Consultation
Manx BirdLife and Manx Wildlife Trust have not been consulted on the drafting of this Amendment Order. This is our first opportunity to comment on its content, merits and potential impacts.

Proposal
The proposal to omit article 4 of the Game Order 2009 [SD 706/09] – in order to remove the additional closed season that was previously provided for Grey Partridges from 1st October to 31st January in any year – raises both questions and concerns.
The stated reason for the amendment is, to quote:
“While there have been no sightings of the Grey Partridge on the Island in recent years, there is demand from farmers and landowners on the Island to be allowed to import and maintain flocks of Grey Partridges for the purposes of shooting.
Grey Partridge have specific and well-researched habitat requirements and, while such habitats are present on the Island, these habitats are currently fragmented.
The reduction in the closed season for Grey Partridge will encourage the improvement of habitats for such birds, to the benefit of other wildlife, improving the Island’s biodiversity.”

Intent
Our understanding is that the intention of the proposal is to ‘open up’ the season for Grey Partridge in order to make (more) viable the importation, captive rearing, release into the wild and maintenance of flocks of this particular non-indigenous species for the “purposes of shooting”.

Any potential gains for native species, habitats and biodiversity need to be clarified, and are likely to be secondary outcomes.

Status
In the Isle of Man, Grey Partridge is a non-indigenous species. It arrived as an alien introduction in the 17th Century (Sharpe 2007).

Grey Partridge has never been abundant on the Island. Its temporary, small and fragmented populations have occupied widely scattered areas of suitable habitat that were sustained only through the use of traditional, less intensive farming methods.
In the 1970s, the remnant population of repeated introductions crashed. Since 2002, there have been less than 10 records per annum, with none reported to Manx BirdLife since 2014. Notwithstanding, Grey Partridge has not yet officially been declared extinct in the Isle of Man.

Habitat
We believe the Isle of Man is not a suitable landscape for supporting a population of this non-indigenous species.

Habitat improvement should be driven first and foremost by priorities relating to species and habitats of conservation concern.

The stated habitat improvement, largely through the provision of cover for the non-indigenous Grey Partridge (and other non-indigenous game birds), could provide favourable conditions for ‘native’ species that are considered priorities for conservation effort and resource, but a clear protocol for habitat creation is required.
The likely habitat improvements cited in the stated reason are unlikely to improve the Island’s biodiversity. More likely, these could provide small gains for some species that are already present on the Island.

Considerations
The protection and optimisation of shooting interests and the interests of wildlife frequently collide. Birds of prey as well as, for example, native mammals such as Stoat and even hares, become casualties when they are considered to be limiters of populations of species and habitats maintained for the purposes of shooting.

The importation, rearing, release and maintenance of a non-indigenous species must be considered carefully whether for the purposes of shooting or otherwise. The Island has a poor track record in understanding and managing the impact of alien species (e.g. Wallabies, Peafowl, Laughing Thrush, Polecat-Ferret) on its natural environment and wildlife.

Competition for food, transmission of disease and parasites, and diminishment of natural habitats could all be outcomes of ‘rearing, releasing and maintaining’ populations for shooting.

Typically, only a proportion of released birds are shot; many, often most, are left to perish from starvation, disease or for example as road casualties. They are typically poorly equipped to survive in the alien environment to which they have been discarded.

Questions
Having not been consulted on this proposal, Manx Birdlife and Manx Wildlife Trust would wish to ask what we believe are key questions:

Demand
• What and how much demand is there from landowners and farmers for this species?
• Why do the current season and shooting arrangements for Pheasant, Red-legged Partridge and Grey Partridge not satisfy the demand for hunting and shooting?

Benefit
• How exactly does this proposed change furnish the Isle of Man’s Biosphere credentials?
• From where and under which schemes will the required cited resources be provided? If from the
public purse what will be the public benefit?
• How exactly will the Island’s biodiversity be improved?
Impact assessment
• Has an independent environmental impact assessment (EIA) of this proposal been carried out?

Monitoring and control
• What guarantees are there that selective methods will not be used to suppress species that are seen as threats to the availability of maintained Grey Partridges?
• What will be the limits of importation, rearing, release and maintenance of Grey Partridge flocks and how will these be monitored?

Support
• Does this proposal have support from the NGO environmental/conservation community?
• What have been the objective conclusions of the Department’s own research and analysis of this proposal? Can these be shared?

References
Sharpe, C. (Ed.) et al. 2007. Manx Bird Atlas: An Atlas of Breeding and Wintering Birds on the Isle of Man. Liverpool University Press.

Manx BirdLife www.manxbirdlife.im

Manx Wildlife Trust www.mwt.im

17th July 2020