Creating a reserve for Apis mellifera mellifera on Colonsay: summary of views, submitted for consideration by the Scottish Government, during the period from 5 February to 19 April 2013 1. Background 2. Summary of responses 3. Summary of issues raised 4. Conclusion 5. Annex A Original proposal 6. Annex B List of responses 1. Background Between 5 February and 19 April 2013 the Scottish Government sought views on the creation of a protected area for Apis mellifera mellifera encompassing Colonsay and Oronsay using the powers contained in the Wildlife and Countryside Act 1981. The proposal that was circulated for comments is included at Annex A. This was carried out to fulfil the requirement in the 1918 Act that the Scottish Government consult Scottish Natural Heritage and any other person appearing to them to have an interest in the creation of restrictions such as those outlined in this proposal. 2. Summary of responses 43 responses were received: 21 representing the views of organisations, 21 representing the views of individuals and one response whose origin was unconfirmed 1. All organisations were content with their details and responses being published. All individuals were content with their responses and names being published. 6 asked for their contact details to be withheld. A summary list of the responses is included at Annex B. 3. Summary of issues raised Hybridisation: Taking steps to maintain a population of Amm bees protected from hybridisation with other subspecies was, in general, acknowledged to be a worthy aim. In addition most responses agreed that the steps outlined in the proposal would provide that protection, although many highlighted that the protection would only be as effective as its enforcement. Disease: The majority of the responses received were supportive of the proposal however many expressed concern that it failed to address the issue of diseases 1 This response has been removed from the consultation. 1
potentially being brought on to the island. Many responses expressed concern that there is no longer any prospect of protecting bee colonies on the mainland from infestation and that therefore disease free island populations should be protected. Suggested additions to the proposal included a ban on imports to Colonsay of any bees, a requirement to sterilise any beekeeping equipment being brought on to the island that could be contaminated, a ban on repackaging non-colonsay honey on the island or feeding non-colonsay honey to Colonsay bees. Human impact: A number of responses highlighted the potential positive impacts for businesses and individuals on the island resulting from the proposed action, as well as the general benefit to researchers and the beekeeping community. Many felt that tourism on the island would benefit. Wider biodiversity: Several responses mentioned possible competition between honey bees and wild pollinators some to warn that there may be a risk if the honey bee population on the island was increased and others to state that there was no clear evidence that there was a risk. 4. Conclusion Many of the extra measures suggested, relating to disease control, are already part of good beekeeping practice and a ban on any bees being taken onto Colonsay has the potential to be counterproductive as it risks the genetic pool becoming too narrow. The Bees Act 1980 and the order made under it (the legislation that currently provides for disease and pest protection of honey bees) do not make specific provision for protection from Varroa, however the prohibition on keeping non Amm honey bees on the island will reduce the risk of diseases being brought on to the island by limiting the movement of bees onto the island generally. In relation to the potential for honey bees on Colonsay to have a negative impact on wild pollinators the scientific literature, and case studies of similar scenarios, indicate that increases of honey bee densities on Colonsay would increase the risk of competition with native bees. There is no evidence however that creating a ban on the keeping of other honey bees on the island would substantially increase the number of colonies kept. The Scottish Government will now work towards creating a ban on keeping of non- Amm honey bees on Colonsay and Oronsay, according to the terms of the original proposal. If competition between Amm honey bees and wild pollinators becomes an issue, the Scottish Government will consider options available for limiting negative effects. 2
Annex A Proposal for creating a reserve for Apis mellifera mellifera on Colonsay 1. Legislative background 2. Background to Colonsay bees 3. Proposal 4. Questions 5. Process for responding to the Scottish Government 1. Legislative background The Wildlife and Countryside Act 1981 has recently been amended, by the Wildlife and Natural Environment (Scotland) Act 2011, to include a set of powers for restricting the sale, possession and release of certain species. The Scottish Government are considering the use of these powers to protect the current population of Apis mellifera mellifera (Amm) on Colonsay. During the passage of the 2011 Act an amendment was put forward to create such protection in primary legislation but was withdrawn following assurances by the Scottish Government that the Act would provide sufficient powers to address this issue and that protection of the Colonsay bees would be considered as a matter of priority following the coming into force of the legislation. The 1981 Act, and secondary legislation made under it, controls the release, keeping, reporting and sale of species according to a set of definitions relating to their history and the risks they pose. The terms are explained in the Code of Practice on Non-Native Species http://www.bit.ly/scotcodenns, some are outlined below as they are particularly relevant to this proposal. Native range: This is the range of locations in which an animal or plant (or type of animal or plant) is indigenous where it occurs naturally. Former native: An animal or plant whose native range previously included Scotland or a particular part of Scotland but is now not indigenous. Unauthorised release is an offence under the 1981 Act. Former native species are non-native species for the purposes of the 1981 Act. Invasive species: These are animals and plants which, if not under control of any person, would be likely to have a significant adverse impact on: Biodiversity Other environmental interests or Social or economic interests. 3
Annex A 2. Background to Colonsay bees The honey bees currently kept on Colonsay are thought to be one of very few Amm populations in Europe, as such they are a valuable genetic resource. The honey bees found in Scotland today are a domesticated animal with some colonies living in the wild. All of the current Amm populations in Scotland are kept as livestock. Amm is the only sub-species of honey bee native to northern Europe. The native range is thought to have included Britain, but there is uncertainty over whether it extended into Scotland. For the purposes of the 1981 Act, Scottish Natural Heritage considers all honey bees to be a non-native on Colonsay because it is very unlikely they colonised without human intervention. To restrict the keeping or sale of any species under section 14ZC or 14A of the 1981 Act the species in question must be invasive. The Scottish Government considers that the keeping of any honey bee on Colonsay and Oronsay is likely to have a significant adverse impact by hybridising with the Amm population. Such an outcome, when the impact is in a rare population of pollinators, has an impact on both environmental and socio-economic interests. All honey bees other than Amm are therefore considered to be invasive on Colonsay and Oronsay. 3. Proposal The different ways in which the 1981 Act can be used to control the introduction or use of species are dealt with separately below for clarity. These together form the proposed framework for protecting the Colonsay population of Amm. Release: The release of any animal outwith its native range in Scotland is an offence. The release of any honey bee on Colonsay and Oronsay is therefore an offence. The Code of Practice on Non-Native Species outlines that the keeping of honey bees is not a release for the purposes of the 1981 Act (see chapter 4, list 1(a)). The Scottish Government is not therefore proposing any change releases of honey bees. Keeping/Possession: The keeping of any honey bee is currently unrestricted by the 1981 Act in Scotland. The Scottish Government proposes to prohibit the keeping of any honey bee other than Amm on Colonsay and Oronsay in order to protect the current Amm population from hybridisation. 4
Annex A 4. Questions The Scottish Government is interested in your views on the proposal outlined above, in particular in relation to the questions below. This list should not be treated as exclusive and comments on any other aspect of the proposals are welcome. a) Do you agree that the Amm population on Colonsay should be protected? b) Do you think that the proposal will protect the Amm population on Colonsay from hybridisation? c) Do you think that the proposal goes far enough/too far? d) Should the proposal go further? For example by restricting the sale or advertising for sale of honey bees on Colonsay or requiring the reporting of non-amm honey bees if they are seen on Colonsay. e) Do you think that the proposal would affect businesses? If so what types of business and what effect would you envisage? f) Do you think that the proposal would affect individuals? If so what types of people and what effect would you envisage? g) Do you think that the proposal would have an impact on other species? If so which species and what impact would you envisage? h) Do you think that the proposal would have an impact on wider biodiversity? If so which ecosystems or habitats and what impact would you envisage? i) Do you think that the proposal would have an impact on conservation efforts. If so what work and how severe an impact? 5
Annex A 5. Process for responding to the Scottish Government The 1981 Act requires the Scottish Government to consult Scottish Natural Heritage and any other person appearing to them to have an interest in the creation of restrictions such as those outlined in this proposal. We have contacted the following organisations: Scotland s Rural College Bee Farmer s Association Scottish Beekeeper s Association Buglife Butterfly Conservation Scotland Bumblebee Conservation Trust Hymettus Ltd University of Stirling Scottish Environment LINK Scottish Working Group on Non- Species We have also contacted a number of individuals that have expressed an interest in this issue in the past. How to respond We require you to indicate, along with your response to the proposal, whether you are content that the Scottish Government publish you response. Please indicate how you would like response to be treated: Are you responding on behalf of an organisation? If YES If NO Please indicate whether you are happy Please indicate whether you are happy for your response to be published. for your response to be published. Your organisation name and address will If you have indicated that you are happy be published. for your response to be published, please indicate which of your details you are happy for the Scottish Government to publish: (a) Publish name and address. (b) Publish neither name or address. (c) Publish name only. A summary of the responses received will be published on Friday 10 th May on the Scottish Government website. All responses should be sent to catherine.murdoch@scotland.gsi.gov.uk OR Catherine Murdoch Wildlife and Protected Areas Natural Resources Division 1-D North Victoria Quay Edinburgh EH6 6QQ All responses should be submitted before Friday 12 April 2013. 6
Annex B Summary of responses from organisations 1 Mull Beekeepers' Association 4 Newbattle Beekeepers Association 6 Dunfermline and West Fife Beekeepers Association 9 Colonsay Community Council 10 Cowal Beekeepers Association 12 Western Galloway Beekeepers Association 13 Dingwall and District Beekeepers' Association 14 West Linton Beekeepers' Association 15 Lochaber Beekeepers Association 20 Societas Internationalis pro Conservatione Apis Melliferae Melliferae 21 The Bee Farmers' Association of the U.K. 22 University of Warwick 24 The Bee Improvement and Bee Breeders' Association 34 Scottish Beekeepers' Association 35 International Bee Research Association 37 Royal Society for the Protection Birds 38 East of Scotland Beekeepers Association 40 Buglife 41 Swiss Black Bee Keepers 42 Farm Animal Genetic Resources Committee 43 Orkney Beekeepers' Association 7
Annex B Summary of responses from individuals 2 Dave Goulson 3 Alastair Cameron 5 Joyce Duncan 7 Robert Paxton 8 Stephen Martin 11 Angela Skrimshire 16 Kevin Lane 17 Mark Scullion 18 Duncan MacDonald 19 Hilary Heasman Norris 23 Calum Grigor 25 Eric McArthur 26 Alistair Martin 27 Austen Brown 29 Crissie White 30 Alan Govan 31 Ian Craig 32 Roger Patterson 33 Clare Darlaston 36 Thomas McGravie 39 Doris Fischler 8