Specimen Response Natural England Licence fee charges consultation
1. What is your name?
2. What is your email address?
3. Are you answering on behalf of an organisation or as an individual?
4. What is your interest in wildlife licensing or profession?
Academic / researcher / curator / museum professional Archaeologist / scheduled monument manager Beekeeper / bee breeder Developer / builder / architect / civil engineer Ecological or environmental consultant Farmer / gamekeeper / forester / fishery manager Government (national) employee Gull egg harvester or seller / bluebell bulb seller Lawyer Local government employee Minerals / quarry industry operator Nature conservation organisation employee Taxidermist Transport (road / rail / harbour / airport)Utility company employee Volunteer working with licensed species Wild bird photographer Wildlife hospital / wildlife rehabilitation / keeper of non-native animals Other (please describe)
Prefer not to say
Other interest / profession – please describe here: Falconer
Individual responders are directed to Question 8
5. What organisation do you represent?
6. How big is your organisation?
self-employed micro (0-9 employees) small (10 – 49 employees) medium (50 – 249 employees) large (250 or more employees)
7. Which sector is your organisation in?
Academic or research Ecological or planning consultancy Developer / minerals / extractive industry Energy or utility company NGO Farming / fishing / forestry Local government National government organisation Other
8. Do you have any comment on the proposal to introduce charges to improve delivery of the licensing service?
introduction of charges free text comment box
The proposal aims to:
Whilst charging for licences is an established practice in government, using small organisations and individuals to pay for investment in licensing services in order to ‘improve’ the imposition of those licenses that are of debateable benefit to the preservation of native bird and animal populations, is highly questionable.
A scientific audit is required to provide clear evidence to support the assertion that charging for licenses actually improves the conservation status of protected species.
Charging for licenses that are produced by a system that is essentially self-perpetuating, cumbersome, and un-reflexive and that will inevitably result in increased costs for many applicants is unethical. Assessment of the processes and procedures within Natural England is required in order to legitimate any charge let alone those proposed. Unfavourable comparisons with private sector efficiency will inevitably be drawn.
To charge for compliance monitoring ostensively to improve environmental outcomes, particularly with regard to Quarry licenses is nonsensical. The cost of such would be prohibitive and the monitoring largely unworkable.
9. Do you have any comments on the proposed charge structure?
Proposed charge structure free text comment box
The proposed charging structure is punitive for individuals and small organisations. The level of increase is unacceptably high and will produce undesirable consequences.
The argument that the proposed fee structure for licenses will actually improve the conservation status of protected species, is shown to be weak 1, by making rehabilitation and release of wild raptors where flying and entering at quarry is necessary, too expensive for private falconers to contemplate, and 2, by hindering the legal recovery of lost captive birds of prey (property) through the imposition of excessive charges for the appropriate license.
10. Do think that the proposed exemptions from charging are reasonable?
What are the reasons for your response?
By failing to include any social, cultural, or traditional exemptions in the charging proposals, Natural England is discriminating against low impact, legal and time-honoured activities. This is effectively an assault upon some branches of falconry, which is a rural sporting tradition that is recognised as Intangible Cultural Heritage of Mankind by UNESCO.
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