14 BIRDS OF CHESHIRE. 
Owls anywhere within the county borders throughout 
the whole year. It also protected at all seasons of 
the year, within the prescribed area in Wirral, all wild 
birds, whether scheduled or not. 
By a third order, dated February 15th, 1898, Gulls 
and Terns are protected all the year round in the 
parishes bordering the Dee and Mersey Estuaries. 
The regulations formulated by the County Council 
are, however, so complicated as to be to a great extent 
useless. Rules applying to one parish may be in- 
operative in an adjoining one; and police oflicers, 
desirous though they may be to enforce the law, not 
being practical ornithologists, frequently err in identi- 
fying species. Again, eggs of the Bittern and Dunlin, 
birds which have long since ceased to nest and are not 
likely to return to their old breeding haunts in the 
county, are specially protected, whilst nests of the Great 
Crested Grebe, the Goatsucker, the Woodpeckers, and 
the Redshank may be robbed with impunity. Were 
it not for private protection the last-named _ bird, 
already much reduced in numbers, would soon be 
extinct as a breeding species. The Great Crested 
Grebe is specially protected, and rightly so, but no 
regulations have been made with regard to its eggs, 
and on many of the meres its nests are robbed year 
after year by greedy and unscrupulous collectors. The 
regulations as they now stand present a curious 
anomaly with regard to the Greater and Lesser Black- 
backed Gulls. These two species were not included 
with the other Gulls in the schedule of the Act of 1880; 
but by section 9 of the order of February 15th, 1898, 
they are protected ‘during the whole of that period of 
the year to which the protection of wild birds under 
the Wild Birds Protection Act of 1880 (as extended by 
