PPC117 | Technical
Gull management requires great effort and knowledge to be successful.
In this article, Natalie Bungay and Special Interest Group (SIG) BirdWise give practical advice on gull control and submitting a successful licensing application.
When looking at gull management, be it the legal requirements or the practical implementation, there is a lot to consider: the legislation, non-lethal options, what licensing application you need for the removal of nests, eggs and adults, and how to submit a successful licence.
The legislation in brief
As we know, all birds, their nests, and eggs are protected under the Wildlife and Countryside Act 1981, section 1.
For gulls, there are allowances, in certain circumstances, for them to be managed in a “lethal” way. But this requires you to first apply for an individual licence issued by the relevant UK Government agencies to provide a legal basis for authorised persons to consider lethal control methods.
Depending on where you are in the UK, this will either be:
Essential steps for securing your gull control licence
Anyone who has applied for a licence to control gulls will know how tricky it can be! But applications should be granted if you have a genuinely good reason for removing eggs, nests, or adults and the right evidence.
When applying for a licence to control gulls, you must imagine that you are the wildlife officer approving or denying an application to kill wild birds.
You would be responsible for ensuring the work has a genuine need and meets the legal requirements for you to approve the application.
If you approve an application that turns out to be unlawful, then you would be in a lot of trouble!
If you keep this in mind, you will better understand the decisions these officers have to make and the solid evidence they need to approve them.
Before applying
Before you log into that licence form and start tapping away, you must first ensure you have followed the legal requirement to have genuinely tried all other non-lethal means of prevention/control. The things you need to consider are...
Prevention before nesting starts
Authorities will examine what work has been done to try to prevent the birds from nesting. You need to consider all angles: proofing, deterrents, scaring with audible alarm calls, fixed and handheld lasers, targeted falconry, and even hawk kites.
Proofing high-pressure areas
If you can, you also need to show that high-pressure nesting locations from previous years have been considered for proofing. Records of this consideration, such as a survey report, will be required.
Generally, plastic owls as a deterrent will not be effective for gulls and should not be considered.
Public health and safety
If the gulls are nesting for the first time and the danger to public health and safety is high, we’d advise speaking with the authority you would be applying for a licence with (e.g., Natural England).
Gathering evidence
If you need to apply for a licence, have you gathered all the evidence you need?
Evidence: the key to a strong application
These are the main things you need to consider when applying for an individual licence for gull control.
The reason
The usual basis is that the gulls cause public health and safety concerns from their nesting activities. “Nuisance” will not cut the mustard; there has to be a genuine public health issue, such as:
- Droppings accumulating that may cause serious injury (slips) or illness through contact
- Droppings blocking gutters or gullies then cause flooding
- Serious issues with birds attacking people, stones being dropped on passers-by
- Gulls fouling on people as a defence mechanism (yes, that does happen!)
- Contamination of food stuffs.
The species
This will be requested at the point of application, so brush up on your identification skills. You will need to say which species of gull you’re looking to control, as there are different rules governing species and the licences/circumstances under which you can control them.
Collect an array of photographs of the birds. Not just one bird perching on the edge of the building, but a good collage of images of the species, close up and as part of the broader problem that exists.
Just make sure you get your identification right!
Evidence of non-lethal control methods tried
You must provide evidence that you or your customer have tried some non-lethal methods to tackle the issue before applying for a licence.
You need to include the reasons for discounting these non-lethal controls. An example of a good reason could be that the weight of the cost to proof is unreasonable for the control required.
Evidence of the problem the gulls are causing
There are a few angles to go here, depending on the problem.
If droppings are causing a public health and safety concern, take plenty of photos of them, clearly showing that they are an issue.
If they’re causing slip concerns, seek records from your customer of “near miss” accident reports or emails from employees or the public stating they have slipped (you can redact personal details for GDPR).
For those with blocked gutters, ensure you have photos and records of maintenance teams having to repair them regularly or water damage as a result of the blockage.
Copies of invoices for cleaning being carried out to address the droppings in sensitive areas can also be helpful.
When it comes to attacks on staff or the public, you should seek records from your customer of “near miss” or accident reports, injury reports, and submitted/hospital visit records.
You should also collect emails from employees and the public stating they have been attacked (again, you can redact personal details for privacy).
A good piece of evidence is video footage (CCTV, etc) of gulls attacking people, fouling on people as a defence mechanism, or picking up and dropping stones on nearby people or vehicles.
And finally
All of the points above will be scrutinised in detail. In the past, I have been contacted by members who have been upset because their application has been refused.
After examining the application, one common denominator emerged: the above points were not covered thoroughly enough.
Licensing authorities will not approve applications based on “stories” or word of mouth about the problems occurring. They need hard evidence.
If you do not have this evidence, you will not be successful and will have wasted a good portion of your time.
Follow our advice, and you have the best chance of being approved for lethal gull management.
About BirdWise
BirdWise, a special interest group (SIG) set up by BPCA in 2017, has the sole focus of ensuring the pest management industry has a place to go when guidance, research, or advice is needed on bird-related topics.
The group has been successful in creating bird codes of best practice, guidance and templates on using general licences properly and legally as well as a general place for the BPCA staff team to go when those tricky bird-related enquiries come in.
If you're interested in joining BirdWise, or any of our other SIGS, get in touch.
technical@bpca.org.uk