FRIENDS OF THE BOAR c/o Dr David J Slater, xx Fairways Avenue Coleford GL16 xxx

01594 xxxxxx 25th August 2011

Dear Kevin, Many thanks for your co-operation and willingness to work together on the wild boar issues we presented to yourself and Ian Harvey at our meeting 5th August 2011. Thanks also for your invitation to respond to your Feral Wild Boar Management Draft Plan 2011-2016. We hope you will consult with us further in the future. As you will be aware that since our meeting, wildlife photographers and enthusiasts have formed a group called “Friends of the Boar”. The group is growing rapidly. Some members have also started an ePetition to Downing Street (as of 23rd August 2011). We have discussed the plan together and wish to present our response to your Draft Plan as a group. The Friends of the Boar wish to make the following MAJOR comments:

1. There should not be any management plan formulated and set in stone prior to your proposed census survey and its results. Adoption of the plan MUST be postponed until after the data is known. 2. The census results should be made public and open to comment before adoption. 3. Any future cull targets must be based on scientific evidence of population numbers and also upon some knowledge of population dynamics. 4. There must be an inbuilt margin of safety (precaution) in the cull target to prevent undue stress on the boar, population rebound, potential for disease outbreak, and to promote a healthy ecosystem within the Forest environment. 5. Cull targets need to take into account boar loss by poaching and private shooting by farmers and recreational shoots. From our conversation, it is also apparent that road accident boar casualties are also inaccurate. Without this information, a cull target cannot be accurate and must be significantly lowered as part of the precautionary principle outlined above.

6. A plan to undertake, and periodically revise a census is the most important aspect of the management plan. Boar populations are known to be dynamic with continual movement in and out of an environment (like a forest). A one-off census is insufficient to formulate a rigid management plan. 7. The current population maintenance level of 90 boars is woefully too low. It was arbitrary. It needs to be closer to the carrying capacity of the Forest (see below). 8. We are unanimous that pre-emptive killing of boar in order to reduce a perceived risk of any kind is an outrage, immoral and unnecessary. Such “risk” is subjective, open to bias and abuse. 9. We can agree that ONLY IF a wild boar is PROVABLY a danger or persistently troublesome, that it may be killed. We do not believe there is enough risk of injury to humans (see below) to justify pre-emptive killing. However, we acknowledge a potential for a wild boar to stray into an urban centre and possibly panic. Examples around the world have resorted to shooting, but could such an incident be remedied by tranquilliser dart? We believe darting is a much more humane way of dealing with a boar that has accidentally strayed from its environment. 10. Section 10.9. We INSIST on a closed season. This should be from the start of farrowing in late winter to the next rut in late summer (approximately 6 months). We understand that Wild Boar would NOT breed all-year round in a properly managed regime. Boar will breed continually when there is over-culling or prolonged culling without a closed season. This has led to the FC killing piglets and suckling sows which we find abhorrent (and although the FC deny this, there are many testimonies to circumstantially prove it has been occurring for several years, including the 2011 press coverage in “The Forester” with you (Kevin Stannard) admitting the FC are needing to cull piglets to achieve your arbitrary cull target – we do not believe this was an error of reportage as you later claimed, but an error of admittance). 11. Wild Boar needs to be allowed to closely occupy the carrying capacity (population) of the environment (which can be determined using current conventional modelling techniques). This promotes a healthy population and age distribution, herd immunity from diseases, and a sustainable source of game. This is healthy and proper game management. 12. We STRONGLY feel the management plan is for too long a period (5 years). There needs to be either some interim re-appraisal included (plus ongoing census data), or a yearly management plan adopted - at least for a few years until the management and monitoring of the boar is much better understood than at present.

13. There is no mention of the trade in boar meat in the plan. We worry this can be a driver of the cull, rather than a by-product. The plan needs to be transparent with regard to the financial interest the FC has dealing with meat sales, with explanation of the obligations you have under contract to supply wild boar to traders. This would alleviate much of the suspicion surrounding cull targets, profit and contracts. 14. There is no mention of how non-FC or private sales in wild boar meat may affect the management plan. We are fully aware by your own admission on the 5th August 2011 that the FC knows of individuals who privately hunt and trade in wild boar meat in and around the Forest of Dean. These known private activities have an effect on population numbers and dynamics and, therefore, needs to be reported, controlled, and/or equated into the management plan. 15. We do NOT agree that the Wild Boar are Feral. We understand this is probably a Defra issue, but the FC may help to change this. DNA tests show that they are as wild as the European population (from where they were imported). We believe the feral status is being maliciously adopted to prevent legal protection under existing wildlife laws. This is seen as appeasing a vocal sector of the community (especially the Forest of Dean) who either want to exterminate or recreationally shoot the boar.

We wish to make further lesser priority (conditional to the above) comments:

16. Section 5.1. Whilst we accept there is some small impact on the FoD human community, the damages and threats outlined in the plan are in our opinion minor as well as very subjective. Much of the subjectivity has been created by previous “scare” stories and fear propaganda in the local media. This includes persistent reference as purposeful “spin” by the FC to a minor incident of when a man’s finger was accidentally cut during hand feeding a friendly boar – due to the boar being attacked by children with sticks at the same time. Public perception has been moulded by inaccurate information about the boar, and as such cannot be taken seriously as a justification alone for culling. 17. Section 5.1. Lack of dog attacks in 2011 may prove vastly reduced numbers of boar in 2011, rather than un-reporting of incidents. It may also suggest that the community are now learning to live with the boar. 18. Section 6. We agree that more study is required to assess ecological impact on the Forest environment. 19. Section 6.1. We agree. Consensus from areas across Europe who do have wild boar in forests tend to agree that wild boar are generally an ecological asset.

20. Section 6.2. The statements relating to butterflies in Section 6.2 is misleading and inaccurate. We have been in contact with the Butterfly Conservation Group. They assure us that the effect on some butterflies (particularly Wood White and Grizzled Skipper) by boar rooting is NOT known, and it is only a tentative hypothesis that there MAY be detrimental impacts – they need some research on this. 21. Section 7. Your rationale for killing wild boar is again subjective, presumably based upon poor education of the boar and rooted attitudes born out of previous media exaggeration and false facts. We do not agree that justification for culling should be to “minimise the risk of adverse interaction…and the visual and physical damage to amenity grasslands…. and to maintain a population at a manageable level.” This is worded to justify pre-emptive killing. It is far too subjective and ill defined and would lead to continued suspicion about how boar management is being undertaken. 22. Section 7. We agree that many residents and tourists do not like the visual “damage” along roadside verges and picnic sites. Could there not be a way to quickly repair this damage by someone? It is not a difficult task to kick back the peeled turves! Maybe utilise “community service” offenders? 23. Section 7. There have been NO instances of unprovoked attacks on humans by wild boar. Only 1 possible example has occurred in Europe where populations of boar are in the millions. It is statistically SAFE to assume that wild boar are not a physical threat to people unless the boar are provoked (as per the Ruardean School incident when the young boar became aggressive due to attempts by the FC at cornering the animal). Avoidance of attack requires some educational promotion – eg. Do not feed the boar, especially near to dwellings, dogs called to heel, etc. The threat from a “rogue” boar or injured boar is remotely possible, nevertheless, but only in these circumstances should killing a boar be deemed necessary after an incident (many animals are dangerous when provoked, injured or during the rut, and boar are no different). 24. Section 8. Public perception is useful information, but more research is required. We repeat, public perception has previously been moulded by fear in the press and lack of real facts. This should be part of an interim review of this 5-year management plan. With education and positive promotion, we feel that the community will largely come to accept and enjoy the boars. 25. Section 9. Almost the entire section on population is meaningless due to lack of any population evidence. Cull targets have been based upon a guess at a population of 90 in 2008 and continues to be based on a guess. There has never been any evidence of how many boars are in the Forest at any given time due to too many unknowns.

26. Section 9. There is no evidence of populations in the FoD of either doubling or trebling in a year. This is a hypothesis based upon ideal conditions in “captivity”, and has no relevance to wild populations. This has persistently been used as “spin” by the FC and such “fear” of population explosion should be based upon facts of wild populations that are CORRECTLY managed and monitored (not blindly over-culled as we currently believe is occurring – as only this promotes over-breeding in the wild and more problems as discussed with you in person). 27. Section 9. We strongly suspect that the Council and others were too trusting of the FC figure of 90 in 2008 to determine a maintainable population. The Scrutiny Committee had no expertise of wild boar, and they could not argue against the FC. The FC was WRONG to present a guessed figure of 90, and present themselves as experts at that time, as this was misleading and unfair. 28. Section 9. We object to the use of eyewitness accounts or photographic evidence in section 9.6, for example “large family groups of up to 40 boar… near Ruardean..or Cinderford” as evidence of anything other than “boar move and can get together in sounders numbering about 40 in 2010”. The conclusion of this section is totally meaningless and has no relevance whatsoever to a management plan 2011-2016. Furthermore, it certainly DOES NOT suggest that boar is happy to move into urban areas. It could be strongly argued that boar are unhappy in urban areas but are forced closer to them by persistent shooting within the forest, or even nearby logging operations (as in the Cinderford example quoted in the plan). We learn from Germany that boar soon learn that increased safety can be sought close to houses (like many other animals who are persecuted, eg. foxes). 29. Section 10.3. There is no evidence that “high cull levels” need to be achieved if you do not know the current population. 30. Section 10.4 and 10.5. We see no reason for traps or cages, except to catch by stealth provably dangerous boar that can’t be caught by other means (e.g. tranquilliser). 31. Section 10.8. We STRONGLY disagree with the use of GnRH contraceptives to control population until research can absolutely guarantee the contraceptives will not adversely affect male boar or other animal species that clean up after the boar. There are major concerns over weakening the genetic health of the population. We also have concerns over safety of any adjuvant. We fear that such drugs would also eventually enter the human food chain. It could be via poaching, even if the FC themselves were to stop trading boar meat.

Lastly, Article 22 of the Habitats and Species Directive (EC 92/43) states that member states of the European Union should investigate the possibility of reintroducing species…. that are native to their territory, where this might contribute to their conservation. Furthermore, under article 11 (2) of the Convention of European Wildlife and Natural Habitats, the UK government should encourage the reintroduction of native species. We believe this should include Wild Boar. Wild Boar is undisputedly a native forest animal that were only exterminated due to poor management by over-hunting. Wild Boar are considered a wild animal across Europe. Only here in the UK is the perversity of a “feral” distinction. We feel there is a duty under European directive to assist the continued longevity and occupation of Wild Boar in the UK, and this could be good public relations for the FC if they were to promote such a policy here in the Forest of Dean. In the interests of future co-operation and understanding between the FC and wildlife enthusiasts, we hope you will seriously take on board the above comments and distribute them to the other consultees before the management plan is set in stone. We would also like to hear some feedback on our comments if possible. We understand the machinations of government to sell the Forest, but we believe your cooperation on this issue also, will only further increase public support for the FC. Yours truly,

Friends of the Boar (Forest of Dean).