first quarterly meeting had been scheduled for mid-February at which, Clements said, a Stakeholder Forum would be established that was seen as a means to elicit the widest possible support for reintroductions as well as develop partnerships leading to successful projects. Clements committed the task force to developing and publishing a framework to inform the assessment of benefits and risks of species for reintroduction that would be aligned with the published code and guidance on translocations (see earlier) and which was intended to ensure a consistent approach to identification of the relative environmental, socio-economic, and legal suitability of species for future reintroductions. In addition, the task force would advise on the suitability of donor locations and reintroduction sites. While the reintroduction of formerly native species at least opened the possibility of a wider view of reintroductions (see above) Clements said that the task force would preferentially promote conservation translocations linked in to government initiatives such as Environmental Land Management Schemes, Biodiversity Net Gain, Local Nature Recovery Strategies, and the delivery of a Nature Recovery Network i.e. the species abundance targets.

As if by magic, the minutes of the first meeting of what must now be known as the Taskforce (and not Task Force) as well as its membership and Terms of Reference, appeared a few days ago (48) on the morning of the day Clements was to give oral evidence to the inquiry on species reintroductions. Barry Gardiner, one of the committee members, drew Clements attention to this coincidence during his oral evidence, pointing out that it had been a long time coming since the original announcement of the taskforce (49). He noted that the Terms of Reference was one of the thinnest documents he had ever seen, full of the obvious, but nothing about the harder issues, which he said were pest control and human-species conflict. Clements said that one of the things the document did was set out the main reason for having a taskforce, which was to provide evidence that informed decisions by others. Gardiner remarked that “Taskforce” suggested something more than just providing advice. I see what Gardiner means about the Terms of Reference stating the obvious since it just rehashes much of what was already known or expected, and pointed to the belated webpage presence (50). The taskforce explored the terms of reference at its first meeting (51). Taskforce members agreed that a clear vision for the taskforce would help, that its role would not include prioritising species for reintroduction, but to ensure all the evidence was available for others to do so in line with a national strategy. They called for the terms of reference to be amended and agreed. As it was, the establishment of the Stakeholder Forum was put off until the next meeting. Longer term, the taskforce and Natural England would convene a conference/seminar in March 2024. There was no discussion on how to approach rewilding without causing conflict with local people as journalist Helena Horton had erroneously asserted (see above).

Returning to Clements’ oral evidence (49) there were questions to him about the independence of the taskforce from DEFRA and Natural England, what its day-to-day working relationship with them would be; how the composition of the taskforce was decided and recruited; whether it had reached out to key organisations and individuals, including organisations that had been critical of the taskforce in their evidence to the inquiry, the lack of transparency over its formation, and the range of expertise in its membership (see (52)) ; and what its funding from DEFRA was. It would be tedious to go through all his responses, but there were other markers. Clements observed that the taskforce had not been consulted before the Secretary of State of State announced at a farming conference in January that she would not support reintroduction of species like lynx or wolves (49). He said that the taskforce would ensure that the evidence was more widely available and understood that would help in decision making about whether lynx and wolf were considered for reintroduction or translocation in the future – he would not rule out their reintroduction. He noted that the key added value of the taskforce was to provide evidence not only on controversial reintroductions of “megafauna”, but on the many plant and animal species of much lesser impact.

Megafauna was an odd term for Clements to use if it was only in relation to wolf and lynx. Perhaps he had his response on outreach in mind when he said he would be following up the “bison reintroduction proposals that they have got going in Kent” with Kent Wildlife Trust (and see this tweet – (53)). It had been my original intention to obtain a current snapshot of opinion on the reinstatement of large carnivores from analysing the evidence submitted to the inquiry. I had my suspicions, though, that those who seek to normalise the presence of bison in Britain would use the inquiry to pursue their own insistent agenda that attracts endless, gushing, public exposure (i.e. 54) but where the bison are erroneously described as wild and free-roaming and to have been reintroduced – they are not former natives and they are behind fencing (3). Was Clements misinterpreting the meaning of reintroduction when he applied it to the bison – don’t forget that the code and guidance says that fenced animals are not a true reintroduction, merely a conservation management tool (see above) the latter being an apt description, as I have explained before for the bison in Kent (3,55). Alternatively, was his use of reintroduction in relation to these bison presaging an early partiality in the advice the taskforce would give?

Large carnivore reintroduction

There was the usual pontification and banalities about the reintroduction of wolf and lynx from those who wanted to appear to be knowledgeable, but who had absolutely no intention for it to happen, such as Alasdair Driver of Rewilding Britain (52,56,) Evan Bowen-Jones, CEO of Kent Wildlife Trust, who even said it would not be the time to consider apex predators such as wolves (52) Richard Brazier of Exeter University (57,58) Katie Beckmann of Edinburgh University (59) Zoological Society of London (60) and Tony Juniper, Chair of Natural England (49). Driver is a peripatetic mainstreamer of safari park rewilding who has done much to degrade the real meaning of rewilding (61) including trying to dissociate it from reinstatement of former large carnivores (62). He never misses an opportunity to catalogue his achievements and unsupported data (the infamous spreadsheet he keeps) when, in his oral evidence to the inquiry, he said he had visited about 140 major landholdings that were seeking his advice and had gathered a “list of 50 species that were either being reintroduced or are being considered for reintroduction. None of them is lynx and none of them is wolf” (52). Clearly, Driver has no concept of the scale at which reinstatement of large carnivores takes place, and which would not be at the level of individual farms. More fun facts from Driver were “42% of our rewilding landowners are members of the NFU; 50% are members of the CLA”. Calling it REFARMING Britain seems apt.

Farming and land organisations focussed on what they perceived were the negative effects of large carnivore reintroduction, that they endangered other threatened species, and citing evidence from Continental Europe of the need to adequately compensate for the loss of livestock as well as ensure stakeholder engagement, such as the Game and Wildlife Conservation Trust (63) National Farmers Union (64) Tom, Bradshaw, National Farmers Union (52) National Pig Association (65) Norfolk Rivers Trust (66) Landmark Associates Ltd (67) Ross McNally (68) and Country Land and Business Association (69). As well as those concerns, Tom, Bradshaw, National Farmers Union (52) the Countryside Alliance (70) British Association for Shooting and Conservation (71) and National Sheep Association (72) wanted there to be a provision for lethal control to manage reintroduced populations of large carnivores.

Of those more favourable, Natural England said that one of its mammal specialists had undertaken a study tour of German and Swiss projects to assess the suitability of lynx and wildcat reintroduction to the UK, and staff involved in reintroduction work benefited from Erasmus-funded visits to Germany to learn about the experiences of communities living with recovering populations of species such as beaver and wolf (73). Natural England said that most conservation translocations around the world were initiated or approved by government agencies. It revealed that it, or a predecessor, had been the lead or co-lead actively involved in 34 species translocations since 1970. Beaver Trust said that reintroduction of keystone species such as Eurasian Lynx would have the biggest effect on species abundance in England due to their scientifically documented ability to create and change habitats that benefit other species (74). West Dorset Wilding observed that lynx and wolves were living alongside people throughout parts of Europe without major problems (75).

The Wildlife Trusts said that reintroduction represented the only viable means of securing species no longer present in the UK, recommending that Government should look at all those species, especially keystone species, consider which should be reintroduced as part of a nature recovery strategy, and set a timetable for their return (76). The Trusts believed that now may not be the time to reintroduce bears and wolves, but it would be entirely appropriate to be considering now the reintroduction of wild cat and lynx. The Lifescape Project said that it had worked with European partners to complete the ecological and viability assessment for reintroduction of lynx, and was currently working with partners to plan practicalities and social consultation (77). The project proposed payments for species presence as well as payments for damage mitigation or compensation under the Environmental Land Management Scheme to support species reintroductions. In addition, it recommended that formerly native species like lynx and wolves should be excluded from the Schedule of the Dangerous Wild Animals Act 1976 (78) in circumstances where they were being released as part of a reintroduction programme.

The fantasy in which bison were being framed

The infiltration of bison into evidence given to this inquiry on species reintroductions was truly depressing. Thus, it was casually included in lists of species for reintroduction to the UK by Beaver Trust (74) West Dorset Wilding (75) Landmark Associates Ltd (67) and Richard Brazier (57). In contrast, Driver said that “there is no categoric evidence that Bison existed in Britain” by which he probably meant European bison (56) the Wildlife Trusts that the steppe bison that used to occupy Britain were extinct and thus implying were not replaceable (76) whereas Lifescape implied that European bison had been lost from the UK so that they were replaceable (77). Just to be clear, Government defines reintroduction as a species translocation of “an organism inside its natural range, to areas from which it has been lost. Reintroduction aims to re-establish a viable population of the focal species within its natural range” (79). If it has a natural range that it has been lost from, then it implies that it is a former native species. You cannot reintroduce a species if it is not a former native species. It would instead be an ecological replacement as a proxy for a former native species.

To get a grip on the fantasy in which bison were being framed in other evidence to the inquiry, I have couple of analogies. Say you needed to use an animal to chew up grasses and shrubs as a conservation management tool for open landscape species, but also wanted some high-profile publicity. What better, then, than a wild rather than a domesticated herbivore. Bowen-Jones declared that he was “conducting a very high-profile bison project” in Kent, and that native habitats were best managed by keystone species, the “diversity that they inject into them” increasing their climate resilience (52). The later claim is speculative and anthropocentric, but he could have reinforced his climate credentials by the added selling point of choosing a wild herbivore having lower methane emissions than most ruminants, including bison, and that would be kangaroos (80). Like bison, kangaroos are listed under the Dangerous Wild Animals Act 1976 as requiring to be licenced and be safely contained, such as in a fenced enclosure (78) so there would be no difference there. However, rightly, you wouldn’t consider fenced kangaroos in Kent as a reintroduction as there are no marsupials in our evolutionary past, so why would you consider European bison a reintroduction? There have, anyway, been captive bison in England for many years before the high-profile bison project in Kent, as they are farmed for meat at places like Bush Farm Bison Centre, west of Salisbury in Wiltshire (81,82) Farnless Farm Park near Bishop Middleham in County Durham (83) and Bouverie Lodge Bison and Venison Farm at Nether Broughton near Melton Mowbray in Leicestershire (84). All three have North American bison behind fences, but none of them claim any role for the bison in managing the landscape. So why are people sucked in by the overheated publicity about a few bison behind a fence in Kent?

One of the bison farms, Farnless Farm Park explained that they had to have a dangerous wild animal licence for their North American bison (buffalo), as you do for European bison, and under no circumstances were visitors to enter their pasture (85). You wouldn’t call those American bison a reintroduction, but you would be wise to observe the potential danger of a wild animal that has unpredictable behaviour. I first saw wild bison in 2003 in Elk Island National Park near Edmonton in Canada (86) and the Park advises driving slowly as they will move out of the way, and not to approach closer than 100 metres when on foot (87). I saw bison again in 2008 in the Hayden and Lamar Valleys of Yellowstone National Park in America (88) where the safety advice was to stay eight bus lengths away from wolves and bears (100 yards) and two bus lengths (25 yards) away from bison (89) – we kept 100 yards away from bison.

There was special pleading around bison, and herbivores in general, in evidence to the inquiry. The Wildlife Trusts claimed that elk, bison and wild boar – all listed in the Dangerous Wild Animals Act 1976 - were no more dangerous than deer, domestic cattle and domestic pigs (76). It whined that for its high-profile bison project, Kent Wildlife Trust had to “spend very significant funds (many thousands of pounds) to erect a fence to separate humans from introduced bison”, claiming this was a “significant barrier” to the introduction of wild or semi-wild herbivores. It said there were “no safety grounds for this separation – anymore than you might have for domestic cattle”, the “experience in the Netherlands” showing that “it is perfectly safe to allow people on to land where bison graze”. That’s not my experience of truly wild bison in America (see above) and it is pretty disingenuous to point to experience in the Netherlands when it is likely based on the Kraansvlak where the safety advice is to keep to a distance of at least 50 metres when walking through the bison enclosure (90). The Wildlife Trusts complained that legislation designed for domestic cattle and horses should be modified to accommodate wild or semi-wild grazing. (76) Then we got to the nub of it when The Wildlife Trusts claimed that there were “perfectly adequate Health and Safety regulations in place to regulate the reintroduction of bison (as a proxy for the extirpated Steppe bison) back into the UK”. Driver also endorsed the use of proxies for species formerly resident in Britain but that were now extinct, and which had had “an important function in the ecosystem” (52). He asserted that European bison would most closely fulfil the function of aurochs in modern-day Europe, even though as I have pointed out, their habitat selection differs (91,92) and even domestic cows have a different habitat selection to aurochs and are thus not an adequate taxon substitute (93). Driver also said that bison were “good examples of enclosure species” like beaver (52). Lifescape said that large herbivores, such as bison, needed to be reintroduced for the “recreation of fully functioning ecosystems in the UK” (77)

Kept wild large herbivores

The Wildlife Trusts put this function of herbivores into context when it painted a picture of wild herbivores having shaped the British ecosystem by being critical keystone animals that had had “profound impacts on species diversity and abundance through grazing, browsing, wallowing, nutrient transfer etc” (76). Failing to mention large carnivores in this ecosystem development is the usual wilful blind eye of herbivore obsessives. The Wildlife Trusts claimed that any promotion of nature recovery beyond protected sites must “recreate guilds of wild herbivores”“Wild cattle, wild horse and steppe bison are now extinct but proxies can be used: domestic primitive breeds of cattle and horse and European bison” but that these “reintroduced large herbivores cannot not fulfil their ecological function when effectively kept as livestock, as the current UK legislative regime generally requires”. The Wildlife Trusts proposed a new legal category of “Kept wild” that would “allow wild or semi-wild large herbivores to fulfil their role in nature recovery and ecosystem restoration. It would clarify issues of contention in existing law and define the conditions in which large wild herbivores may be kept”. It said we needed to “develop areas in which semi-wild grazing by these large herbivores is possible by creating larger and unfenced landscape recovery areas”. Confusingly, it then back-tracked on unfenced by saying that this required installation of perimeter fencing of large areas, cattle gridding and speed limiting roads, fencing of major roads and installation of green bridges or underpasses, and use of “no-fence” collars that apply an aversive electric shock near businesses and houses when animals cross a virtual boundary. Lifescape listed "Kept Wild" as an initiative it was involved in, and claimed it was a “founding member of the Large Herbivore Working Group” that had been set up to create the conditions for large wild herbivores to return to Britain (77) - I can find no evidence of this group. Lifescape sought to have bison removed from listing under the Dangerous Wild Animals Act 1976, and the “onerous animal welfare and health obligations” lifted from the “natural grazing of semi-wild large herbivores”. Warning bells about the ecological meltdown at the Oostvaardersplassen in the Netherlands should be ringing when removal of animal welfare and health obligations there led to mass starvation and deaths (94, 95).

If it hasn’t already dawned on you, the high-profile bison project in Kent - now that cattle, horses and pigs have been added in with the bison (54) - is obviously the prototype for The Wildlife Trusts vision of large recovery areas, and with the intention of its recreated herbivore guild being “Kept wild”. It’s just so banal that it would copy the Kraansvlak in the Netherlands, its bison and horses, and with the same busted logic on the evolution of landscapes when, fundamentally, it is being subjected to a human-induced trophic imbalance (55,96). Bowen-Jones of Kent Wildlife Trust (52) claimed to the inquiry that it was important to get “opposing views”, find “common ground”, take “everyone’s opinions into account”, and give them “equal weight”, and yet whenever I have been critical of this high-profile bison project, he told me, as he did the inquiry, that there were a “lot of people who are extremely supportive of this from a principle perspective” then blocked and ignored me, and with questions unanswered. Bowen-Jones common answer to the inquiry on species reintroduction was that it was “complicated” – it depended on “where a species sits on the Wildlife and Countryside Act list and which appendix it is on, whether it is extant, whether it is formerly extinct or whether it is, in some cases, not on the list, like bison, because it is pre the date that they decided whether anything was native or extinct”. Of course, he is a master of all this complication, and so he added to it by complaining that there was a limited categorisation of animals that can used in law and which allegedly lumped wild animals in with domestic animals. Thus what was needed, he said, was a tiered system where there was a “wild managed category” He opined that “It works for new proxy species….like bison, which need to be brought in as ecosystem engineers but do not fit into any of our pre-existing lists”. He then brazenly said – “Everyone on this panel and beyond needs to promote a more active management of a number of species in the right way”. Brow beating?!

So, why must it be made easier for wild managed herbivores? Why should the Environment, Food and Rural Affairs Committee be hoodwinked into facilitating clones of the fenced-off, herbivore-infested Kraansvlak and Oostvaardersplassen? Is it the intention of these herbivore obsessives to have free living bison, or will they just be satisfied with their movement restrained – it is such a muddled picture. If free living, are European bison an ecological replacement, a proxy for aurochs or for steppe bison, both extinct species, but only aurochs could be considered to have become extinct through human agency and thus merit consideration for replacement (55)? Perhaps what the England Species Reintroductions Taskforce should be doing is considering the implications of an ecological replacement in the introduction of European bison as a proxy, elucidating advice on which a decision could be made of whether steppe bison should be replaced – the evidence suggests not - whether they are an adequate taxon substitution or not for steppe bison or aurochs, and which would determine whether they have to be fenced or not. International guidelines identify the need for greater stringency for translocations as ecological replacements, especially in the ecological fit and habitat selection of the replacement species to that which it is replacing (97).

Wolves increase their nocturnality at sites of high human disturbance

I could have saved myself work by waiting for the Committee’s report on its inquiry into species reintroduction to be published, rather than wade through the evidence myself, an awful experience. However, the juxtaposition in evidence to the inquiry of the first public outing of the England Species Reintroductions Taskforce and the onslaught of promotion of wild managed herbivores was more than concerning for its attention setting agenda that had to be exposed before it runs away with everything. The reinstatement of large carnivores will be drowned out in this, even dissuaded as troublesome for the herbivorists, yet it must be within the function of the England Species Reintroduction Taskforce to gather advice on this. If it did, many will be quick to offer evidence of the negatives, often factually inaccurate and perpetuating harmful stereotypes, but - as I try to document - there are sound approaches towards wolf reinstatement (see earlier) and studies on wolf behaviour that indicate that wolves are as disinclined to come into conflict with people as we are with wolves. Here’s another paper on the latter, a recent study of the spatio-temporal patterns of avoidance strategies from Greece that found that wolves exhibited different activity patterns between low and high human disturbance levels, increasing their nocturnality at sites of high human disturbance, travelling at night as well as avoiding paved roads (98).

Mark Fisher 30 March 2023

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(11) Parks and Wildlife Commission meeting recap: Final public comments, Commission guidance on edits to Draft Wolf Restoration and Management Plan, Colorado Parks and Wildlife News Release 3/3/2023


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(14) Endangered Species Conservation Act, 87 Stat. 884, United States Statutes at Large, Volume 87, 93rd Congress, 1st Session, 1973

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(38) Environment Act 2021 CHAPTER 30

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(51) 15 February 2023: meeting minutes. England Species Reintroductions Taskforce

(52) Oral evidence: Species reintroduction, HC 849, 28 February 2023

(53) Andy Clements (@_AndyClements) Twitter 1 March 2023

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(77) Written evidence submitted by The Lifescape Project (SR0029) Species reintroduction, Environment, Food and Rural Affairs Committee December 2022

(78) Dangerous Wild Animals Act 1976

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