The Countryside Alliance welcomes the opportunity to provide comment on this Natural England (NE) draft Internal Guidance Note (IGN). We understand that this IGN has been produced following the judgement in the High Court in the case of McMorn v Natural England which ruled in favour of the Claimant. We therefore welcome NE's efforts to implement Defra policy lawfully when licensing lethal control of birds to prevent serious damage.
The Countryside Alliance is broadly supportive of the process and criteria detailed in the IGN. However, we have some concerns about how this achieves neutrality and the use of evidence in the decision making process. We have severe concerns about the additional guidance document on "Non-lethal methods of resolving conflicts with birds". We believe that further consultation is needed with a broader range of stakeholders before this additional guidance can be used to determine Principle 1 of the IGN.