Together for birds and people

Impact of Regulation 1774/2002 and European Commission decisions in 2003 and

2005 on carrion-feeding birds in the Iberian Peninsula, and possible solutions

Report for the European Commission,

elaborated by SEO/BirdLife 15 June 2007

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Impact of Regulation 1774/2002 and European Commission decisions in 2003 and 2005 on carrion-feeding birds in the Iberian Peninsula,

and possible solutions

Authors:

Ana Iñigo and Juan Carlos Atienza SEO/BirdLife Spain

On behalf of

The BirdLife International European Partnership

With contributions from:

Jose María Garcia de Francisco (Ministry of Agriculture, Fisheries and Food of Spain), Rubén Moreno-Opo (Fundación CBD-Hábitat

Spain),David Howell (SEO/BirdLife Spain), Martine Razin (LPO/BirdLife France), Michel Terrasse (LPO/BirdLife France), Iván Ramírez

(SPEA/BirdLife Portugal), Luís Suárez (WWF/Adena Spain), Luís Tirado (SEO/BirdLife Spain).

And

Ariel Brunner, Ellen Townsend and Konstantin Kreiser

BirdLife International

Produced by SEO/BirdLife for BirdLife International

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Contents Page

1. Summary 4 2. Introduction 5 3. Evolution of Bovine Spongiform Encephalopathy (BSE) 6 4. Current status of carrion-feeding bird populations in the Iberian Peninsula 7 5. Member States´ obligation to collect livestock carcases 13 6. Member States´ obligations to conserve carrion-feeding birds 14 7. The incompatibility of these commitments 15

a. Reduction of the food availability i. Number of feeding spots

ii. Necessary food amount in these spots iii. Distribution of the feeding places

b. Increasing risks from other threats i. Sanitary menace for these species at the feeding spots

ii. Possible change of the distribution area iii. Other menaces

8. Impact of the legislation on the carrion birds on the Iberian Peninsula 19

a. Reduction of productivity b. Changes in behavioural pattern c. Rising hospitalization in recovery centres d. Scientists show the impact of this Communitarian rule e. Other threatened carrion vertebrates

9. Possible solutions 26 10. Bibliography 29

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1. Summary The outbreak of Bovine Spongiform Encephalopathy (BSE) in the 1990s prompted the European health authorities to publish and endorse a specific regulation controlling the disposal of animal carcases in the countryside in order to minimise the risk of spreading this disease amongst animal and human populations. This regulation prompted EU breeders to change their procedures for disposal of fallen livestock. Up to that time any dead animal which was not suitable for human consumption was left in the field or removed to a designated location for dead livestock. These carcases, especially of goats and sheep, represent the essential food source for carrion-feeding bird species which consume practically 100% of the livestock carcases not suitable for human consumption. The new regulation dramatically changed livestock management and banned the abandonment of dead animals on the field or their removal to the designated locations. This new situation poses a serious problem for the conservation of carrion-feeding birds which, as a result, are failing to find enough food to survive. The situation is particularly serious in Spain and Portugal, which host more than 50% of the total European population of carrion-feeding birds. In the light of these concerns a series of decisions was taken with the aim of making livestock management consistent with the conservation of carrion-feeding birds. However, as this report demonstrates, these proposed measures are not sufficient to meet the needs of these bird populations in the Iberian Peninsula. In recent years, decreased productivity, increased numbers of hospitalized birds in recovery centres due to semi-starvation, and changes in vulture behaviour represent some of the most obvious impacts of this legislation on carrion-feeding birds in Spain and Portugal. It is important to bear in mind that BSE is gradually cows has dropped since 2005 after it was demonstrated that the peaks in 2003 and 2004 came from livestock born in the 1990s, when the parent animals were fed with contaminated feed. More striking is the fact that goat and sheep do not suffer from BSE, but that all reported cases of Transmissible Spongiform Encephalopathy (TSE) in these animals arose from scrapie, a disease known for many years to pose no risk to humans. It seems clear that the current legislative framework and its implementation are driving a major crisis for the populations of carrion feeding birds in the Iberian peninsula, which holds the most important concentration of such birds in Europe and one of the most important worldwide. If urgent measures are not taken this could seriously

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jeopardise the conservation status of several species, some of them already globally threatened. The current system is also leading to the collapse of a clean and efficient natural sanitary system replacing it with a much more expensive and polluting artificial one. It would thus be appropriate to update the rules for handling animal by-products not eligible for human consumption in order to allow dead livestock to be removed to recognised locations or, as was previously the case with extensive livestock rearing, the abandonment in the wild where they are immediately consumed by carrion feeders. 2. Introduction Traditionally, in the Iberian Peninsula and elsewhere in the EU, when a cow, goat or sheep died, either it was left where it fell or, in the case of dying on the farm, it was removed to a specific location - away from the farm or village - traditionally known as a “muladar” (a dump for carrion). These “muladares” were known since the Middle Ages, and have become one of the most significant food sources for carrion-feeding birds. In areas like the Iberian Peninsula, with a high density of these bird species, these dumps, along with abandoned dead livestock in the wild, form the basis for maintaining these populations. The need for these dumps and other special hygiene measures has long superseded the threats of the Black Death and other mediaeval epidemics. However, more dramatic measures were adopted after the emergence of the first cases of BSE (“Mad Cow Disease”), and Creutzfeldt-Jacob Disease (CJD) the human form of the disease. Since then, a range of monitoring, control and analysis measures have been applied to animal products within the human food chain, as well as health regulations applied to animal by-products not destined for human consumption. Not all EU countries have the same density of carrion-feeding birds as Spain, France, Portugal, Italy or Greece, and these hygiene measures did not consider the possible impact on these species, which depend to a great extent on livestock carcases. Obeying these rules has entailed serious consequences for the majority of carrion-feeding birds, with the disappearance of their main food source. In this report we discuss Member States´ commitments to livestock management and the conservation of carrion-feeding birds; the existing conflicts between both commitments; the current status of the relevant bird populations; the impact of the new regulations; and some possible solutions.

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3. Evolution of BSE BSE belongs to the group of diseases known as Transmissible Spongiform Encephalopathy’s (TSE) which affect a range of animal species and some may even occur amongst humans. The first TSE classified as such in the UK was scrapie in 1986, which had already been known for centuries (the first case of scrapie was noted in 1792) and is not harmful to human beings. It is a disease of sheep and was probably the source of the disease spreading among sheep via contaminated feed. However, in 1985 the first cow with symptoms of convulsive, uncoordinated muscle movements died on a UK farm. Several investigations identifed it as BSE: the first case in Europe. In the 1990s this disease spread to mainland Europe, involving up to 37,000 cases between 1991 and 1992 (compared with 100,000 cases in Great Britain in 1993). In 1995 the first related human death was recorded due to infection with a variant of Creutzfeldt-Jacob Disease, followed by two further deaths in the UK. In 1996 a further variant of CJD emerged and the ten CJD deaths recorded thus far were linked to the consumption of BSE-infected beef or beef offal. This news provoked profound public concern, and was followed by urgent controls over cattle, starting with the ban on exporting beef products from British farms or importing them into other European countries. On October 1st 2000 the rule requiring the withdrawal of high risk sheep materials (brains, tonsils, spinal cord, etc) came into force in Europe. In November that year the first Spanish case of BSE was detected on a farm in Galicia, in northwest Spain, and the importation of cattle from France and Ireland was suspended. In the light of this situation, several new measures were introduced, such as surveillance and analysis of all sheep entering the food chain and the extension of the prohibition on the use in livestock feed of powders derived from mammal meat and bones. From the first case of BSE detected in Spain in 2000, the incidence of the disease rose until 2005, when it started to decline thanks to preventative measures. Knowing that the infection source was infected mammal powder, its removal and destruction prevented new outbreaks, with the only new cases being those due to parental transmission. From the appearance of this disease and distribution of the cases in 2000-2005 onwards, it is known that most BSE cases arose amongst animals born between 1995-1998. The peak in infected calves was in 1997 (see Figure 1), with few cases in calves born after this period. The disease peaked in 2002- 2004, corresponding to the late 1990s peak of infected calf births, but with a decreased incidence from 2005 on, leading to the disease`s disappearance on the cattle farms within a few years (Report from Spanish Ministry of Agriculture).

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4. Current status of carrion-feeding bird populations in the Iberian Peninsula

a. Carrion-feeding birds in the Iberian Peninsula

The Iberian population of carrion-feeding birds is distributed between three EU countries: Spain, Portugal and France (north side of the Pyrenees). The remaining main EU populations, found in Greece and Italy, are geographically isolated and comprise considerably fewer species. The Iberian Peninsula hosts the highest concentrations of these birds in Europe. Its location in the southeast of the Paleartic Occidental is of enormous significance for its bird fauna thanks to its migration routes, winter resting places and its outstanding importance for many endangered species in Europe. Along with its different bioclimatic regions, marked by diverse seasonal climates which support a wide range of habitats, and its strategic situation between Africa and Europe, the Peninsula hosts a huge biodiversity compared to the rest of European continent. It is of crucial importance for the conservation of carrion-feeding birds. For most species it hosts 50% of the European population. For example, 98% of the European population of Black vulture (Aegypius monachus) can be found in Spain. For Griffon vulture (Gyps fulvus), the figure is 94%, for Egyptian vulture (Neophron percnopterus) 82%, and for Bearded Vulture (Gypaetus barbatus), 66%. Furthermore, it hosts one third of Europe´s nesting population and almost the entire European winter population of Red kite (Milvus milvus); the second most important European nesting population of Black kite (Milvus migrans); the first of Golden eagle (Aquila chrysaetos) and the whole population of Spanish Imperial eagle (Aquila adalberti).

Figure 1: Outbreaks of BSE per year of birth (Spain)

0 20

40

60

80

100

120

140

160

1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

Year of birth of infected animals

Cases

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Portugal hosts the Iberian Peninsula`s remaining population of carrion-feeding birds. North of the Pyrenees, France hosts the second most significant populations of Griffon vulture, Egyptian vulture and Red kite. As Figure 2 shows, carrion-feeding birds are found throughout most of the Iberian peninsula.

Figure 2: Distribution of carrion-feeding birds in the Iberian Peninsula (Spain,

France and Portugal).

This report considers all of the strict carrion-feeding species (Griffon vulture, Black vulture, Egyptian vulture and Bearded Vulture) and four facultative carrion feeders (Red kite, Black kite, Golden eagle and Imperial eagle). The European significance and restricted distribution of these populations of carrion-feeding birds is reflected in their inclusion in 14 ongoing LIFE projects in Spain; 8 of these, which focus specifically on carrion-feeding birds, have a combined budget of approx. €8.5m. Their conservation needs are reflected in a further 7 LIFE projects not specifically designed for them. All of these species are included in Annex I of the Birds Directive. Thus, they should be subjected to special conservation measures (including Special Protection Areas for

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birds) with the aim of guaranteeing their survival and reproduction within their area of distribution. Moreover, in the light of the Birds Directive, Member States are required to take specific appropriate steps to avoid habitat deterioration and the necessary conservation measures corresponding to the ecological requirements of these species. Of course, guaranteeing these birds´ food resources is one of the basic requirements for ensuring their survival and reproduction. Carrion-feeding birds feed on other animals´ carcases, fulfilling an important ecological role. Eliminating these animal remains makes them absolutely indispensable for completing the trophic chain and for helping to avoid the spread of disease amongst wild and domestic animals. They are legally protected species which in some cases are in serious danger of extinction (see Table 1).

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EUROPE SPAIN FRANCE PORTUGAL

Species

Nº of pairs (Data BiE)

SPEC

Status

Nº of pairs Data of the last

surveys

Category of

threat

Nº of pairs (Data BiE)

Category of

threat

Nº of pairs (Data BiE)

Category of

threat Black kite (Milvus migrans) 64000-100000 SPEC 3 Vulnerable

9000 NT 22500-26300 AS 800-1600 LC

Red kite (Milvus milvus) 19000-25000 SPEC 2 Declining 1900-2000 EN 3000-3800 AS 50-100 CR Bearded Vulture (Gypaetus barbatus)

610-1000 SPEC 3 Vulnerable 81 EN 40 E - RE

Egyptian vulture (Neophron percnopterus)

3500-5600 SPEC 3 Endangered 1300-1500 EN 69-75 V 83-84 EN

Griffon vulture (Gyps fulvus)

19000-21000 Non-SPEC Secure 22500 589-639 R 267-272 NT

Black vulture(Aegypius monachus)

1800-1900 SPEC 1 Rare 1600 VU 8-10 V 0-5 CR

Spanish Imperial eagle (Aquila adlaberti)

175-180 SPEC1 Endangered 216 EN - - 1-3 CR

Golden eagle (Aquila chrysaetos)

8400-11000 SPEC 3 Rare 1400 NT 390-460 R 46-48 EN

Table 1: Population and threat category for carrion-feeding birds in Europe and the Iberian Peninsula; Spain, France and Portugal.

For Europe, France and, Portugal, data are numbers of pairs published in Birds in Europe II (2004) For Spain the data are numbers of pairs from the published information for each species in recent years ( see Annex 1) CATEGORY of THREAT: Spain: Libro Rojo de Aves en Espana; Portugal: Livro Vermelho dos Vertebrados de Portugal; CR: Critical Endangered, EN: Endangered , VU: Vulnerable, NT: Near Threatened, LC: Least Concern, DD: Data Deficient, RE: Extinct at regional scale, EX: Extinct, Ne: Not Evaluated Francia: Oiseaux menacés et à surveiller en France; AP: A Préciser; AS: A Surveiller; D: Déclin; DI: Disparu; E: En danger; L: Localisé; N: Nouvellement installée; NE: Non Evaluée; R: Rare; S: Safe; SS: Stable ou en progression; SX: information insuffisante; V: Vulnérable

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b. Feeding strategies of carrion-feeding birds

The main food source of carrion-feeding birds is animal carcases in the wild (whether of domestic livestock or wild species), or carrion dumps (´muladares´) for domestic stock. According to scientific studies in Spain, dead livestock remains constitute, on average, 40-60% of the diet of these species. In certain regions this rises to 80-90% for some species

i. Feeding ranges

Few studies have determined the feeding ranges of carrion-feeding birds. There is some information for Griffon vulture, where various surveys have detected movements of at least 50-70km (straight line distance) from the colony to feed (Donázar, 1993). These birds range over vast areas, including the ranges of other colonies. Surveys of similar species in other countries have shown even longer distances Following the overall tendency of birds of prey, the feeding range increases exponentially with the bird´s weight, so the bigger species require vast areas (Donázar, 1993). Knowing the Griffon vulture’s distribution in the Iberian Peninsula and estimating a feeding range of about 50km radius around each colony, the species´ potential feeding range for the whole peninsula can be estimated. Taking into account the number of individuals living in each breeding colony and overlaps of potential feeding ranges, the number of vultures using this area has been estimated. The outcome is that, in the Iberian Peninsula, with such a high population density, practically all of the land surface may fall within the feeding range of vultures (Figure 3).

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Figure 3: Estimated occupation of Griffon vulture’s feeding range in the Iberian Peninsula

(with circles of differing colour intensity according the number of individuals which would use the same area)

c. The role of “muladares” in the diet of carrion-feeding birds

The food available at muladares has been one of the factors in the conservation and recovery of populations of carrion-feeders. This is especially the case for the Black vulture, which several years ago was nearly extinct. The current dependency on muladares is the result of a long process in which the birds have been substituting natural food sources stemming from wild mammals, big and small, for sources derived from livestock rearing and its by-products (Sunyer, 1992). These birds have adapted from exploiting the carrion of numerous wild ungulates (Houston, 1983) towards feeding on that from extensive livestock rearing, where human interference increasingly substitutes food availability distributed throughout the territory for specific areas located where most animal deaths occur. It is then when specific carrion dumps appear, acting in effect as feeding stations, often near to villages, where the livestock carcases are disposed of (Donazar, 1992).

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These “muladares” have undergone substantial changes as a result of ever stricter hygiene measures. However, it was not until the emergence of diseases like TSE, with the severity of the associated control measures, that carrion-feeding birds´ nutrition began to suffer. 5. Member States´ obligation to collect livestock carcases In order to control the removal and processing of animal remains, in 2002 the European Commission approved Regulation (CE) 1774/2002 which established hygiene rules for animal by-products not destined for human consumption. This regulation and its entry in force in the affected countries meant, amongst other things, restrictions on disposing of carcases in the wild. This regulation controls the collection, transport, stocking, handling, processing and use or disposal of animal by-products with the purpose of avoiding any risk to human or animal health. It includes a range of restrictions on the use of these materials and requires the collection, transport and destruction of all materials belonging to the categories 1, 2 and 3, which include whole animals, animal parts, and derivatives or remains considered to be high-risk. The materials in category 2 form an essential part of the diet of carrion-feeding birds: “dead animals not destined for human consumption”, i.e. all livestock that die on extensive livestock farms and are disposed of in the wild or in “muladares”. Thus, EU livestock farmers have been urged to withdraw and destroy all carcases not destined for human consumption by means of new systems of collection, specially created in order to comply with this regulation. Only in those remote areas to which these collection systems do not have any access is it permitted to maintain the traditional methods of in situ disposal. However, despite these exceptions, carrion-feeding birds are struggling to find enough food to survive. Faced with the evidence that these measures harm European carrion-feeding bird populations, two subsequent European Commission decisions (2003/322/CE and 2005/830/CE) allow certain EU Member States (Greece, Spain, France, Italy and Portugal) to establish feeding stations for carrion-feeding birds, as long as there are strict hygiene controls, for the following species: a) Griffon vulture, Bearded Vulture and Epyptian vulture, in the case of Greece; b) Griffon vulture, Black vulture, Egyptian vulture, Bearded Vulture, Spanish Imperial eagle, Golden eagle, Red kite and Black kite, in the case of Spain; c) Griffon vulture, Black vulture, Egyptian vulture, Bearded Vulture, Red kite and Black kite in the case of France;

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d) Griffon vulture, Bearded Vulture and Golden eagle in the case of Italy; and e) Griffon vulture, Black vulture, Egyptian vulture and Golden eagle in the case of Portugal. These feeding stations must satisfy a range of conditions. For example, they must form part of a specific, authorized conservation programme for several species, and they cannot be used as a means of disposing of specified high-risk material or ungulates with TSE risk. In fact, a range of periodic laboratory analyses must be carried to check for the occurrence of TSE. Furthermore, the various responsible authorities must coordinate their activities; the authorization for the feeding station must be officially registered with a description of its geographical location and the species involved; the area concerned is to be prepared, closed off and fenced in order to guarantee that no carnivore, except birds, has any access to the food; regular, TSE-free supplies of cattle older than 24 months and goats older than 18 months are to be guaranteed; and records must be kept of, for example, the number, the nature, the approximate weight and the origin of the animals disposed of, and the outcome of associated TSE tests. It is apparent that, despite the approval of these measures, strict compliance with them has led to the closure of numerous feeding stations and a ban on abandoning livestock carcases in the wild. In reality, this has meant a considerable reduction in the number of dead animals available for birds and other carrion-feeding species. 6. Member States´ obligations to conserve carrion-feeding birds The EU Birds and Habitats Directives were approved in 1979 and 1992 respectively, in order to protect and ensure the survival of wild bird species and their habitats, as well as other species which depend on carrion for their survival. Article 4(1) of the Birds Directive states that the species listed in Annex 1 (which includes all of the carrion-feeding bird species to which this report refers) must be subject to conservation measures in their habitat in order to ensure their survival and reproduction within their areas of distribution. Article 4 also obliges Member States to take adequate steps to avoid pollution and habitat deterioration in the respective protected areas as well as disturbances which could affect the birds. Article 4 of the Birds Directive is therefore particularly relevant to the purpose of this report. The same directive also requires Member States to take steps to avoid pollution and deterioration of bird habitats outside the protected areas. Articles 11 to 16 of the Habitats Directive also oblige Member States to monitor the conservation status of protected species and habitats.

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Bearing all this in mind, Member States are obliged to take as many measures as may be required to protect and ensure the survival of wild species and their habitats. In the case of carrion-feeding birds, adequate food resource management (in particular, livestock carcases and other by-products) is essential if these species are to be able to feed properly. As food availability clearly represents one of the most vital needs of the birds, Member States must guarantee their food supply if they are to fulfil their obligations for the conservation of carrion-feeding birds under these directives. 7. The incompatibility of these commitments The legislation currently in force, from Regulation (CE)1774/2002, subsequent Decisions, their transposition into Spanish national law and recently approved local decrees in many Spanish autonomous regions do not take acknowledge the reality of the of the food requirements of carrion-feeding birds. This new legislation prohibits the abandonment of dead livestock in the open countryside, as well as in feeding stations which do not comply with the specific rules. All this entails serious problems for carrion-feeding birds which rely on this important food resource. This has resulted in a situation in which there is neither a proper management of dead livestock in intensive and extensive livestock farming, nor are the needs of carrion-feeding bird populations being taken into account. As a result, a controversy has arisen over the conflict between meat hygiene legislation designed to control animal by-products and that designed for nature conservation. The two sets of legislation are demonstrably incompatible, at list in the Iberian Peninsula. In the first instance, Article 23 of Regulation (CE)1774/2002 mentioned as an exception the feeding of birds of prey and wild animals with animal by-products of category 2 and 3, but it didn’t specify under which circumstances and how this feeding can take place. As a result, the setting up of recognised feeding stations has been regarded as the only legal solution for the food supply of carrion-feeding birds, without considering in any of the successive regulations the possibility of leaving livestock carcases in the open countryside, not even those of animals free of TSE, e.g. sheep and goats younger than 18 months old, cows younger than 24 months, pigs, horses, rabbits or poultry. The problem developed as a result of the imposition of a series of strict conditions which are, in many cases, difficult to comply with and which do not resolve the situation. Only very restricted types of animal remains where authorized for disposal in

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the “muladares”, ruling out products containing specified risk material (SRM) and thus the majority Spanish livestock. Decision 322/2003/CE included the possibility of leaving carcases at feeding stations, but only if they where proven to be TSE-free. This make it impracticable to dispose of animal remains at feeding stations as beforehand as SRM (e.g. spinal columns and brains) had to be tested by an official laboratory, and once proved to be disease-free, the carcase, which has in the meantime had to be kept safely refrigerated frozen for an extended period of time, could be taken to the feeding station. This process involved very considerable effort, time and expense for livestock farmers. In view of the completely impracticable situation facing livestock farmers, there was an attempt to ease the situation in late 2005, with the endorsement of Decision 830/2005/CE, which modified the earlier Decision in terms of making Category 1 materials available to threatened species of carrion-feeding birds in Mediterranean countries. This Decision included an important measure for carrion-feeding birds as it allows the disposal of sheep and goats containing SRM as long as at least 4% of the livestock destined for this purpose can be shown to be TSE-free. These new changes appeared to be an advance and to ensure the maintenance of carrion-feeding bird populations. However, bearing in mind (a) the need to prove the absence of TSE in at least 4% of sheep and goats (which is not feasible for many herds); (b) until very recently, the lack of a reliable means of distinguishing scrapie from BSE; and (c) the ban on abandoning livestock in the wild, it is clear that the real needs of carrion-feeding birds have still not been addressed. Moreover, the rules established for running feeding stations are in many cases impossible to comply with, so many muladares have been shut down. Furthermore, as well as making it difficult to comply with the EU nature conservation directives, the measures adopted for managing livestock by-products not eligible for human consumption are inconsistent with the EU commitment to halt biodiversity loss and restore habitats and natural systems by the year 2010. In the Iberian Peninsula the maintenance of carrion-feeding bird populations based solely on feeding stations is inadequate for the following reasons:

a. Reduced food availability

In the light of the likely impact of Regulation (CE)1774/2002, especially in those Member States such as Spain with a high density of carrion-feeding birds, two EU Decisions established the possibility of setting up a network of carrion feeding stations.

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However, the real effect of these Decisions was not what was expected. At least in areas such as the Iberian Peninsula, which hosts more than 50% of the European population of carrion-feeding birds, present food availability does not meet the birds´ real needs. Calculating the number of feeding stations which would be needed to support current carrion-feeding bird populations, together with the amount of food that would be needed for this network throughout the Iberian Peninsula, it is obvious that it would be unfeasible to set up and maintain a network of feeding stations that would meet the needs of carrion-feeding birds in areas where they reach high population densities.

i. Number of feeding places As the carrion-feeding bird population reaches 120,000 individuals in the Iberian Peninsula and considering that, on average, one feeding station would be needed for every 40 birds (taking into account that there will be some areas where Bearded Vulture is present in lower numbers and others where Griffon vulture colonies host higher numbers), the outcome is that it would be necessary to set up a network of 3,000 feeding station, as well as needing to know:

- The best places to locate them whilst also bearing in mind the density of individuals.

- Their construction or adaptation to the requirements of the legislation. - Identifying the amount of carrion that would be needed to be left at each

station according to the species present and the numbers of birds likely to use that location.

- The maintenance and daily supply of these feeding stations, and the manpower required to do so.

ii. Amount of food that would be needed at feeding stations

It has been calculated that one adult Griffon vulture in captivity requires approximately 2.5 kg of food per week in order to gain weight gradually, whilst in the wild, and in the breeding season this would rise to 3.5 kg per week (Mendelsohn and Leshem, 1983). On the other hand, based on the available data, one Griffon vulture needs between 500 and 700g of food on a daily basis, depending on the time of year and climatic conditions (Donázar, 1992). Thus, if the Iberian Peninsula hosts a population of some 70,000 vultures, 35 to 49 tonnes per day, or 12,775-17,885 tonnes per year, would be required to maintain this species´ population. For the Egyptian vulture, with a population of 5,000 birds 365 tonnes and for the Red kite with 35,000 wintering birds, 2,500 tonnes. It should be pointed out that, depending on variations between species and regions, in numerical terms, sheep, goats and pigs (Camiña, 1995, 1996, 2001b) are the main food

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source for these species, although, in terms of biomass, cattle would represent the most important source of livestock remains for carrion-feeding birds (Camiña, 2001a).

iii. Distribution of feeding stations

All these species are widely distributed, occupying the majority of the Iberian Peninsula. For instance, in Spain the Griffon vulture breeds in 35 out of the 50 Spanish provinces and in 12 out of the 17 autonomous regions. The Egyptian vulture breeds in 36 provinces and the Red kite over winters in 31. In other words, of the 8,078 Spanish municipalities, these carrion-feeding species are found in a total of 6,664s, i.e. 82.5%. Taking into account the overall area covered by these species, out of the 498,480km2 of peninsular Spain plus the Balearic Islands (without The Canary Islands, Ceuta and Melilla), the carrion-feeding species occupy 313.900 km2, 63% of the total territory. For the Griffon vulture, one of the species most affected, and of which 98% of the European population is in Spain, the potential feeding range is 373,553 km2, i.e. 75% of the peninsular territory would be potentially relevant for the setting up of feeding stations. As already stated, it appears that the amount of food needed to maintain populations of vultures and other facultative carrion-feeding birds on the Iberian Peninsula, would be unfeasible to provide via feeding stations, due to the large populations of these species in this part of Europe, even more so given their very wide distribution which covers most of the peninsular surface. It is therefore possible to conclude that it is totally impracticable to maintain a network of carrion feeding stations in order to maintain these populations. Thus, considering what would be needed to maintain such a network for these species, it would be costly, difficult and impracticable.

b. The increasing risk of other threats

i. Sanitary risks in terms of the treatment with these species at the feeding

spots If, despite the difficulties already described, it was possible in the Iberian Peninsula to establish a network of feeding stations for carrion-feeding birds, a number of health risks may arise. For example, the massive gatherings of birds that would take place would increase the risk of disease transmission between birds. Furthermore, given the far heavier reliance on high concentrations of carrion from livestock (as birds would roam less looking for food and become more attached to fixed feeding stations), and increasing use of veterinary treatments and zoosanitary products, there would be an

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increased risk of mortalities or illness due to bioaccumulation or directly toxic effects. This phenomenon was recently reported in India and Pakistan, where a huge number of Asian vultures perished after feeding on cattle carcases previously treated with diclofenac (http://www.birdlife.org/news/news/2005/03/diclofenac.html). The use of pharmaceuticals in animals has been the cause of mortality among numerous endangered species, with cases of poisonings from feeding on carcases of animals previously treated with these chemicals. There would also be an increased risk of conservation problems if there was a poisoning episode at a major feeding station used by hundreds of birds, due to the sheer numbers of birds which could be lost.

ii. Further threats In the event of reducing the number of places where these birds can feed, they would be very likely to range more widely in search of food. This would increase the risk of deliberate poisoning, collision or electrocution with electricity cables or wind-farms, increasing threats which are responsible for hundreds of vulture mortalities each year. In Spain, poisonings, collisions and electrocutions make up more than 70% of the mortalities of Imperial eagle, Red kite and Egyptian vulture by other than natural causes.

iii. Possible changes in distribution If the number of feeding opportunities is reduced, carrion-feeding birds might alter their distribution, influencing their reproductive success and even, possibly, the ornithological value of SPAs created for the purpose of protecting some of these species (possibly leading in the short term to the SPA losing its legally-established ornithological value). Furthermore, these birds would not enjoy the legal protection of the protected area if they were forced to use other areas not included in the Natura 2000 network . 8. Impact of the legislation on the carrion birds on the Iberian Peninsula The main impact of Regulation (CE)1774/2002 on carrion-feeding bird populations has been the notable reduction of food availability in the wild. Until now, the practice of abandoning livestock where they die has been of considerable benefit to these species. The other possibility for livestock farmer was to leave the carcases at muladares, as already described.

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With the arrival of the new legislation, the first effect was the removal of the option of leaving dead animals in the wild as carrion. After that, the authorities approved a range of measures controlling muladares, so that they could continue to operate. However, non-compliance with this legislation led to the closure of numerous muladares, and the setting up of different carcase collection systems in each autonomous region, which were occasionally financed by the public authorities. Furthermore, the application of this legislation has not only had serious consequences for carrion-feeding, but has also involved a range of difficulties for cattle farmers, who were also opposed to the new controls. For them, not being able to leave livestock carcases in the wild and having to use a collection system exclusively set up for this purpose have considerably increased their expenses. Small farmers with low incomes very often lack the financial means to absorb these additional costs. Difficulties have also increased in the sheep and goat sector, already in a critical state, with ever more herds disappearing from many villages. The important consequences of this legislation for livestock farmers include:

- Risks to farm biosecurity: Farm to farm carcase collections endangers livestock health through the increased risk of disease transmission.

- Higher production costs: The carcases have become an additional expense for the farmers to add to their existing running costs.

- Extensive farms with livestock in remote areas: In areas with difficult access, carcase collection is complex or almost impossible. The cattle farmer might not visit these areas for days, with the stock left to range freely for extended periods. In these situations when an animal dies, it may be virtually decomposed by the time the farmer next arrives. Thus, it is not possible to comply with the Regulation.

Initially, the disappearance of food for carrion-feeding birds was not that obvious, despite the early warnings of ornithologists and scientific specialists. But during the last year this situation has not only become self-evident but other evidence has also emerged, such as decreasing productivity, changes in the species` behaviour patterns, or rising numbers of animals admitted to animal rescue centres showing signs of starvation. All this has merely confirmed what was expected at the outset and has left no doubt about the current critical situation for these birds. Some of them are in serious danger of extinction, as already stated.

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a. Reduced productivity There are no studies of the productivity of the whole vulture population of the Iberian Peninsula. However, one of the most significant Griffon vulture colonies in the centre of the Peninsula has been monitored and studied by WWF/Adena for more than 10 years in “Las Hoces del Río Riaza” (Segovia, Spain), and published recently by Melero (2006). Thus, it might give a good indication of what is happening to the rest of this species´ population. In general terms, in these ten years this particular vulture population has been increasing. However, considering recent years´ surveys and breeding productivity since the approval of Regulation (CE) 1774/2002, the reduction of available food in the areas adjacent to the colony has indeed had an impact on this population, an effect which may be extrapolated to other colonies. In the same colony, again based on the data of Melero (2006), the reduced food availability is reflected in fewer breeding couples and lower reproductive and fledging success compared to previous years. In this area a system of carcase collection for incineration has been introduced. As a result, the adjacent farms of Las Hoces where until recently major vulture gatherings were observed (for instance, the pig farms of El Alto de Milagros or of Santa Cruz de la Salceda), are now required to remove dead animals for incineration without being able to leave them at the former feeding stations. Thus, the local vultures` food supply has virtually vanished. As a breeding pair of Griffon vultures requires some 500 kg carrion a year, the vulture population in the Las Hoces del Riaza area would need about 225,000 kg of carrion. The Las Hoces colony has benefited from two feeding stations, one at Montejo de la Vega within Las Hoces, and the other at El Campo de San Pedro, in its outskirts. However, the amount of carrion left at Montejo during the last three years (30,260 kg in 2004, 25,880 kg in 2005 and 45,670 kg in 2006) has only been enough to meet between 10-20 % of the total yearly needs of the Montejo colony. Thus, the other feeding locations seem to have been vital both to the high reproductive success in earlier years, and to the progressive growth of the colony throughout the last three decades (Melero, 2006). In Sierra Salvada (Basque Country), the Griffon vulture population has been studied since 1997 and vulture numbers have increased from 60 pairs in 1997 to 137 in 2006. Nevertheless, this colony`s productivity has been influenced in recent years by a distinct drop in food availability. Thus, in 1999 the colony showed a breeding success rate of 75%, in 2001 of 82 %, whereas in 2006 only of 55 % (Pérez de Ana, 2007).

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b. Changes in behaviour patterns

According to those who monitor and observe carrion-feeding bird species, one of the first consequences of the new legal regime appears to have been a series of behavioural changes due to the disappearance of their traditional feeding sites and the consequent lack of food. Unusual behaviour patterns included vultures gathering in new locations, on the ground, in trees or even on the roofs of inhabited areas adjacent to former feeding stations. Several observations from 2006 demonstrate the conspicuous food shortage these birds are suffering. For example, at Montejo de la Vega the vultures rarely used to enter the feeding area until the person delivering the carrion had left. However, more recently the vultures have been observed waiting at the edge of the feeding station then moving directly onto the carrion to feed before the delivery driver has even lowered the lorry’s skip, ready for departure. A further example that has alarmed hunters and gamekeepers is the fact that in recent months vultures have started to approach the fallen quarry (e.g. deer) as soon as it has been shot down. The normal procedure would be that once the shot animal has been gutted and cleaned, theses remains would be left out in the open for the carrion feeders. Now, the vultures approach the shot animals faster than the hunters, often spoiling the pray which is leading to new conflict between hunters and vultures. These changes in behaviour have also been observed in other areas of Spain, as in Aragon where the situation was even worse last year, as vultures are attacking live livestock, normally sick, immobile animals or newly-born young. This is provoking major concerns among the region’s farmers. The Ligue pour la Protection des Oiseaux (LPO/BirdLife) has informed SEO/BirdLife that there is proof of numerous individual Griffon vultures, especially young birds originating from Spanish colonies, crossing the Pyrenees and ranging as far as the French Massif Central in search of food.

c. Rising admissions to animal rescue centres Normally, carrion-feeding bids are only occasionally admitted to wild animal rescue centres, with the main reasons for admission being electrocution, some kind of injury, or, more recently, collisions with windmills. In hunting areas, numbers of admissions are increasing due to the consumption of poisoned bait. It is also frequently the case that in the post-fledging dispersal period, young birds end up in rescue centres due to semi-starvation, dehydration or some sort of infection, as the dispersion period coincides with the hottest and driest period of the year when food and water become scarce.

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However, in the last few years in Spain the figures of hospitalized carrion-feeding birds showing signs of starvation symptoms have been rising in all autonomous communities. Analyzing the available information on admissions to rescue recovery centres around Spain demonstrates the serious food shortages that carrion-feeding birds are suffered from in the wild.

Castilla La Mancha (España)

0

5

10

15

20

25

30

35

En Feb Mar Ab May Jun jul ag sept oct nov dic

200420052006

Monthly totals of carrion-feeding birds admitted to wild animal rescue centres in Castilla La Mancha, 2004-2006.

Causas de entrada en los centros de recuperación de Castilla La Mancha

TraumaElectrocuciónIntoxicaciónDesnutriciónEnfermedadOtro Desconocido

Causes of Griffon vulture admissions at the different wild animal rescue centres in Castilla La Mancha during 2006.

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Aragón (España)

0100200300400500600700800900

1000

2004 2005 2006

Number of carrion-feeding birds (Egyptian vulture, Griffon vulture, Black kite, kite and Bearded Vulture) admitted to the rescue centre at La Alfranca (Aragón, Spain).

Number of carrion-feeding birds admitted to the rescue centre at La Albufera (Valencia, Spain).

d. Scientists express their concern at the impact of the EU Regulation

Individual scientists and meetings of experts and ornithologists have drawn attention in their publications, conference summaries or working group conclusions to the problem of reduced food availability for carrion-feeding birds as a result of the EU legislation. Thus, at the VI World Conference on Birds of Prey and Owls in Hungary in 2003, the Birds of Prey Workshop published the following resolution:

Valencia (España)

0

5

10

15

20

25

30

2000 2001 2002 2003 2004 2005 2006

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Resolution of the VI World Conference on Birds of Prey and Owls

WHEREAS carrion-feeding raptors rely heavily on carcasses from domestic livestock for their survival;

ACKNOWLEDGING widespread concern over various human diseases (such as bovine spongiform encephalitis) and the need to eradicate these diseases;

ALARMED that the currently existing carcass-disposal arrangements within the territory of the European Union (Regulation 2002/1774 and subsequent decision 2003/322/CE) are impossible to put into practice (both technically and economically);

AWARE that carrion-feeding raptors often perform a major service in eliminating otherwise undetected carcasses;

URGES all countries worldwide where both breeding and foraging areas of carrion-feeding raptors occur to create a feasible legal framework to ensure the continuous feeding of these birds, the maintenance of extensive livestock keeping, and the establishment of feeding stations as a management tool in areas where this management technique is necessary. Numerous conservation groups, NGOs and scientists continue to demand a resolution to the problem created by this regulation, as it is totally incompatible with the conservation of carrion-feeding birds.

e. Other threatend carrion vertebrates

Birds are not the only wildlife threatened by the disappearance of carcase feeding opportunities in the countryside. Other vertebrate species, in particular mammals, such as wolves, brown bears or foxes, also rely on this resource for their survival. Thus, one bear protection group states its position as follows: «Bears mainly need three things to survive: shelter, freedom from disturbance, and food. If there is no carrion left in the forests and mountains, we are having a negative impact these animals´ feeding opportunities, especially in a period which can be critical since in springtime the bears leave their shelters in search of protein and they are confronted with a habitat without this food source, prompting them to look elsewhere.» For all of these carrion-feeding species the lack of the food required for the survival of adults and the weaker and more vulnerable younger generations, is a serious problem as these animals are failing to meet their basic survival needs. Moreover, this situation is causing other indirect problems, as for example in the case of bears which seek sustenance in commercial beehives. This has generated considerable economic losses for beekeepers.

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9. Possible solutions As this report has demonstrated, in the Iberian Peninsula (including parts of France) it is impossible to reconcile the present BSE hygiene regime with obligations for the conservation of carrion-feeding species arising from the Birds and Habitats Directives. Therefore, the BSE legislation should be revised so that the requirements for biosecurity and the conservation of these species can both be met. This revision should take into account following possible solutions:

1) Define Special Activity Zones for Carrion-Feeding Birds

Priority areas should be established within which the priority measures proposed below would be applied. These are largely areas included in the Natura 2000 network.

2) Allow exceptions to the compulsory removal of livestock carcases in areas

under extensive management which do not involve Specified Risk Material (SRM)

This involves “Category 2 by-products” such as carcases of free-ranging pigs, horses, mules, asses and birds which do not involve specified risk material

3) Allow exceptions to the compulsory removal of sheep and goat carcases so that

they can be disposed of naturally The carcases of small ruminants, and especially of sheep, are of particular importance for the conservation of carrion-feeding birds in the Iberian Peninsula. Despite the enormous effort made by Member States to detect BSE in small ruminants, examining more than 1.5 million animals between 2000-2006, it has only been detected in one goat reared in France. There are also three disputed cases in sheep, which are being studied by the EU Community Reference Laboratory. The Route Map for TSEs of DG-SANCO of the European Commission includes as a strategic objective for EU policy on TSEs more flexible control measures for small ruminants than those established in Regulation (CE) 999/2001. For example, in Spain BSE has NEVER been detected in sheep or goats, despite enormous epidemiological screening efforts and even though all animals diagnosed with scrapie have undergone discriminatory testing for BSE. Furthermore, the prevalence of scrapie in Spain is extremely low, as is demonstrated by the fact that only 107 foci were detected in the period 2000-2005. In 2005 73,203 rapid tests were carried out and only 38 foci of scrapie were declared, which is a TSE NOT a zoonosis and BSE has never been detected

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in sheep in Spain. In any case, BSE is not a contagious disease as the only transmission route with any epidemiological relevance10 is the ingestion of material contaminated with prions and thus there would never exist a risk of horizontal transmission between carrion-feeding birds. In such circumstances, it seems UNACCEPTABLE that the carcases of small ruminants in Special Activity Zones for Carrion-Feeding Birds can not be subject to an exceptional measure which would provide exemption from the need for compulsory carcase removal and would instead allow fallen stock to remain in the countryside without the need for their transfer to muladares and without the need for 4% of them to be analysed according to Annex III of Regulation (CE) 999/200111, as was the case until the publication of the current legislation. The legislation should consider what the minimum permissible distances to relevant human populations are in order to allow the abandonment of carcases in the countryside.

4) Allow exceptions to compulsory carcase removal for extensively-reared cattle younger than 24 months old (free from Specified Risk Material)

This concerns animals without the risk of having developed (and as such, of transmitting) BSE as deduced from the Commission´s Route Map for TSEs. Between 2001-2004 more than 3.5 million cattle younger than 24 months had been inspected and analysed, including sub-populations of healthy animals, animals at risk and dead cattle without having detected ANY cases of BSE12. For this reason the age of compulsory removal of the spinal column of animals slaughtered for human consumption has increased from 12 months to 24 months.

5) Maintenance of the traditional muladares which have been used until now in areas with high densities of carrion-feeding birds

Given the results of the analysis for BSE, there is no reason whatsoever for prohibiting the disposal of dead animals from sheep and goat herds in which the absence of BSE has been proved and which therefore carry no risk of infection for other animals or human beings.

Furthermore, the public authorities should check all appropriate locations for animal disposal, should allow new feeding stations to be set up, and support new legislation which would allow the disposal of dead sheep at these feeding stations and the abandonment of dead animals, at least in countries like Spain and Portugal where BSE cases are almost non-existent, and there are large

10 http://www.oie.int/esp/maladies/fiches/e_B115.htm 11 REGULATION (CE) 999/2001 OF THE EUROPEAN PARLIAMENT AND COUNCIL of May 22, 2001 on which the provisions for the prevention, control and eradication of specific transmissible spongiform encephalopathy are based. 12 http://www.eeb.es/pags/hoja_ruta_EET.pdf

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populations of carrion-feeding birds which, representing the most significant in Europe.

6) Approve the designation of new “farm unit” Feeding Stations Extensive landholdings covering large areas of land are common in the south-west and centre of mainland Spain and are of great importance for the survival of species such as the Black vulture, Griffon vulture or the Spanish Imperial eagle. Having closed perimeter fences, these areas are officially considered for animal health purposes to be separate epidemiological units.

The approval of muladares for these individual management units, to which only animals from the same farm could be delivered, is a measure which has numerous advantages. It would favour the livestock farmer (saving the cost of insurance cover for carcase removal), would be a saving to the public purse (the present carcase collection system is heavily subsidised), reduce health risk (avoiding the collection of carcases with a lorry which visits other establishments) and would have very beneficial effects for the conservation of endangered carrion-feeding bird species

It is predicted that such a system would be very much welcomed by livestock farmers as it would reduce their production costs and at the same time would encourage the dispersal of carrion-feeding birds across the landscape, avoiding any risks associated with concentrating on just a few feeding stations.

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Rocamora G., Yeatman-Berthelot D. 1999. Oiseaux menacés et à surveiller en France. SEOF et Ligue pour le Protection des Oiseaux (LPO/BirdLife). Paris. Sunyer, C., 1992. Importancia de los muladares en la conservación de las rapaces carroñeras. Quercus 78: 14-23. Viñuela, J., Martí, R., Ruiz, A. (eds.) 1999. El Milano Real en España. Monografía nº 6. SEO/BirdLife. Madrid. Web Links: http://ec.europa.eu/food/food/biosafety/bse/index_en.htm http://www.sandach.com.es/ http://www.eeb.es/ http://www.oie.int/esp/maladies/fiches/e_B115.htm. http://rasve.mapa.es/Publica/Programas/Normativa.asp