In October we blogged about how SNH was preparing to make changes to the 2013 General Licences via a public consultation process (see here).
They’ve now just published their proposed changes and by the looks of things, they’ve ignored almost every single recommendation except those made by the game-shooting lobby.
Their letter to consultees, in which they outline their proposed changes, can be read here.
Many concerns remain unaddressed, and particularly about the use of crow cage traps under the General Licence, including trap design (welfare issues), year-round use (as opposed to seasonal use), uncontrolled positioning of these traps, ineffective regulation of crow trap users and ineffective monitoring of crow cage trap use.
There’s one particularly strange ammendment:
“Requirement for persons to have read and understood conditions: We will remove the requirement for people to have read the licences before using them. New licenses will require users to ensure that they have understood the conditions“.
What’s the significance of removing the requirement for people to have read the licences before using them? This sounds like the introduction of a very dodgy legal loophole…we wonder who made this recommendation to SNH?
However, the biggest concern is that SNH has officially authorised the use of ‘clam’-type traps (see above), even though they are fully aware of concerns that these traps are likely to cause injury to non-target species (e.g. see here and here). SNH acknowledges these concerns and proposes to “commission research in 2013 that will examine how these traps are currently being used“. Why authorise a trap before you’ve carried out research to assess the potential damage that trap could cause? By authorising its use without being able to define the trap, SNH has just opened up the floodgates for gamekeepers and other users to put out any trap, call it a clam-type trap, hang an ID tag on it and it’ll be legal. How will SNH control trap size, height, spring tension? It’s nothing short of disgraceful that these traps have been authorised without a proper, independent assessment of their use. SNH say they will work with the representative bodies of the trap users as part of their research. Brilliant – do they really think those users are going to tell them when they’ve caught a non-target species? Or when they’ve ‘accidentally’ injured or killed a non-target species? You only have to read the evidence given in the current hare-snare trial to know the answer to that.
What a total shambles. What we’d like to see now is a complete list of ALL the consultation responses that SNH received for the 2013 general licences. Why? So we can assess whose recommendations SNH has listened to, and whose have been ignored. SNH has not made these consultation responses available in the public domain, but it’s common practice for any public authority conducting a consultation to do so (just look at the Environmental Audit Committee consultation on wildlife crime – every single consultation response was made publicly available).
We urge our blog readers to write to Robbie Kernahan, SNH Head of Wildlife Operations, and ask for ALL of the 2013 general licence consultation responses to be put on the SNH website. Here’s his email address: licensing@snh.gov.uk
Raptor Persecution UK 
The fact that they are commissioning a study shows that they are concerned about how these traps affect wildlife now…so why allow them to be used at all?…Perhaps some concerned organisation should really have a go over this – as the blog says its a decision which undermines the whole practice of trap regulation – and ask for a Judicial Review on the decision….also by restricting any research to “how the traps are currently being used” is totally inadequate, surely they must study how such traps “could be used” at any time in the future. Thats not research, thats just monitoring.
Nice to see SNH has approached any changes to the general licence sensibly and without buckling to some of the rediculous suggestions some individuals should become mandatory.
Very disappointing response. Licensing of clam traps without independent research to establish the welfare costs is appalling (but quite in line with authorising the horrible Collarum snare as a “spring trap”, as happened not so long ago). Allowing someone to claim he understands a licence without having read it – inexplicable! And you’ll notice that the legal loophole has been retained that allows a person convicted of a wildlife or welfare crime, but merely admonished, to continue to access the licences . I suppose we should be pleased about the robins.
Presumably the responses will be available via FOI but anonymised as there was no respondent form issued with the consultation.
I’m really not that surprised by the SNH response. The organisation is very adept at producing some nice brochures and literature but when it comes down to the welfare and future of Scotland’s natural heritage, they are sadly lacking. Recent tales of their staff’s inability to show up at meetings on time (or at all) resulted in a slight change of meaning to the acronym – for many SNH simply meant Still Not Here.
There are other concerns about their lack of care or knowledge of lands they have some responsibility for. On my local SSSI, they have suggested an avian list of 160 species. The real figure is in excess of 200 species, meaning that desk studies and field studies have not accounted for at least 40 species. So, if they can miss 40 avian species, how many less-detectable species have they missed over the years? But then again, I happened to bump into a SNH surveyor a few years ago, and got talking. A small of flock of waders were on the shore (about 80 yards away) and he had to ask me if they were Dunlin or Ringed Plover. Says it all really.
Scottish Natural Heritage, as their name suggests, should be looking after native wildlife but I find it despicable that this organisation favours the indiscriminate and unregulated trapping of native wildlife in favour of introduced species. Yes, it would appear that SNH are not interested in the responses from those organisations that carry out their duties legally, but they will pander to organisations with a long history of criminal activity. Perhaps if badger-baiters and deer and hare-coursers somehow managed to align themselves with gamekeeping interests, SNH would be happy for these activities to persist. SNH are an absolute joke and they are not fit for purpose.