Pest Control Procedures Manual

Urban Gulls

April 2015
Contents
1 Effective control of urban gulls 3

2. The urban habitat 4

3. What can be done 6

4. Establishing the scale of the problem 6
5.  Establishment of the management,
intervention action team and resources 7
6 Formulating and action plan 8
7 Use of GIS mapping 9
8 The law on gull control 10
9 
Summary 11

Acknowledgements
Nigel Batten
Richard Bevan
NPAP members
David Oldbury
Geoff Ward

The CIEH would like to thank Killgerm Group for their assistance in producing this booklet.
1 Effective control of urban gulls
Urban Gulls are a growing problem to the 4. Building damage and additional maintenance
environment and public health of our towns and and cleaning Constant aerial droppings mare
cities. Large colonies have now established themselves heritage building and risk damage to paintwork,
in the urban realm and are causing severe challenges flashings other weathering feature. Accumulating
to local authorities throughout the British Isles. Its nesting material and dead birds block gutters and
not a problem confined to seaside towns with many drainage risking floods and dampness in
inland cites miles from the sea. The birds are buildings. The constant effort in scrubbing and
extremely long-lived, 25 years and more, many have cleaning adds to the cost of maintaining a clean
never seen the sea enjoying the urban environment and slip free environment. Gulls are also known to
where there are all the essentials for life. cause extensive damage to buildings by attacking
soft roof sub-straits, glass roof sealants and
The key challenges from urban gulls are as follows:
insulation which covers air condition units. They
1. Scavenging and waste spillage Its likely the have also been known to pick up the pebbles of
city will be operating black bag non-containerised adjacent flat roofs and drop them onto glass
waste collection service for both domestic and atrium roofs and cars. This activity is usually as
trade waste operated with a multitude of consequence of boredom or in the case of the
contractors. Waste spillage causes unsightly stones that are mistaken for possible shellfish. In
refuse scattered around streets and often in any event the hidden costs of constant repair is
numerous locations depending on the population. often not budgeted for.
Waste can be injurious to the public, broken
5. Food safety and health is potentially
bottles, sharp open cans, food spillage and greasy
compromised on retail sites aerial dropping
surfaces contributing to the dangers. Such regular
contamination is possible in food stock unloading
spillages cause other urban pests such as rats,
areas and in restaurants and food manufacturing
mice, flies, pigeons, cats and urban foxes etc to
sites, internal drainage has the potential for
be interested in feeding themselves.
introducing pathogenic bacteria to the food
2. Contaminated objectionable environment production environment. In the home the wheels
Droppings are a consequence of urban gulls and of childrens buggies, bicycle tyres and foot-ware
buildings, street furniture, benches and roads and has the potential of introducing such bacteria
pavement become contaminated sometimes into the living environment.
extremely quickly and in a sustained period of dry
6. Noise nuisance this is the most noticeable
weather considerable unsightly accumulations
cause of complaint in respect to gulls. Early
can occur with consequential objectionable
morning first light awakenings (usually 4.00am),
odour, feathers and detritus. All this has a
disrupt sleep both of city centre residents and
considerable impact to the safe enjoyment of
visitors to hotels alike. Many a leisure break
towns and cities. This is particularly a problem in
weekend has been spoilt to the cost of repeat
cities with considerable al fresco dining where
business. Social media and tourist advisors
diners enjoying their dining experience can be
damages business in some cities.
marred by droppings and attacks for food.
7. Gull attacks many attacks take place from
3. Potential Health Risk Whilst there are few
aggressive and competing birds in the urban
documented cases of illness directly attributed to
environment particularly when they are
gull excreta the birds are known to carry
defending young and after food. Cuts on the
Salmonella, Campylobacter and E coli spp. The
face, neck and hands are not uncommon some
national outbreak of Salmonella caused by
needing attendance at a local casualty
Cadbury Chocolate was traced to the crumb
department. Gulls are also expert in seeking out
factory in Marlbrook. It was known there was a
schools in each borough where they learn the
gull issue on the roof of the factory and the
time of the breaks taken by the children,
investigation concluded, leaking internal roof
particularly in the summer months. Attacks on
drainage into open product ingredients was a
the children can be reduced through
possible cause of the outbreak. These same
management by reducing the areas in which they
circumstances will exist in many food businesses
eat their food to under cover areas only.
in towns and cities throughout the country.
8. Reputational damage this applies to both
Councils and their partners e.g. tourism and the
local economy. Residents, visitors and the
business sector suffer as a result of no action
being taken, sometimes abusive behaviour can be
directed towards council staff.

3
2 The urban habitat
Humans have created an environment which a. Scavenging of the remnants of discarded street
enables the gull to thrive away from its natural food from the night-time and the day time
and expected seaside environment. Sustained year economy. Sometimes the birds will swoop down
on year unchecked breeding has led to the gulls in public areas of alfresco dining and steal food
naturalisation in the urban environment. There is little off plates and from the hands of people
doubt that some cities are more prone to colonisation consuming it. Such behaviour can become well
but it is methods of waste collection, the acceptance established where there is a developing caf
and tolerance of the gull and the ongoing attitude culture and birds can compete and become quite
that little can be done which leads to growth in aggressive in these circumstances. They have
population and long term establishment of large been known to cause injury. As this is one of the
nuisance populations. Key factors which support growing issues which is unacceptable and leads
colonisation include: to calls for bird populations to be removed or
reduced both by food business owners and the
1. A habitat of tall buildings with ledges and public alike.
parapets mimicking their wild habitat of cliffs.
Here they are able to perch and observe the b. Bird Feeding No one can deny these birds often
ground below for feeding opportunities. They can make a spectacular sight swooping and gliding
find comfortable and safe nesting and breeding through the city scape avoiding buses, cars,
sites which might include parapets, next to buildings and street furniture to grab a morsel of
chimneys and valley gutters. Such places are often food it has identified from its keen eyesight.
free from potential disturbance, observation and Locals and visitors alike are often part of the
difficult to access. A further factor in respect to problem, offering the birds a free crust or a few
buildings might well be design. In cities where the chips which they can be confident enough to take
gull and other feral birds are an issue you might from the hand. In parks with ponds and river
expect the design to prevent colonisation by birds frontages birds can be attracted in large numbers
and design to include gull proofing measures but and it can be quite a sight as they are whipped up
It is common that little if any thought of using into a competing frenzy from bird feeding. Food
the planning system to get ahead of the problem traders from market stalls and takeaways often do
is considered. the same with a hand full of chips on the streets
of the city. All such behaviour does is encourage
2. Places to perch, rest, preen and observe their birds to locate and remain near the free and
urban realm which includes the top of lamp readily available food source, growing in numbers
standards, roof ridges and high ledges are a over time.
common sight after the morning feed. It will be
typical to see a build-up of white droppings c. Urban Domestic Waste this represents a key
covering the perch place, down walls and often source of food and encourages over time a growth
splattered at the base of street furniture. in populations. In cities there are challenges in
domestic storage of domestic waste. Many flat
3. Opportunities to scavenge and feed from the dwellers have little storage and store waste in the
many sources of food in the urban and local rural small kitchen bins, shopping bags or black sacks as
environment. They will eat virtually anything and it is produced. Some local authorities collect waste
our discarded food waste seems to be a highly more regularly, perhaps twice each week. Many
nutritious form of sustenance. They will often local authorities require segregation of all waste
move out into the county-side and feed on worms to reduce volumes to land fill. Segregation needs
and grubs on local (and sometimes quite distant) space in itself, not always easy in small living
farmers fields but those tasked with waste space characterised in the often very expensive
collection or control of urban gull populations city centre residential setting. Many authorities
should be under no illusion that there can be more allow refuse to be put out in black sacks, or
than enough urban morsels to sustain Gull segregated into thin plastic shopping bags
populations. If the opportunity for such feeding is without the hard protection of metal or plastic
not restricted then the population will spiral year bins, wheelie bins or communal containers. Where
on year with consequential stress and menace to there is a gull population such collection methods
both businesses and urban residents. Such sources will lead to gull attack, scavenging and scattering
not in any particular order of priority will include: of waste in the public realm. The consequence is
the objectionable appearance of early morning
waste spillage, open mixed food waste on streets
and greasy hazardous pavements for early starters
in our cities. There is danger to the public in
respect to slips, trips and falls, bags are often
dragged into roads and cars and buses will often
swerve to avoid obstructions with consequential
risk to pedestrians and cyclists.

4
 T
 here are a small number of drivers who will Trade waste management poses many challenges in
deliberately target birds feeding on roads, some urban gull reduction plans. Such challenges include:
adults and many juvenile birds are killed that way,
i) There may be fraudulent behaviour with traders
which can certainly not be condoned but is a fact of
doing what they can to reduce volumes and
the human/bird interface in the urban realm. Some
charges. This includes placing unmarked black
of this behaviour stems from bravado but there is
bags amongst domestic waste on domestic waste
evidence that some is as a consequence of the stress
collection days. The nature of the food waste is a
caused by persons who are awoken early because of
good indication this is happening during
the noise nuisance caused when birds start feeding
scavenging and spillage incidents as a resident is
at first light.
unlikely to throw away vast amounts of rice, bar
fruit waste, tomato and salad material and blue
The major challenge here is also collection time.
paper hand wiping material.
Many residents find it more convenient to put their
waste out overnight ready for a collection often early ii) T
 here is less likelihood of segregation of food
in the morning. This will certainly lead to regular waste and larger amounts of food waste proving
availability of food but these premises will be well highly attractive to scavenging birds.
known as spillage will be a regular occurrence.
iii)The competing number of contractors and timings
Other factors come into play here. Increased food of collection can support anti-gull strategy or
wastage and segregation and recycling rates are often hinder it. Where there are numerous options for
lower in city residences. A number of factors contribute service its highly likely that some waste can be
to this. Student accommodation, more takeaway foods missed, leaving it on the streets overnight. Even if
consumed, smaller kitchens and general lifestyle of city the waste is left out for half an hour before
dwellers. It all helps to contribute considerable feeding collection, when the streets are empty of shoppers
opportunities of the gulls. and city visitors the hungry gull will have enough
time to start its work of pecking open bags and
d. Trade/Commercial Waste There is a vast emptying the contents. Having numerous
amount of waste from food businesses including competing firms can be a most difficult control
hotels and guest houses, restaurants and cafes, challenge when attempting to deny birds from this
takeaways, retail stores, offices and other shops. food source.
Often it is removed daily as such premises have
challenges in storing such waste due to lack of Connecting up competing service aims to
space and in terms of the risk of encouraging common goals
pests in a food environment, contrary to good Waste collection has become an engineering activity
food safety practice and compliance. Sometimes and not a pest prevention activity. Where this is the
relatively thin and often coloured plastic sacks case protection of waste before collection becomes
are used. an encumbrance to the speed and economic
collection of waste. This will lead to gull colonisation
They identify the waste to the contractor/service if other factors are present i.e. the right type of
provider collector and such waste is put on the buildings with perches.
streets after premises, often without protection
from scavenging birds and at risk from other
scavenging animals including urban foxes,
pigeons, cats, dogs etc.

5
3 What can be done?
The first consideration is whether there is the political The key to control is reduction in population over time
will or initiative to make a concerted effort to control by denying habitat, denying food sources and
the urban gull. The plan will have to be driven by the environmental discouragement. There are five main
Local Authority and harness the support of local phases;
businesses and the local population. Without the
1. Understanding the scale of the problem
political will and sufficient resources it will not be
possible to have any real impact over time. The 2. Establishing the management, intervention action
population of gulls will continue to grow and the team and resources
problem of the urban gull will be compounded and
expand to a wider area. The politicians will have to be 3. Development of a fully co-ordinated action plan for
in agreement and allocate sufficient resources over a intervention
sustained period if a worthwhile reduction in 4. Implementing the plan
population is to be achieved. The Authority will have
to be careful it does not fall into the research trap 5. Assessment of intervention effectiveness.
where inaction remains the norm whilst waiting for
research or legislative action is awaited. There is
certainly much that can be done with existing
knowledge of the gulls habitat and behaviour and
within the constraint of existing legalisation. Where
problems exist Local Councils have a responsibility to
show leadership and make an effort to grip the
problem.

4 Establishing the scale of the problem

In many cities the population has been steadily Without this information it will be impossible to
increasing year on year leading to an escalation in understand the gull issue and whether interventions
the issues described earlier in this guidance note. It is are working. The information can form an
important to have measurable data in order to qualify intelligence picture which can be used to target
the level of issues being suffered in order to have a control activity and public communication. The
baseline from which any control interventions are Authority needs to be honest and diligent in its
having a beneficial impact. It must be remembered recording and proactive to disseminate it regularly
that gull behaviour and numbers fluctuate and widely in an understandable transparent form.
significantly in and out of the breeding season. The
3. Record on dead birds During each year street
following are suitable parameters which should be
cleansing teams and all those officers must keep a
measured:
record of dead birds collected and date collected.
1. Gull population Every year a census of gull Any complaint from the public or building occupier
population should be undertaken. The number of of dead birds found should also be recorded and
breeding pairs by species needs to be professionally statistics kept for an annual total. In cities with
recorded by an Independent gull/bird expert. large established populations there will be a
Without a baseline assessment of population it is surprising number of road-killed birds both from
impossible to know whether over time the accidental and deliberate action. Many of the birds
population is increasing or decreasing and whether killed on roads will be juvenile birds from that
interventions are having an effect. years breeding season. Some bird casualties will
also be from shooting, especially where there is
2. T
 he number of complaint calls in the following
considerable annoyance to the public. A count of
categories should also be recorded:
dead birds over time adds to the population
Noise nuisance complaints from gulls intelligence picture.
Domestic scavenging of waste incidents
Trade waste scavenging incidents
Gull attacks to members of the public
Social media complaint and interactions
Other gull incidents

6
5 Establishment of the management,
intervention action team and resources

A dedicated officer should be appointed who The team must be qualified, trained and established
co-ordinates all activity, interventions and control with officers and staff which understand the gull
measures. They must have a good working knowledge issue, have the capability to apply interventions and
and have the gravitas and capability of working have the resources for control and media activities.
across the Authority with all departments. They will Staff must be experienced at working at heights, have
need sufficient personnel and resources and the access to all the necessary safety equipment and
Authority Chief Executive must ensure that the team have a good understanding of health & safety. Flat
is empowered to require interventions within each roofs can usually be accessed safely but other roof
department. Only if effective coordination of designs will require the hire of cherry pickers for more
interventions is established will control be possible. difficult locations. They will need to be Authorised
Officers for pest control, waste and litter enforcement
and have access and capability to use GIS mapping.
Resources will include vehicles, office and storage
facilities, access equipment etc. There would also be
an advantage for a good working relationship with
the local Fire Authority which would have access
equipment which might be advantageous for high
access to building and difficult to access locations.

7
6 Formulating and action plan

A key constraint will be the protection afforded to 2. An intervention campaign - in three parts:
some gulls species by the Protection of Wild Birds
1. Waste management Without enclosure and
legislation. Further issues will be the reaction by some
protection of waste from attack it will be
members of the public who misguidedly like and
impossible to prevent attacks on waste,
encourage gulls within the urban environment. Media
whether commercial or domestic. The
attention and reaction can go both ways and defend
Authority needs to recognise the reason why
the status quo. Media messages need to be clear and
their city has a gull problem is the plastic sack
managed effectively otherwise the plan will run into
collection method which has no doubt been
difficulties.
introduced in order to cut cost and time of
The plan should include the Education Authority who collection and to allow residents and
can cascade the messages out to schools. Gulls have businesses ease of storage without bins the
quickly recognised school breaks especially lunchtimes best option.
as a source of food as school children take delight In
(a) Provision of gull proof sacks to residents in all
enticing gulls with food.
badly scavenged streets. Require containerisation
The plan should include measures which seek to work on all other waste outside of the main city area
within the constraints to significantly manage the where space is not so much at a premium.
local population to levels which see a substantial Organise collections such that waste is not put
reduction in complaints and gull issues. This will out overnight.
include:
(b) Trade Waste co-ordinate and control trade
1. A
 n information/media campaign - to include: waste collectors so they support the
management plan not hinder it.
Effective waste management from both domestic and
commercial premises this will require suitable (c) L itter control litter and street food through
containerisation of all or most waste prior to effective containerised bins. Takeaways need to
collection. be engaged to play their part.
Advice not to feed wild birds with a posted and 2. Control on buildings As described above
advertising campaign leaflets in hotels and guest this includes netting, perch denial through
houses and in locations where tourists might take spikes and removal of nests pre-season
note of the request will be important for visitors. This and egg replacement during season
is especially important in parks and by open water
3. N
 ew/refurbished/redeveloped buildings
areas.
In cities with gull populations it is vital to
Use of local radio and cable TV to promulgate the design out the features which allow
messaging. Use of social media including Twitter, nesting and perching. The planning
Facebook etc. Use of resident delivered newsletters department and officers must be acutely
aware of their role in reducing the gull
Building owners need to be clear that they are part of
population. Local planning policies must
the coordinated control effort. They must be given
consider implementing conditions of
information as to what legal measures they can apply
consent that all large new and refurbished
which might include: Removal of nests from roofs
buildings are bird/gull proofed.
prior and during the nesting season. Removal and
replacement of eggs during the breeding season. 3. Enforcement
Installing proofing measures such as netting and Where there is failure to support initiatives required
spikes to reduce nesting and access on ledges. A by the Authority in the control of gulls then
leaflet explaining the options should be widely enforcement is an important resort which must be
distributed. A request to undertake the measures used under waste control power which the Authority
recommended and provide advice and assistance for has. Circumstances will include:
a fee with regard to an egg replacement programme.
Littering on land and in streets
Recent anecdotal evidence suggests that bird Feeding birds in public places
repellent gels may also prove an effective deferent Allowing domestic waste to be scavenged
against gulls alighting on buildings. Allowing commercial waste to be scavenged
This needs to be a sustained, branded and
Other activities which encourage the gulls in an urban
co-ordinated campaign to harness the public and
setting.
businesses as part of the control effort.
It will be important to keep records of such
interventions and use the media to the authoritys
advantage as part of its control plan.

8
7 Use of GIS mapping

This vital resource is key to maintaining and

understanding the measures being undertaken to
effectively implement a plan. Mapping of nest sites,
perches and preening locations, waste attack
locations, waste bins, bathing sites etc. will all add to
the intelligence picture and provide evidenced based
intervention activity. The city centre can be broken
down into zones and responsibilities for targeted
action whether that be information campaigning,
scattered waste clearing or repeat offender
enforcement action. Effective use of mapping is a
valuable tool which can be harnessed to the control
teams advantage.
Assessment of progress it is vital to ensure regular
reports and interventions and presented to
committees and local interest groups so that focusing
can be adjusted and the public kept on board. It is
likely this will be at least a 5 to 10 year campaign and
there is a risk birds will be forced to feed further
afield.

9
8 The law on gull control

With all control activity it is important to be aware of Optical Gel This works on the birds senses, their
the legal boundaries on protected species. It is also sight is affected by an optical illusion and an irritation
important to be aware of what is reasonable in the of the retina. Touching the product also provides a
eyes of residents on non-protected bird interventions. stinging sensation (not harmful to the gull). Smell and
Whilst many would want to rid the city and their auditory signals between the birds effects and
homes of the gull menace once active interventions changes their daily movement patterns. It has been
are applied it is surprising how some sections of the tried with some good effect but it needs to be done
population can become upset and angry especially comprehensively on many perching areas to act as an
when there is sympathy whipped up by media effective deterrent. All surfaces are not always easily
attention. accessible or treatable. Anyone wishing to prevent
perching on a particular building, which might include
The Authority needs to know and communicate the
a heritage building to prevent damage, might find
boundaries of what can be done by interested parties.
this a useful treatment but it might only last a season
This can be done on websites, through leafleting and
before retreatment is required.
a through media campaign. The questions that need
straight answers are: Electrical System This low profile track can be fixed
to a roof, parapet or ledge where perching exists. A
Which birds are protected and what does
small electrical shock is felt when a bird lands on the
protected status afford?
track. Whilst the birds do not suffer through this
What can be done legally by building owners? Can
action, they quickly learn to avoid the property and
nests and eggs be removed?
change their daily behaviour accordingly.
What can legally be done by residents?
What can be done legally by local councils? Culling Only as a last resort, care is required when
Without clear information and guidance you considering this solution, all should be aware of the
cannot expect the public to be part of the plan. Wildlife and Countryside Act 1981 where a general
Without them you cannot expect to win. license may be used. These are open licences which
are valid between January and December of each
A regular nest and egg removal scheme can be
year and are subject to changes of species and
successful, a lot can be achieved for relatively little
conditions. The detail can vary between England,
expenditure.
Scotland, Wales and Northern Ireland. To be certain,
Egg replacement This intervention is known to work professional advice should be canvassed before any
but needs to be comprehensively undertaken. Egg culling programme is even considered, also be aware
oiling using a technical white oil prevents incubation that media attention to any cull will be extreme.
and or real eggs can be replaced for dummy eggs
It is not possible to be thorough enough to prevent
which makes the bird believe they are incubating
breeding, as not all species may be culled, however a
viable eggs and prevents the parent birds laying
reduction in adult bird numbers through control and
further eggs early in the season until its too late to
deterrence measures along with natural wastage
raise their intended offspring. It works well but
should within a few years begin a steady decline to a
assistance of flat owners, businesses is needed.
point where the birds lose their memory of nesting in
Nesting sites need to be easily accessible, flat and
the city environment. Thats not to say they will nest
safe. A service may be offered by the authority to
in another city but in that environment they might
provide the dummy eggs. Cost recovery is possible
not find sufficient habitat requirements to establish
under the right circumstances.
the larger nuisance colonies.
Hawks Flying a hawk regularly in City centres has
Prevention of Gull colonisation
been known to scare off gulls but whether this has
Building design If architects are required to take
long-term effect is doubtful.
account of the risk of gull colonisation then they can
Proofing buildings and structures This is by far the design out the nesting areas and perches. This is an
most effective deterrent to nesting and perching. The extremely important planning consideration for our
perching locations are fitted with spike or sprung wire cities and it is vital it is adhered to if future problems
systems. Optical gel and electrical ledge deterrents are to be avoided.
may also be considered. Open areas are proofed with
75mm netting for the cap net and 50mm netting to
the sides to prevent gulls getting caught in the
netting which they can often fly into. This method will
prevent anxious comments and concerns from the
general public.

10
9 Summary

It is entirely possible under current legislation and

from current knowledge and technology to control the
urban gull. There needs to be a concerted effort led
by the local authority and they need to harness the
community which includes businesses, residents and
visitors if they are to be successful. The key to success
is control of potential food sources through
containerisation of waste, information campaigning to
ensure everyone knows what they can do and
enforcement upon those who fail to support the control
effort when they have the means to support it.
A baseline needs to be set to understand and
quantify the problem. Full elected members support
is required along with identified and sufficient
funding to support a 5 to 10 year programme. A team
needs to be established under effective management
and authority. A plan needs to be formulated for
intervention. The plan needs to be implemented and
regular review of actions must be done to re-align
resources and target activity. In this way the urban
gull challenge can be beaten in a cost effective and
humane way.

11
 The National Pest Advisory Panel
Chartered Institute of Environmental Health
Chadwick Court, 15 Hatfields, London SE1 8DJ
Telephone 020 7928 6006 Fax 020 7827 5831
Email [email protected] Web www.cieh.org/policy/npap