No subsidy withdrawal for mass poisoning of raptors on Glanusk Estate

Further to the news about the mass poisoning of raptors uncovered on the Glanusk Estate in the Brecon Beacons National Park, Wales (see here), we wanted to find out whether the Estate had incurred a financial penalty for what appears to be a clear breach of cross compliance rules.

In order to qualify for Common Agricultural Policy (CAP) subsidy payments, claimants are required to keep their land in ‘Good Agricultural and Environmental Condition’ and comply with a set of Statutory Management Requirements (SMRs). This is known as cross compliance. [NB: the rules have now changed slightly but as this mass poisoning took place in 2012/2013, the old rules apply].

In our opinion, the illegal poisoning of raptors with Bendiocarb is a breach of SMR1 (relating to the protection of wild birds) and SMR9 (relating to restrictions on the use of plant protection products).


In April, an FoI was submitted to Rural Payments Wales (RPW), the Government agency responsible for implementing CAP subsidy payments and for imposing penalties if cross compliance regulations have been breached. Here are the questions that were asked, along with the answers received from RPW:

Question 1. Which of these incidents were on land in receipt of subsidies under the Single Payment Scheme (SPS) during the years 2012 and 2013?

Answer: I can confirm that 10 of these incidents were on land in receipt of SPS in 2012 and 2013.

[RPUK comment: Although there were 24 incidents in total, it seems that RPW has excluded 14 of them, presumably because the illegally-poisoned birds and/or illegally-placed poisoned baits were on land that is not subject to SPS, for example, in woodland].

Question 2. What were the amounts of payments made under SPS in 2012 and 2013 and to how many beneficiaries?

Answer: A total of £98,802.01 was paid to 2 beneficiaries under SPS 2012. A total of £97,145.70 was paid to 2 beneficiaries under SPS 2013.

[RPUK comment: We’ve scrutinised the CAP payments website to find out who these beneficiaries were and we’ve worked out that they are two tenant farmers on the Glanusk Estate, presumably on whose landholdings the poisoned birds/baits were discovered].

Question 3. Can Rural Payments Wales confirm whether these offences would have breached SMR1 and SMR9 of the SPS?

Answer: These offences would be a breach of SMR1 and SMR9 if they were found to be attributable to a benficiary of Common Agricultural Policy (CAP) funds.

Question 4. What investigation or enforcement action has Rural Payments Wales undertaken in relation to these offences?

Answer: RPW considered the offences in question and concluded there was insufficient evidence to apply a cross compliance breach to a beneficiary.

[RPUK comment: We’re fascinated by this. The standard of proof for a cross compliance breach is lower than the standard of proof required for a criminal prosecution. A criminal conviction is NOT required for a cross compliance penalty to be imposed].

Question 5. What subsidy withdrawals have been made from anyone in receipt of money under the SPS in 2012 and 2013 as a result of these incidents?

Answer: No withdrawal of subsidy has been made from anyone under SPS 2012 and SPS 2013 as a result of these incidents.


A further FoI was submitted to RPW in May 2016, to try and understand why RPW thought there was ‘insufficient evidence’ to apply a penalty. Here are the questions that were asked, along with the answers received from RPW:

Question 6. Please can you tell me the date (day/month/year) that RPW first became aware of these poisoning incidents?

Answer: RPW first became aware of the poisoning incidents on 5 December 2013.

Question 7. Please could you provide information about the extent and type of enquiries RPW conducted when “considering the offences in question and concluding there was insufficient evidence to proceed with a cross compliance action”?

Answer: A formal police investigation was underway in this case and RPW undertook a review of the documentary evidence.

Question 8. Have the two claimaints been informed by RPW of the SMR1 and SMR9 breaches on their land?

Answer: No, RPW has not established any breaches to SMR1 and SMR9 on their land.

Question 9. Have the two claimants been interviewed by RPW about the incidents on their land?

Answer: No.

Question 10. Can copies of any correspondence between RPW and the claimants about these incidents be supplied (with personal details redacted)?

Answer: RPW has had no contact with the claimants over these incidents.

Question 11. What steps has RPW taken to prevent a reoccurence of these breaches?

Answer: RPW undertakes a programme of annual on site visits to farm businesses to ensure cross compliance requirements are respected.


To be honest, we’re completed baffled by RPW’s answers to questions 8-11. They’re either displaying overwhelming apathy, or they’re confused, or we’re confused. Confusion and apathy shouldn’t be unexpected – we saw a similar approach from the Rural Payments Agency (operating in England) when we challenged them about a subsidy withdrawal for the Stody Estate (Norfolk) after the discovery of mass raptor poisoning on their land. The confusion and apathy continued for a year, but, to their credit, the RPA did eventually get it right and imposed a large financial penalty on Stody Estate (see previous blogs here).

Are we going to have to go through the same process with Rural Payments Wales?

Was there a cross compliance breach or wasn’t there? If there was, why hasn’t a penalty been imposed? Why hasn’t RPW bothered to discuss these poisonings with the subsidy recipients? How can RPW claim, with straight faces, that their on site visits “ensure cross compliance requirements are respected”? If that’s the case, where was RPW in 2012 and 2013?

Emails to:

There’s something decidedly rotten about this whole affair. The most significant wildlife poisoning incident ever uncovered in Wales, and the second largest in the UK in 40 years, on a prominent estate with strong royal connections, inside a National Park. Abject secrecy about these crimes from Dyfed Powys Police (until we started asking questions 3 years later), no criminal prosecution, and no subsidy penalty.

18 thoughts on “No subsidy withdrawal for mass poisoning of raptors on Glanusk Estate”

  1. It looks as if you have discovered not only a cover up of crimes of epic proportions but a truly blatant disregard of the regulations by RPA. I’m surprised that there were no people in all these organisations willing to spill the beans. No moral courage anywhere.
    Well done RPUK.

  2. Have a few sheep with their ear tags missing, and if inspected and found out its a fine via reduction of your basic farm payment. Maybe 5% reduction. Should be like New Zealand, get rid of Subsidys. Its made land very expensive, and some folk very rich, but the poorer farmers need it to get their bills paid. Thats how the system is. Of course you dont have to claim it, then you can do what you want.

  3. To be fair, the RPA are so inefficient you should not be surprised by this. They have failed to ever pay all farmers what they are due on time and are continuously being fined by the EU for their failures. Their only priority is to get money out – and not decide whether or not some toe rag is a criminal or not.

  4. This annoys me intensely because the RPA is ruthless in fining Wildlife Trusts for minor breaches such as small discrepancies in the amount of declared land in good condition (typically as a result of scrub encroachment), and yet they totally ignore this horrendous case.

  5. Unless I’ve missed it, not much has been said by the Wales Green Party. I’ve contacted them and will keep you posted.

  6. “On a prominent estate with strong royal connections” Therein lies the answer that nothing has been done, and that the criminals have got away with their crimes.

    1. Sadly, it’s not just Wales where RPA are ‘ineffective’. I reported an incident on a SSSI in Yorkshire to both Natural England and the RPA, neither did anything about it. RPA informed me that it is not for a member of the public to get involved with such matters. NE expected RPA to act, RPA expected NE! A blatant act by the landowners lawful tenant, both parties recognised that – but the RPA – begs the question are they fit for purpose? Then again n’owt compared to what you’ve uncovered!

  7. William preaching about saving African wildlife & the likes, he should begin at home with some of those in the royal circle. Starting with with Hen Harrier Harry .

  8. I fear that we are not going to progress fast with elimination of the intolerable level of raptor crime in game shooting unless we start some more hard – hitting activism.
    This is how progress against injustice is achieved.
    Further to my recent query;
    Is RPUK a registered charity ?
    Would this not be a good move if not currently charitable ?
    Public opinion is an open door to be pushed at, but funding,media direction & activism is necessary.
    I would willingly start the ball rolling by providing funding if such a charity were to be created.

    What do others think ?


    1. You can donate to Mark Avery’s publicity campaign on banning DGMs.
      As i understand it charities always involve money. RPUK is free and anonymous.

  9. If anyone would like to “like” a few of my comments on their facebook page-it would stop becoming the only target for the SAS!

  10. Wales Green Party now taking an interest, will keep you posted. Also I’m thinking over a submission to the Health and Safety Executive to stop all forthcoming events at Glanusk Park/Estate. Advice welcome.

  11. sennan bottalak . It wouldn’t be a good move. Charities are not allowed to get involved in political matters.

  12. Looks like the Green Man Festival is going to Glanusk Estate again this year (2017). They obviously don’t care about the worst wildlife crime in Wales on this estate. So much for their “green” credentials. Just about the money, I suppose. Seems hypocritical to me though.

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