Metro, Friday 31 July 2026
Some 655 pigeons have been shot and killed as part of regular culls organised by Transport for London. At least 123 shoots were carried out between March 2024 and March 2026 to clear stations of birds nesting on ledges or trapped behind netting. Campaigners say the operations inflicted unnecessary suffering and have filed a report with British Transport Police. Manchester Pigeon Rehab, which collected the data, alleges that TfL did not take reasonable steps to mitigate suffering or explore non-lethal alternatives, and says some injured birds escaped after being hit. Natural England recommends avoiding lethal control during breeding season, but the shoots went ahead regardless. TfL contracts its pest control services out to the firm AGS One. Shooters require a GL41 licence, whose conditions include taking reasonable precautions to minimise suffering. TfL said it has invested in preventative measures and that pest control is only brought in as a "last resort" once other deterrents have failed, adding that it has a duty of care to customers, staff, contractors and third parties to maintain a safe and clean environment.
There are three separate constraints in this story, and it is worth being precise about what each of them actually is, because the difference between them is the entire point.
The first is the GL41 licence, which carries conditions. Conditions attached to a licence are binding on their face. The second is Natural England's position on lethal control during breeding season, which is a recommendation. A recommendation is advisory by definition, and nobody is breaking it by proceeding. The third is TfL's own account of when culling happens, which is that it is a last resort once other deterrents have failed. That is not a rule at all. It is a description of an internal judgement, made by the organisation that benefits from the judgement going one way rather than the other.
Stack those three together and you have a structure that reads, from the outside, like regulation. Licence. Guidance. Stated policy. What the reported figures suggest is that the structure produced 123 shoots in twenty-four months, roughly one a week, including through the period the guidance advises against. A weekly occurrence is not, in ordinary English, a last resort. It is the resort.
None of this requires anyone to have broken anything. That is what makes it a useful example rather than simply a scandal. The condition about minimising suffering says "reasonable precautions", and reasonable is the word that does the work, because it is the operator who decides what is reasonable and the operator who would have to be challenged to establish otherwise. Natural England advises rather than requires, so proceeding through breeding season is a lawful choice. And the pest control itself is carried out by a contractor, which places the actual conduct at one remove from the body whose stations are being cleared. Every element of the framework is intact. What is missing is any point at which the framework stops something.
The word "last resort" is doing what this book describes stated standards doing generally. It signals that a threshold exists, that it was considered, and that it was reached. It does not commit anyone to a definition of the threshold, a record of the deterrents attempted, or a count of how often the answer came back the same. It is a claim about internal process offered in place of evidence about outcomes, and it works because most people hearing it will assume that a phrase that specific must correspond to something.
The campaigners' response is worth noting for what it concedes. They are not asking for the licence to be enforced. They are asking for lethal control to be replaced with habitat modification and humane deterrents, which is a request for a different policy rather than for the existing one to be applied as written. That is a reasonable read of where the leverage lies. When a rule's conditions are satisfied by the operator's own assessment of reasonableness, the argument about compliance is not available, and the only argument left is about what the rule should say instead.
Which leaves the report filed with British Transport Police as the interesting test. A criminal complaint is an attempt to move the question out of a framework where the operator interprets its own obligations and into one where somebody else does. Whether that succeeds will say more about how the GL41 conditions actually function than two years of shoot data has.
This entry shows a licensing framework whose conditions are stated as requirements, recommended as guidance, and applied as neither, with the operator retaining the decision on what its own duty of care permits.