Grouse moor management in Scotland: Government launches public consultation

Today, the Scottish Government has launched a public consultation as the start of its commitment to introduce a licensing scheme for grouse moor management, following the publication of the Werritty Review in 2019, which was commissioned in 2017 after unequivocal evidence was published of the on-going illegal killing of golden eagles on some Scottish grouse moors.

That illegal killing continues, as evidenced by this young golden eagle recently found poisoned on a grouse moor in the Cairngorms National Park laying next to a dead mountain hare that had been used as the poisoned bait (photo by RSPB Scotland).

As is so often the case, nobody has been charged or prosecuted for this hideous wildlife crime, which is a fundamental reason why the Govt is introducing a licencing scheme, presumably as a means of sanctioning an estate (by withdrawing its licence) when evidence of wildlife crime is discovered. Without knowing the exact details of how the licensing scheme will operate, it’s impossible at this stage to predict its effectiveness. There are many sceptics, and I’m one of them, but I’m also certain that the status quo is untenable and so I view licensing as a step in the right direction, but definitely not the end of the road.

The Government’s licensing consultation preamble reads as follows:

‘A Stronger & More Resilient Scotland: The Programme for Government 2022-23 which was published on the 8 September 2022 committed to introducing the following Bill:

Wildlife Management (Grouse)

The Bill will implement the recommendations of the Werritty Review and introduce licensing for grouse moor management to ensure that the management of driven grouse moors and related activities is undertaken in an environmentally sustainable manner. The Bill will also include provisions to ban glue traps.

In November 2020, the Scottish Government published its response to the recommendations made by the Grouse Moor Management Group (“Werritty review”).  That report was commissioned by the Scottish Government in response to a report from NatureScot (formerly Scottish Natural Heritage), published in May 2017, which found that around a third of satellite-tagged golden eagles in Scotland disappeared in suspicious circumstances, on or around grouse moors.

The Werritty review made over 40 recommendations regarding grouse moor management. The recommendations, which were accepted by the Scottish Government, seek to address raptor persecution and ensure that the management of grouse moors is undertaken in an environmentally sustainable manner.

As well as proposals relating to grouse moor management, this consultation also considers glue traps. A report from the Scottish Animal Welfare Commission, published on 23 March 2021 stated that

‘……the animal welfare issues connected with the use of glue traps would justify an immediate outright ban on their sale and use. This is our preferred recommendation‘.

This consultation is therefore seeking your views on the Scottish Government’s proposals on:

*Grouse moor licensing


*Trapping (wildlife traps, glue traps, snares)

You can complete all the sections in the consultation or only those sections which are of interest/relevance to you’.


The Government’s proposals for its grouse moor licensing scheme are laid out here:

I haven’t yet looked at the consultation paper so I can’t offer any comments or suggested responses yet but I will do very soon. The consultation will close on 14th December 2022.

The link to the consultation questionnaire can be found HERE.

UPDATE 26th October 2022: REVIVE coalition cautiously welcomes Scot Gov’s consultation on grouse moor licensing (here)

UPDATE 27th October 2022: Grouse shooting lobby quietly seething over proposed licensing scheme (here)

UPDATE 10th December 2022: Last chance to have your say on Scottish Government’s consultation on grouse moor reform (here)

18 thoughts on “Grouse moor management in Scotland: Government launches public consultation”

    1. Indeed. But there are also more issues involved with Grouse shooting (CO2 emissions from degraded peat moors, water pollution, flooding) than with lowland shooting. It also covers much more land, especially in Scotland.

    2. Grouse shooting is in a pretty unique position and so is the raptor persecution that takes place (on a grand scale) as it takes place out of the sight of alot of the public and the birds involved are very scarce without these thugs poisoning trapping shooting and killing them in any way possible.That is not to say there is no persecution on lowland shoots .
      Then of course theres the muirburn and the stink pits and the killing of just about every creature on the uplands.

  1. “…the management of driven grouse moors and related activities is undertaken in an environmentally sustainable manner.” Really? Hmm, the Scottish Government would have more chance of success if they tried un-frying an egg.

    But of course sustainability is not the true objective here. The SG are merely throwing a bone to the conservation movement that will allow DGS to continue (with a bit more paperwork) with all the added trimmings of licensed legitimacy. The spin will no doubt be that DGS licensing is working, even if/when it doesn’t.

    Like you Ruth I’m a DGS licensing sceptic, but I cannot agree that this is step in the right direction. In fact I would say it is a big step in the wrong direction as it will scupper the chances to ban of the most damaging of all our heinous ‘bloodsports’ for years/decades to come. DGS is SO wrong on SO many levels that a licensing system, at best, could only ever be seen as turd polishing. The “end of the road” – I’m sure you would agree? – has to be a ban, but DGS licensing is a substantial roadblock, not a stepping stone.

    1. Stephen,

      You write as if a ban was an option. It never was and it’d be politically naive to think it ever could be without first going through a licensing stage, because the SNP won’t go straight from zero to a ban.

      The bottom line, as I see it, is that there are two current options: continue with the status quo or support a licensing scheme. If that licensing scheme, in whatever format it takes, fails to address the issues, THEN will be the time to push for a ban.

      Personally, I find the status quo totally unacceptable so I’ll be spending my time over the coming months making sure the proposed licensing scheme is as robust as it possibly can be, against the inevitable push-back from the game-shooting lobby who will take every opportunity to weaken it.

      It’s pointless right now to be discussing whether a ban is a better option than licensing, because a ban simply isn’t on the table.

      1. Hi Ruth,

        Thanks for your considered reply.

        I agree that a ban is not on the table at the moment, but for me that is all the more reason for campaigners to continue to seek a ban. I guess where we’ll have to agree to disagree is my point that licensing makes a ban less attainable as the SG will see the problem as ‘sorted’; for a very long time.

        I often compare the current DGS ‘debate’ to the campaign against fox hunting. Nobody called for licensing of fox hunting during the campaign for a ban and eventually – with a change of government – we got a ban, imperfect though it may be. So it seems odd (and sad) to me that the bulk of the campaign against DGS is settling for the licensing option. Far better, I think, that the campaign sticks to calling for a ban and repeatedly telling the SG why licensing won’t work then do a bit of ‘I-told-you-so’ later on if we ever did get a ban.

        I’ll be putting a submission in to the consultation and, like you, I’ll be watching for robustness of any scheme. To be honest though I have little hope of an effective licensing system as I noted the big-upping of grouse shooting in the consultation pre-amble as the tired old claptrap thus: “While the management of grouse moors for game shooting makes an important contribution to the rural economy…”. Not an auspicious start. Even with the influence of the Greens on the SNP my forecast is for weasel-worded, dog’s breakfast of a licensing system with woeful enforcement on the ground. I hope I’m wrong.

    1. ‘Delaying tactics’ have been employed right from the start… It is what politicians do when vested interests are involved. But – unless enough people work outside of the political system – it is what we have to deal with.

  2. As a person who would like to see an end to grouse shooting in Scotland I believe that it is important to respond to the consultation. I was in little difficulty in deciding my response to the questions. I accept that licencing is a part way house but it is better than the status quo.
    My final assessment is that anyone interested in seeing an end to grouse shooting should respond to the consultation induvidually which should ensure that there are voices other that those who support grouse shooting. The consultation is quick to complete.

  3. Can I please ask that if you haven’t already responded to the consultation you consider adding a couple of points that I think are enormously important, but are often missed. The first is that even targeted rather than blanket tree planting of trees in certain locations can still do a fair amount to reduce flood peaks downstream. However, if beaver are present and create their famous dams – which they will on the narrower watercourses higher up in the hills – then the flood reduction benefits are magnified enormously It’s frankly obscene that there isn’t already a plan in action to do widescale riparian tree planting in our uplands right now with the purpose to create conditions for beavers to be brought back ASAP.

    As soon as they can get to work they’ll do an awful lot to reduce the financial cost and human misery caused by the flooding of better quality farmland, businesses and especially homes that tends to happen in places like Perth (the city with the highest flood risk in Scotland), there are plenty of grouse moors on the Tay’s upper watershed. As a bonus the effect of drought would be alleviated too and here’s a real biggy, fire risk would be reduced. Wider, damned water courses fringed by damp, new woodland is going to a hell of a lot harder for fire to cross than a faster flowing stream a fraction of the width fringed by highly flammable heather. The DGS lot are really playing the ‘if we don’t do regular muirburn then the build up of old heather will mean INFERNO!!!’ schtick right now especially as support for rewilding grows. Surely the owners of grouse moors themselves wouldn’t want the potential to lower the number of farmers, businesses and householders below them hit by flooding and to reduce fire risk on the hills compromised for the sake of traditional grouse moor management? Surely no one could be that selfish could they? If one animal spells doom for grouse moors it’s the beaver, a tremendous catalyst for getting flood reducing trees on the hills and moors at very long last.

    The second point relates to Leeds University’s EMBER report on the hydrological effects of muirburn What it said about increased acidification and sedimentation of watercourses running through grouse moors plus reduced numbers of aquatic invertebrates and possibly exacerbating spates screamed to me that muirburn isn’t good for most wildlife and is particularly bad (terrible?) for game fish, trout and salmon. I’ve had private communications with fishery scientists who’ve confirmed that.

    Grouse moors are bad for salmon and thereby salmon fishing. Years of pointing this out to fishing clubs and angling organisations has been met with deafening silence. The same folk though have often been very loud in calling for seals, cormorants, mergansers, goosanders, sometimes otters and even occasionally the bottlenose dolphins in the Moray Firth (I kid you not) to be ‘controlled’ to help salmon. Rumours circulate dippers are still killed as it’s thought they’d eat fish eggs. They’ve also kicked up hell about beavers spreading and supposedly blocking the movement of salmon. Salmon co-evolved, co-existed, survived and in fact thrived for millions of years alongside these and other predators plus beavers and their dams. Salmon never had to deal with muirburn though. I’m trying to push this issue at the Scottish parliament at the moment, but it’s like wading through effing treacle. This is potentially a big fly in the ointment for the field sports sector so please raise it in the consultation, the DGS lot did actually try to disparage the EMBER report in a rather underhand way which backfired on them – they know it’s not good news for those running grouse moors.

  4. I have responded to the survey. It is laughable to think most gamekeepers are interested in conservation. They are only there to deliver profitable numbers of grouse for shooting for their managers. Any talk of carbon capture through muirburn is just greenwashing!
    I think it is important to point out that muirburn does not promote biodiversity. It is clear muirburn promotes an monoculture of heather, as can be clearly seen when driving past grousemoors where there is more diversity of flora in the 5 metres verges than 100 metres further on to he moor.,

    1. Spot on!!! According to the John Muir Trust sampling peat deposits has shown fire as a widescale natural phenomena on our hills only occurred every 150 or 200 years or so, it’s not regular. Juniper like heather is an important plant culturally and ecologically, but it doesn’t like over grazing and it really doesn’t like fire. Thanks to that it’s become a very rare plant over much of its range where it should be quite common. There are over seventy invertebrate species linked to juniper in the UK which therefore suffer when muirburn effectively limits it to the few spots like rock ledges where the fire doesn’t reach. How many other plant species are similarly affected, how many invertebrates, reptiles, amphibians and small mammals get incinerated?

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s