Flawed Natural England policies assume gamekeepers don’t illegally kill raptors

We’ve been blogging for over a year about the use of propane gas guns on grouse moors and about our concerns that these booming bird scaring devices are being used to discourage raptors (and particularly hen harriers) from settling to breed (e.g. see here, here, here, here).

In June this year, Natural England finally produced what they called ‘guidance’ for those wishing to deploy gas guns and published a decision flow chart. It looked like this:

Gas gun guidance NE - Copy

A spokesperson for Natural England said he hoped the guidance was helpful (it wasn’t, see here) and welcomed further questions if clarification was needed.

One of our blog readers did want further clarification and he asked Natural England to explain how ‘ensuring that gas guns are located so that they do not disturb breeding Schedule 1 birds’ would work in practice?

Here’s Natural England’s response:

In response to your query the onus is on the land manager or their representative not to cause disturbance as that would be unlawful. The use of gas guns aims to dissuade species such as corvids from causing damage to ground nesting birds or livestock. On large expanses of open moorland they should be able to be deployed away from Schedule 1 species. Most managers should know where these species are present but it would be best practice for Natural England and other interested groups, for example raptor study group members, to pass on information over the location of Schedule 1 species to the land manager so they are in a more informed position and then able to ensure that gas guns are deployed appropriately“.

Ah, of course. Because telling the grouse moor manager/gamekeeper where you’ve seen hen harriers will undoubtedly lead to those birds being protected and left undisturbed, right? Have you got that, raptor study group workers?

And here’s another ingenious policy strategy from Natural England. In response to the news that Natural England had issued a licence to a gamekeeper allowing him to kill up to ten buzzards in order to ‘protect his pheasants’ (see here), another blog reader (@exPWCO) asked Natural England how they would check that just ten buzzards had been killed? Here’s Natural England’s response:


Ah, of course. Because asking a gamekeeper to fill in a form stating how many buzzards he’d killed under licence is bound to result in a truthful response, right?

Both of these policy statements just beggar belief. They are both based on the assumption that gamekeepers don’t illegally kill raptors, which, as we all know (and so should Natural England), is a flawed assumption.

gamekeepers prosecuted - Copy

32 thoughts on “Flawed Natural England policies assume gamekeepers don’t illegally kill raptors”

  1. Natural England and Brtish Heritage are nothing more than Orwellian euphemisms.
    Bot are there to administer noxious selfserving government policies..
    Margaret Beckett once said when asked about her low profile as Minister for Agriculture.
    I am not here for farmers, I administer agricultural policy!

  2. I’m at a loss for words .. there is enough evidence out there for everyone to know that game shooting interests are the primary cause of the illegal killing of birds of prey. Given the answer the blog reader received the only way that this can be framed is that Natural England is in collusion with these wildlife criminals. Could this be seen as a neglect of their duties? Could a civil case be pursued…..or is there anything under European Law that is not being upheld. Or am I simply clutching at straws?

  3. They should try this with drink driving … it’ll save a ton on money. You’re allowed one pint before you drive, but there’ll be no random police stops or breathalysers. Instead, you fill out a form stating that you only had one pint.

  4. Takes away yer breath and the will to live.Press Unnatural England hard on its inane policies and guess what?
    No reply.
    Imagine getting up in the morning to a job as pointless as that

  5. The licensing system at NE and other UK SNCO’s is completely reliant on the honesty of the licensees. NE aim to do compliance checks on 5% of licenses issued, usually just as a phone call to ask what was done under the licence in relation to what was actually licensed and what was submitted on the report of action taken.

    The only people who ever get penalised are ones who make honest mistakes and then go on to admit it. Those who wish to deceive the system can do so with wild abandon, safe in the knowledge that NE staff do not have the time or authority to spend the duration of the licensing period covertly monitoring the licensee’s activity. You can shoot as many cormorants etc as you like as long as you have the licence to wave at anyone who challenges you and remember to write the number licensed, not the number killed, on the licence return. Criminal conviction statistics show that gamekeepers are compliant with deceit in the pursuit of illegal activities to serve their masters, therefore underestimating the number of buzzards shot on their licence return should not cause them too much lost sleep. XXXXX XXXXX is already a convicted wildlife criminal FFS, now they are just legalising what he would be doing anyway. The licence should never have been approved, whoever assessed it was obviously not able to interpret the GWCT guidance on pheasant rearing best practice properly or too scared to tell the applicant to sort his protection measures and habitat management out. He leaves poults to run under conifer woodland with no understorey and then starts crying about buzzards showing interest, what did he expect?

    The gas gun ‘guidance’ is beyond a joke. Naïve and worthless doesn’t even come close. Licensing is a joke as NE will fail as always when it comes to monitoring and enforcement.

    I’ve met a lot of raptor workers in recent years on the verge of giving up. Tired of trying to work with gamekeepers, playing on a level field within the law while the people you are dealing with have no such restrictions. I’ve seen some hope recently, Mark Avery’s petition is helping, it will be given lip service without action in parliament but the profile of illegal persecution is being raised. Even RSPB are finally shedding their tiresome veil of procrastination and fence sitting that they adopted because they are so worried about upsetting game estates while the gamekeepers are laughing all the way to the pesticide shed. The tide is turning, patience has run out and attempts to find a practical compromise have repeatedly failed. We know many estates that continually persecute raptors, and there are a few that don’t, and there are others that succumb to peer pressure to ‘do their bit’ to keep raptor numbers down. Shooting estates must now be treated with no compassion or remorse, to bring about legal operation that they have failed to be able to do in-house. If, and this is a big if, a licensing system for shooting estate management can be provided that has impartial monitoring and appropriate enforcement I’d support it, but I can’t help being sceptical as it would be as open to abuse as the current species licensing systems. Specific raptors such as Merlin, Peregrine, Hen Harrier should also be key performance indicators that affect how much public funding the shooting estates receive, I was working on revision of a moorland agreement last week and believe me the tens of thousands they get paid for damaging our heritage is shocking. I think the only resolution will be a ban eventually, the shooters have demonstrated they will say anything to deflect attention from their nefarious activities, I no longer have any sympathy for their arguments or protests and rejoice at anything that damages their ‘sport’.

  6. Come on guys play fair (ha), haven’t you heard about the £12m cuts to their budget and the suggestions as to how they will make it up?

    This isn’t a dig at staff on the ground but the politicians running the organisation.

    Is it time the organisation was culled then at least we’d have a clear shot at the real targets?

    You’d suddenly find the gamekeepers, the agri-industry, developers et. al. defending them so they could keep cutting the green c**p and handing out grants for …. remind me what they do again?

  7. So the use of gas guns is to “dissuade species such as corvids from causing damage to ground nesting birds of livestock”? I’m not sure what a “ground nesting bird of livestock” [sic] is, but I’d sure like to know who invented a gas gun which scares only selected species like corvids without disturbing Hen Harriers. To anyone who understands what’s really going on out there, it’s blatantly clear and obvious that the real reason for deploying these instruments is for one reason only – to harass and dissuade harriers from nesting. The guidance in general issued by Natural England (and SNH in Scotland) has gone well beyond a joke. It comes across as if they are actually on the side of the criminal element by default, which of course they would deny indignantly, but the poor quality of their supposed professional advice has reached such a low that it is having that effect. Should we now by treating Natural England and SNH as part of the problem, not the solution?

    [Ed: “ground nesting bird of livestock” was our typo, not NEs (now amended, to read “ground nesting bird or livestock”]

    1. See above Jack Snipe, sadly they have been part of the problem here for sure.

      Their political masters and partnership working pals (aka business) need them as a butt to hide behind.

      Mark my words it will get a lot worse.

  8. So they are appealing to the good nature of gamekeepers in these cases – what could go wrong??………….

  9. Reading the excellent comments from Winn-D, it occurs to me that the only way to enforce licencing would be for all shooting estates to have to contract an independent body like the Raptor Study Groups to monitor activities on their individual estates, with full and unrestricted access. If the estates are prepared to pay more than lip service to their innocence, as they do at present, they should have nothing to worry about.

    However, I’m still convinced that in the longer term, the outlawing of shooting living targets is the only way to bring an end to animal cruelty and ruthless persecution of natural predators, whether legal or not.

    1. Independent monitoring would help, and a model could be designed and developed. There would be resistance, naturally. As I’ve already suggested there would no longer be a need for Natural England as they have demonstrated too much subservience to the ‘politicians’. The roles and functions they provide or deliver could be better achieved through other options, IMHO.

      In terms of economics we have an opportunity given that it appears that we are still to Brexit. We need to present a robust economic case which will be compelling and in the public benefit. We need to get the public engaged and behind us, think forestry sell off?

    2. Jack Snipe – absolutely agree with your comment on Winn-D’s post – and we in our group concur completely with your last paragraph.
      You have summed it up in a nutshell.

  10. It would appear that everyone in authority are obviously on the side of the gameshooting criminals. No point in beating round the bush anymore with regards to this fact.

  11. We have said it often enough before but I think we are going to have to be more inventive in how we fight this battle. Our opponents are for ever telling us “for every action there is a reaction” so we need to think of ways to cause economic damage to their businesses.We need lots of brain-storming and then agreed plans which teams can be given responsibility for. It is clear that we cannot rely on this Government to deal effectively with the issues, so we need to.The question as always, is do we have enough people willing to make the effort?

    1. In terms of illegal persecution of wildlife, general suppression of biodiversity, environmental harm such as reduced water quality and social disbenefits such as failure to develop a stronger rural economy and more chance your home, business or farm will be flooded, and then considering grouse moors cover 3.5 million acres of the country Friends of the Earth, Greenpeace and the Green Parties MUST starting seeing this as not ‘just’ about birds of prey being killed and the revulsion of shooting vast numbers of birds for fun but as the full environmental and social disaster it is. If they all started to publicly decry what the estates are doing to the land, wildlife and people they would be opening another front against the grouse moors and I think they would start buckling. At present the one organisation doing a decent job publicly highlighting the ecological and environmental costs of grouse moors is the League Against Cruel Sports, an animal welfare group – pretty appalling comment on the ‘environmental movement’.

      There’s also the point that virtually every conservation organisation in the country has a big stake in grouse moors changing to become genuinely wildlife friendly – we’re talking about everything from a slight change in ‘management’ to full scale rewilding with beavers (and the latter one of the best things to reduce flooding). Bats, amphibians, dragonflies, fish, woodland birds and the hundreds of species that live on dead wood, organisms that like scrub and proper (non incinerated) moorland etc, etc etc all could increase. What would the Woodland Trust be risking by speaking up about grouse moors, pissing off people who think they are doing us all a favour by stopping ANY tree growth on the moors? Same for the Bat Conservation Trust and probably Butterfly Conservation. If they start speaking up about what should be in the uplands, but isn’t the incessant ‘good for wildlife’ crap we have to listen to is going to start sounding very hollow to the general public too. It would also be very useful if there was more in the way of plans or at least ideas for how to transition away from grouse moors to alternative employment and businesses. This really should be the job of Scottish Land and Estates and others, but their agenda has always been huntin, fishin, shootin first everything else is expendable, that’s something worth pointing out as well, they aren’t making an effort to diversify/move on.

      I’ve spent more than forty years reading and hearing of what the estates have done to Scotland but change has been pitifully slow, in fact even ten years ago I would never have believed that the other side would be openly lobbying for raptor ‘control’ today, but they are and a license has been granted, it won’t be the last. All parties that have a responsibility towards stopping what the moors are doing, and that doesn’t leave out many in the enviro/conservation sector, need to get their finger out and sort this once and for all, it’s 2016 FFS.

      1. The Govt. ensured they gagged many wildlife charities through introducing the ‘lobbying’ legislation, likewise contracts contain clauses preventing such activity. Many are also in hoc to their project paymasters such as NE or the EA etc. Vote with your membership subscriptions, keep them regularly under review?

        Until we as individuals, at grassroots act collaboratively and collectively then they win. This recent raising of issues associated with driven grouse shooting is a welcome opportunity to bring bad land management practices into the public realm. If people understand that its not just about raptors (much as I enjoy watching skydancer) but flooding, water quality etc. then they will reject subsidies for private individuals without tangible public benefit.

      2. Thank you, Les Wallace. Very good points.

        We are strong supporters of LACS and they deserve all credit for their work, not just in this case, but over the years.

        What surprises me (just an animal advocate, neither a scientist nor specialist in this sphere) is that the Natural England/National Trust groups and their ilk spout such rubbish not just to us, who might not know better, but to people like all of you who contribute to this and Mark Avery’s blogs, and are expert in the field.

        Either they think they’re fooling us all – or they don’t give a damn. I’m beginning to think it’s the latter.

  12. Government orgs. just tow the line for the rich and ugly. Those Victorian attitudes of allegiance to the Lords, who, of course know what is best for people and animals. Natural England will not wake up from this horrendous dream. They are stupid enough to believe that the landed gentry and all their staff will obey and observe the law.

    A sickening, mindless activity continues to destroy habitats and animals, including their precious gun fodder.

    It must be stopped but it is going to be a long haul.

  13. It is such a damaging practice with such wide impacts that trying to tackle it from a raptor persecution angle only is tying one hand behind our backs. Especially when we are up against the establishment and its secure entrenchments.
    We have to break the problem down and tackle all of the issues with equal vigour. This is not one campaign, we will not win if we treat it like a single issue.

    1. Adam, thanks for the links, I have filled out the lengthy form, but have little expectation of change. The CNPA have had 13 years, and done………… what ? Both Raptor persecution, and the industrialisation of the moors have increased, and the estates continue to hoover up subsidy and grants, from the public purse.

      If this were happening in another country, we would call it criminal corruption !

  14. When we try and understand how bodies like EN and SNH make their decisions on licencing, this is the sort of warped policy that drives it.


    Have a read…it is divorced from any real ecological thinking and sets out to justify the status quo. The framework is supposed to be broad enough to address all issues (with the presumption that “somebody” should be automatically empowered) but it only focusses on mammals and birds with the assumption that all interactions should be the subject of human interference. It should put the habitat at its core…not individual species.

    Its worth a read… then ask yourself whether its a biased approach or not…. do they ever apply it before they issue a licence?

  15. Yeah, slag off NE and their staff, SNH and whatever the Welsh call their conservation body these days; but the fact remains that there are many frustrated, angry employees within all three agencies who remain vehemently opposed to what is currently taking place in the name of conservation in Britain today. It is not the staff of NE who sanction the killing of ten Common buzzard that prey on pheasant pout’s, It’s the minister’s of environment who call the tune, the tune that everyone has to dance to, or lose their jobs! Hold the Tories responsible for all of this.

    1. I don’t recall ‘slagging’ off grass roots staff who I’m sure are pretty hacked off.

      Can you signpost us to where we hear about them being vehemently opposed? I’ve not heard or seen any put their heads above the parapet – have you? They seem to keep on taking the civil service salaries, redundancies and generous pensions?

      I don’t really blame them [grassroots] but I don’t see any need to apologise about critising the management of the organisations I try hard to work with because I have files that evidence so many broken promises, failings etc. that there’s little wonder it feels like we are constantly pushing water up hill in a collander?

      Would anyone miss the organisation(s) beyond there being no protection for accountable (ha) Minister or businesses?

    2. I’ve stated on numerous occasions that it is not always the staff that are to blame for bad advice. They are under pressure from managers who in turn are under pressure from senior civil servants who are under pressure from politicians. Unfortunately however, I do have some direct experience where relatively ‘ordinary’ members of staff are in awe of management and undergo subliminal pressuring to “toe the party line.” It’s all part of developing a career as a civil servant. Those who adopt a more bolshie or scientific approach don’t get promoted, in fact their working lives can create stress and other difficulties for them. This isn’t just a NE or SNH problem; it is deeply entrenched in society as a whole. Too many people afraid to speak their minds. However the more recent problem in the national conservation agencies is the positive recruitment of new officers who show themselves prepared to adopt the “modern” approach to nature conservation, which gives too much priority to development, and the social and economic requirements of the Establishment. This is amplified by decent professional front line staff giving up in disgust.

  16. I don’t care about the ‘they are nice people only doing their jobs’ excuse. This has been used throughout history to justify various atrocities.

    Governments and Government advisors both sides of the border are displaying that they are not prepared to grasp the nettle and put in steps the necessary measures that are required to reduce the illegal killing of our most sensitive species.

    The main issue is the rich, elite landowners with the attitude of doing with their land what they want including harmful land management and killing anything they consider vermin.

    Tories and SNP are clearly unwilling implement the necessary changes required. So we continue to go round and round with not accepting evidence or making excuses in the face of the growing mountains of evidence.

    That’s why licences are being issued to placate and general licence sanctions are non existent. Clam traps are permitted for use without appropriate testing etc etc. The list goes on and on

    1. The usual suspects have done their best to decry this and say it’s just an attempt by FES to get funding, awards, that the researcher is biased etc, etc. Very rich coming from them. They just cannot stand anything good being said about predators. This can be added to the increasingly incontrivertible evidence that returning pine marten help red squirrels by noshing on the grey ones – as something that really, really pisses off the more backward element of the keeper community. Reintroducing lynx would add another element of our currently missing predator guild, but of course they are doing their best to sabotage that. Good stuff!

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