Last chance to have your say on Scottish Government’s consultation on grouse moor reform

In October this year, the Scottish Government finally launched a consultation seeking the public’s views on its plans for grouse moor reform. The consultation closes on Wednesday 14th December 2022, so this is your final chance to provide your views on what is being proposed.

Proposals under the Wildlife Management (Grouse) Bill include plans to introduce a licensing scheme for grouse shoots, muirburn licensing and increased regulation on the use of traps used to kill so-called ‘pest’ species on grouse moors.

To say that driven grouse moor reform is long overdue is somewhat of an understatement. This ‘sport’ has been virtually unregulated since it began approx 150 years ago and much of what happened in the Edwardian and Victorian age still goes on today (albeit more intensively and commercially in many areas) including the illegal killing of birds of prey, which is the principle reason the Scottish Government has finally decided to act.

August 1922: M McDonald, a member of Lord Woolavington’s House Party, with a gamekeeper in a hide during a grouse shoot on Mannock Moors. (Photo by W. G. Phillips/Topical Press Agency/Getty Images)

The campaign to get to this stage has been long and brutal and has come at a high personal cost to many of the individuals involved. It has been a hard-fought battle and this is why it’s so important that people now take part in the consultation process. The grouse-shooting lobby is urging its members to contribute – I’ve been sent a copy of how they are intending to respond, which includes ludicrous claims about there being ‘insufficient evidence’ of high levels of raptor persecution on grouse moors (I know!!). I’ll share their response in a separate blog but it highlights why we need to show a strong response in support of the Government’s licensing proposals.

That’s not to say the licensing proposals are perfect – they’re not – but this is our opportunity to make sure that they can be as watertight as possible.

I’m aware that some campaigners on ‘our side’ are very unhappy that licensing is coming in; they would prefer to see an outright ban on driven grouse shooting. That’s a view I understand but right now, a ban is not on the table. It’s either a licensing scheme or the status quo. Those are the two options. If licensing proves to be ineffective, then the campaign for a total ban will be strengthened. Maintaining the status quo is unthinkable, so let’s be pragmatic and work to secure the best standard of licensing that we can get.

The consultation is easy to respond to and anyone can participate – you don’t need to be a member of an organisation, your view as an informed member of the public is just as valid.

REVIVE, the coalition for grouse moor reform, has provided an easy supporter’s guide to help you complete the consultation – see here.

Most of it is a tick-box exercise, but there are also sections where space is provided for you to add your own comments. REVIVE has listed some suggested topics that you may wish to include, but has deliberately not provided statements for cut and paste. It’s important that you use your own words to have greater impact – if everyone submitted identical responses, the Government is likely to lump them all together and count them as a single response instead of the views of many individuals.

I’ll be submitting my own personal response this weekend. As mentioned above, I’m generally in support of the principle of licensing but I do have concerns about effective enforcement. Without that, a licensing scheme will be utterly pointless. I will be urging the Scottish Government to introduce a licensing fee that is sufficient to fund rigorous and effective compliance monitoring and enforcement, and to implement that fee now rather than later, as has been proposed.

I’m also deeply concerned that the proposed licensing scheme excludes the shooting of red-legged partridges and pheasants on land managed for grouse shooting, and instead focuses just on the shooting of red grouse. There is an increasing body of evidence that demonstrates red-legged partridges (RLPs), and to a lesser extent, pheasants, are being released on grouse moors for shooting, either as a proxy for red grouse (in low stock years) or as an additional target species to boost income. When the grouse shooting licence scheme is introduced, it would be very simple for shoot managers to switch from shooting red grouse to shooting RPLs, thus side-stepping the licence (which is currently red grouse specific) and continuing with the very activities that this licencing scheme seeks to end (illegal raptor persecution). It’s a gaping loophole that needs to be closed off before it is exploited.

[This photograph was taken on Buccleuch Estate earlier this year]

For those who haven’t yet read the Government’s proposals, you can do so here:

If you want to use REVIVE’s guide for responding to the consultation, please click here.

Remember, the consultation closes on Wednesday 14th December 2022.

Thank you for your help and support.

UPDATE 12th December 2022: Don’t laugh, but here is the grouse-shooters’ consultation response to licensing (here)

UPDATE 13th December 2022: ‘Golden opportunity to tackle bird of prey killings & stop peatland burning in Scotland’ – RSPB blog on grouse moor licensing (here)

11 thoughts on “Last chance to have your say on Scottish Government’s consultation on grouse moor reform”

  1. Thank you Ruth for attaching the links.
    I would suggest it is vital everyone following this blog responds to this consultation.
    I think we can be sure the shooting industry will be encouraging it’s followers to respond, to try and create as much opposition to licensing as possible.
    The fact that so many followers of this blog are so knowledgeable about wildlife conservation and raptor persecution should ensure that those in favour of licensing can project a balanced and meaningful response as to why licensing is necessary to try and stop the unnecessary, cruel and criminal persecution of birds of prey and other wildlife.
    Very admirable that the Scottish government have opened the consultation to everyone. It is a chance not just for the people of Scotland, but for everyone to have a say on what hopefully will be landmark legislation, and something I hope the other governments /assemblies in the UK soon follow suit on.
    It is vital we get this legislation right first time. It is capable of delivering what it sets to achieve, and it isn’t full of loopholes and get out of jail cards, which seems the blight the legislation surrounding fox hunting!!

  2. It seems to me a great shame that these spoilt rich people have to throw all this money away to blast away at innocent little birds and an even greater shame that they seem to have
    no self awareness or grasp on the effect they are having on wild creatures most of them suffering constant abuse and cruelty.

  3. As someone who grew up in a small village in the Highlands I saw quite clearly the lack of investment, lack of jobs created by the large remotely owned grouse estates. Nothing has changed! Grouse moors bring no substantial work for the local environment. If we could open up the Highlands towards a more ecological positive direction by removing the killing of factory raised grouse it would be more in keeping with the 21st century. The killing of our birds of prey and our mountain hairs is a disgrace and the ecological damage done to the burning of the natural vegetation which these large estates carry out should be stopped immediately. I would like to see these estates closed or at least accurately monitored to apply for a licence for very limited killing of grouse. The effect that these factory farmed grouse, which are not shot for fun do to the wild bird population is not yet fully recognised and understood. This point alone should be taken into consideration.

  4. I have my comments pretty much done & dusted ready to write out on their form tonight. I’m especially keen to hammer home the point that they will need plenty of “field officers” to make this work, and that those will have to be highly motivated & robust individuals to match up to the money and capacity for low-cunning that many of the big estates have ample of. This will need significant funding from day one via a licence fee, no two ways about that. I also think that the specialist investigatory skills of RSPB, LACS, SSPCA will be required for the wildlife crime side (as the govt licencing field officers cannot be expected to be superhuman and will likely be generalists rather than specialists) and that the field investigators of these organisations should be officially co-opted / legally accredited into working with increased powers under the auspices of this licencing scheme. A licensing scheme that works WILL force out of business the intensive operations because they cannot exist shooting the ridiclously high numbers of grouse while at the same time leaving raptors alone to breed in peace. It is a mathematical impossibility fully understood on all sides. If in ten years these estates are still shooting the numbers that they are these days, and the raptors haven’t made a come back – then it will be clear the scheme is a sham and I think decent and law-abiding people will be forgiven for “taking the gloves off” and taking things into their own hands.

  5. I live in Hertfordshire and frequently visit Scotland to enjoy the wildlife there-especially Birds of Prey. I feel it is the duty of everyone who is aware of this consultation and who really cares for our beleaguered wildlife to respond to this essential consultation. This is a great opportunity to at least attempt to stamp out the evil of Raptor Persecution and Victorian attitudes among certain powerful interests and bring them into line with modern thinking

  6. As of low income, slum Glasgow origin, but with a church upbringing hammering home compassion to all living creatures, I, with my friends, “looked after” the poor cats that had been either forsaken or bombed out of their homes, by procuring slivers of gutted fish at the fishmongers, and distributed them among those poor scrawny animals. It was inculcated by parents and teachers to never be cruel to an animal, and I abhorred any boy who would harm wild birds with slings and airguns. However, another inculcation process was operating, and had been so for a long time, and that was the glamour of fox hunting, with Christmas cards showing packs of hounds with red-topped hunts people on wonderful horses, like knights defending the countryside. The Dickensian Christmas was always around us at this time of year, in films, cards and whatever punched home the case for the protectors of our countryside, interweaving a cruel sport into what was acceptable behaviour. Pubs carried the message with “Bayhorse”/Fox and Hounds or whatever conveyed their right to dominate the countryside controlling “vermin”. The late 1940’s and early 50’s saw thousands be decanted to new housing schemes bordering on hitherto undeveloped countryside, and that was a marvel to young people never exposed to a cornucopia of wildlife. Fox hunting and shooting was commonplace in that new-to-us environment, but we were kept well away from it. University for many first-time-in-the-family students, brought a liberal light into some of our lives, when we took up humanitarian causes, either via politics or charities, that found open minds to influence, and thus began the new age of animal welfare and environmental protection, as powers that would strongly grow to influence our society.

    New forces emerged in the forms of Greenpeace for marine life protection, along with Friends of the Earth to awaken people to the contamination of our environment. Anti-vivisection, farm animal protection, wildlife protection saw many forms develop from local save the Hedgehog/Red Squirrel etc to internationally threatened Tigers, Elephants and whatever had been butchered by once thought of heroic big game hunters. Veganism has grown; fur has been condemned; bullfighting avoided by tourists; circuses lost their Big Cats and Elephants; certain types of zoo disparaged; some scientists avoiding animals in research and their use in cosmetics experiments banned, and much more. All of this story has been to show that blood sports have become despised by a large majority of the UK population, through the Enlightenment brought to it by the missionaries from dedicated and courageous, decent people working and volunteering for the relevant charities. The issue under discussion, that of managing our natural landscape in a more humane and economically enriching way, has come along way from when most of this abusive behaviour began two hundred years ago, with the development of hunting estates resplendent with royalty and rich others. The display of what they had slaughtered was staggering, when seen in the photographs of the Victorian times. It is ridiculous that so much landscape is still treated as a killing zone by people who have no other purpose than enjoying the killing of game birds, and the concomitant wiping out of any other form of life affecting numbers available for blasting. No rational politician of humane and practical disposition should support this egregious “industry” to exist in the modern day Scotland and elsewhere. Some of the gamekeepers employed have been exposed as addicted to dog fighting and badger/fox baiting, and others not adverse to spreading dangerous toxins in contaminated bait. Such a world they exist in along with their patrons, is a dystopian one, far away from what should be an state with humanity moving for a more compassionate existence of this threatened planet.

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