Natural England Bird Control Licences - A Fundamentally Flawed System?

* Does Natural England's reliance on the 'good practice' of licence holders really work?
* How many licence holders fulfill their obligation to file a report of action taken?
* I've asked Natural England to provide a figure....

How many returns, that is to say 'reports of action taken', are received by Natural England for the thousands of bird control licences that they issue?
Anyone carrying out licensed bird control, that has been approved by Natural England, is obliged under the terms of their licence to complete and submit a return, detailing the action they have taken, including the numbers of birds shot, eggs destroyed etc.

But how many licence holders actually fulfill this obligation? 

"We rely on the 'good practice' of licence holders...."
I was told some time ago by then operations director, James Diamond, that Natural England relies on the 'good practice' of licence holders to act responsibly in filing their returns. 
And there are apparently no significant penalties for those that don't.
Basically it is a system that depends on the honesty and integrity of licence holders, and so it is a system that is bound to fail on occasion.

Public dismay at Starling cull
Recently I uncovered a case where a farmer had been granted licences by Natural England to cull Starlings over a period of at least ten years, in spite of the fact that at one point he had allegedly shot Starlings without a valid licence and that he had apparently failed to submit the obligatory return for at least one year.
This case raised many questions about just how widespread the misuse of licences really is. When I broke this story, there was much public indignation and many people contacted me to express their dismay that this could have happened.
Doubts over the competence of Natural England seem to be growing.

The question of licence returns....
A few days ago I asked Natural England's Director for wildlife licensing  if he could provide me with details of how many returns had been received by Natural England for bird control licences that were issued during the year 2018-19.
In other words, I want to find out what percentage of licence holders do actually submit their returns.
It's a fairly straightforward way of assessing the credibility of the process. 

At the time of writing, I am still awaiting a reply. Perhaps the figures are not readily to hand, or maybe Natural England would rather we didn't know...
But I will pursue this information as I think it is in the public interest to know how watertight the licensing system is in practice.

My hope, of course, is that the vast majority of licence holders do submit accurate returns, on time. 
My  fear is that there may be many who fail to act with the 'good practice' on which  Natural England relies...

​I will update in due course......