Month: January 2013

Update on SNH clam trap consultation fiasco

snh_logoOn January 3rd we blogged about an apparent discrepancy in SNH’s 2013 General Licence consultation. In early December 2012, SNH claimed that “the majority of consultees” supported the idea of using clam-type traps without the need for prior independent testing on their suitability. In mid-December we asked SNH to publish the full list of responses for public scrutiny. They did this on 21st Dec. Our analyses of those responses suggested that the majority of consultees DID NOT support the use of clam-type traps prior to independent testing (see here).

A number of you have now contacted SNH Chief Exec Dr Ian Jardine to ask for an explanation. We understand that SNH are now “looking into it“. Well done to those of you who took the time to contact him.

SNH have 20 working days in which to respond (by 31st January). We’ll keep you posted.

For background reading on the SNH clam-trap / General Licence fiasco, see here, here, here, here, here, here, here, here, here.

Radio GaGa

bbcradio4120x120Raptors have been the subject of discussion in a couple of BBC Radio 4 programmes over the last two days.

On Sunday (6 January) there’s just under a minute and a half of misinformed information from Clive Aslet, editor-at-large of Country Life magazine. Mr Aslet claims that red kites are “eating up lots of larks“. You can listen here (starts at 56.32, ends at 57.52).

Today (7 January) there was a five minute discussion about hen harriers between Martin Harper, the RSPB’s Conservation Director and Adrian Blackmore, the Countryside Alliance’s Moorlands Director. Neither covered themselves in glory, although Martin Harper’s arguments did get stronger as Adrian Blackmore’s got weaker. It’s a shame that Martin didn’t mention the scientific evidence to support his opinions, particularly the Hen Harrier Conservation Framework. You can listen here (starts at 52.25, ends at 57.30).

Time, and patience, running out for the survival of the hen harrier

Hen harrier being removed from illegal trap on Moy EstateThere’s another article out today about the imminent extinction of breeding hen harriers in England (see here).

None of you will be surprised by its content. It’s the same old opponents, using the same old arguments. How long has this ‘debate’ been going on? At least twenty years and probably longer. What’s changed? Not much. The accusations are the same (grousemoor owners and their gamekeepers are systematically eradicating the hen harrier from the British uplands). The denials are the same (“it’s nothing to do with us”). The one thing that has changed is the number of breeding pairs of hen harriers: just the one, solitary and pitiful breeding pair in England in 2012.

In the latest article, Adrian Blackmore, Moorland Director for the Countryside Alliance, suggests that the decline may be due to the hen harrier’s “susceptibility to bad weather, disturbance, poor habitat and lack of available food“. He clearly hasn’t bothered to read the Hen Harrier Conservation Framework which identifies illegal persecution as the main limiting factor. The game-shooting lobby dismissed this report when it was first published and claimed, amongst other things, that it used data that were now out of date (see here). In response, SNH has agreed to have the report revised to incorporate the 2010 national hen harrier survey data. Another delaying tactic by the game-shooting lobby? Do they seriously expect the report’s conclusions to change, considering the widespread population declines that were uncovered during the 2010 surveys?! Whatever, we’re all looking forward to seeing the revised text, especially as we understand that SNH is asking GWCT to be involved with the revision, that well-known independent scientific body with no axe to grind against hen harriers and no reason to favour the grouse-shooting industry. Ahem.

Meanwhile, back on the moors, how many breeding pairs of hen harriers will be ‘allowed’ to settle this year? And will it be enough to stop the huge and legitimate swell of public anger that may well just lead to a campaign to ban driven grouse shooting (see here)?

Approval of clam traps: incompetence or corruption at SNH?

snh_logoOn Dec 5th we blogged about the changes being brought in by SNH to the 2013 General Licences following a period of public consultation (see here).

We suggested that it looked like SNH had listened to the recommendations made by the game-shooting lobby and had ignored those made by the pro-raptor groups. This was pure speculation because at that time SNH hadn’t actually published the responses they’d received during the consultation. We (and many of you) asked for them to be published. They did so on 21st December. Click here to read them.

Having now had the chance to review all these responses in detail, we believe that SNH has indeed favoured the recommendations made to them by the game-shooting lobby and ignored the recommendations made by the pro-raptor groups. But on a much more serious level, we now also believe that SNH’s decision to approve the use of clam traps in the 2013 General Licences before conducting an independent assessment of their suitability is based on a flawed interpretation of the responses.

In the letter sent by SNH to the consultees, dated 4th December (see here), SNH wrote this:

“On the basis of the feedback received we have made a number of decisions for changes for 2013”.

 One of these changes was this:

“Traps permitted under General Licences 1-4 will be clarified, including authorisation to use ‘clam’-type traps”.

Later in the same letter they further explained this change:

“In the consultation we asked whether there was a need to clarify the traps that are permitted for use under the General Licences. Our proposal was to provide further clarification and to specifically permit the use of ‘clam’-type traps. These traps have been available and used for a number of years but whether or not their use is covered by the General Licences has been debated due to unclear trap definitions in the General Licences to date.

Whilst the majority of consultees supported the proposed amendments, concerns were expressed by a number of respondents over potential welfare implications of these traps and how they could be used to trap non-target species”.

So, in this letter, SNH told us that the “majority of consultees supported the proposed amendments” [to explicitly authorise the use of clam-type traps before conducting an independent assessment of their suitability] and that SNH’s decision to authorise their use was based on “the feedback received”.  According to our analyses of the responses, this is blatantly untrue on both counts.

We divided the respondents into four groups:

(1)   Those who explicitly supported the use of clam-type traps prior to an independent assessment of their suitability;

(2)   Those who didn’t expressly mention clam-type traps in their response;

(3)   Those who did specifically mention clam-type traps but were unclear about whether they supported use prior to independent assessment; and

(4)   Those who explicitly did not support the use of clam-type traps prior to an independent assessment of their suitability.

In group (1) –

Scottish Countryside Alliance, Scottish Association for Country Sports, Scottish Gamekeepers’ Association, Scottish Land & Estates Moorland Group, Game & Wildlife Conservation Trust, British Association for Shooting and Conservation.

TOTAL: 6

In group (2) –

National Farmers Union Scotland, Scotland for Animals, Animal Concern Advice Line, Scottish Tree Trust, Individual B, Grampian Wildlife Crime Unit, Grampian Police, Glasgow City Council, Individual C, University of Stirling.

TOTAL: 10

In group (3) –

National Wildlife Crime Unit

TOTAL: 1

In group (4) –

OneKind, RSPB, Scottish Raptor Study Groups, SSPCA, Against Corvid Traps, Kindrogan Field Centre (Field Studies Council), Individual A, Individual D, Individual E, Individual F, Individual G, Individual H, Individual I.

TOTAL: 13

For the purposes of this analysis, groups (2) and (3) can be discounted. That leaves us with groups (1) and (4).

It is clear that the number of respondents in group (4), i.e. those opposing the use of clam-type traps prior to independent testing, is more than double those in group (1). Thirteen respondents were against the use of clam-type traps; only six were supportive.

So how on earth can SNH justify their decision, “based on feedback received”, to authorise the use of these traps prior to independent testing? At best this appears to be incompetence; at worst, corruption.

This is a serious issue. Has SNH intentionally misled the public to believe that the majority of respondents supported the use of clam traps prior to independent testing? Why hasn’t SNH heeded the majority of the responses, which clearly stated their opposition to the use of clam-type traps prior to independent assessment?

We demand an immediate review of this consultation process and we urge you to seek the same. In the first instance, we suggest you contact SNH Chief Executive Dr Ian Jardine: ian.jardine@snh.gov.uk

If you don’t know how to phrase your complaint, you could simply cut and paste from this blog or provide a URL to this posting.

SNH have a duty to respond to emails within 20 working days. If Dr Jardine’s response is unsatisfactory, then we have the right to ask the Scottish Public Services Ombudsman to investigate the complaint.