In October this year, the Scottish Government finally launched a consultation seeking the public’s views on its plans for grouse moor reform. Proposals under the Wildlife Management (Grouse) Bill include provisions 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. The consultation closes this Wednesday (14th December 2022).
A couple of days ago I wrote about the response that conservationists were planning to submit (see here), including a guide for your own response.
I mentioned in that blog that the grouse shooting industry was also corralling its members, seemingly in an attempt to flood the consultation with arguments designed to weaken the proposed licensing scheme. This shouldn’t come as any surprise, given the industry’s previously very public histrionics against licensing, as well as its denials that any sort of reform is even required (e.g. see here, here, here, here, here and here).
The landowners’ lobby group Scottish Land & Estates (SLE) has been quietly distributing a document amongst its members and supporters called ‘A Call to Action for Guns’ in which it goes through the Scottish Government’s consultation document and provides suggested responses. The full document is published at the end of this blog but I just wanted to highlight a few of the sections because if nothing else, they demonstrate the brass neck of this lot.
Here’s the opening statement:
Here’s their suggested response to Question 1 of the consultation:
The Scottish Government should laugh this response out of the door. High levels of wildlife crime on (some) grouse moors has been unequivocally demonstrated time and time and time again. Indeed, ongoing raptor persecution on some driven grouse moors is EXACTLY what has prompted the Scottish Government to bring in licensing, as stated repeatedly by successive Environment Ministers (e.g. see here and here). To pretend otherwise, at this stage of the game, simply highlights the industry’s intransigence and confirms why Ministers consider licensing necessary. It’s not as though the grouse shooting industry hasn’t been given multiple warnings and opportunities to reform (e.g. see here).
Here’s SLE’s suggested response to Question 10 of the consultation:
Again, the grouse shooting industry is asking for the status quo to remain because it knows how difficult it is to bring about criminal convictions for wildlife offences on grouse moors, given the remoteness of the locations, lack of witnesses, and the extraordinary lengths that the criminals will go to hide their crimes (e.g. see here). Even when sufficient evidence is gathered for a criminal prosecution, it is often ruled ‘inadmissible’ or ‘not in the public interest’ to proceed (e.g. see here, here, here, here, here, here). The odds have been stacked against the wildlife crime enforcers for decades and this proposed legislation seeks to address that imbalance. If I was a criminal gamekeeper or criminal sporting agent or criminal grouse moor owner, I too would be worried. Those who aren’t criminals should have nothing to fear.
And yes, the consequences of losing the right to shoot are significant – that’s kind of the whole point. If you don’t want to suffer the consequences, don’t break the law. It’s quite straightforward.
Here’s SLE’s suggested response to Question 14 of the consultation:
This is just trying to fudge the issue. I don’t think any informed person would argue that the illegal killing of raptors “occurs exclusively on grouse moors”. Of course it doesn’t. But there’s a massive weight of scientific evidence and crime statistics to demonstrate that illegal raptor persecution occurs disproportionately on some driven grouse moors, and THAT is what this licensing scheme is seeking to address.
And as for the “real risk of sabotage against sporting rights holders by those who oppose grouse shooting”, this argument that gamekeepers and estates may be ‘set-up’ was also used by SLE in 2012 when objecting to the introduction of vicarious liability for raptor persecution offences (see here). Ten years on, there hasn’t been a single case where this has been shown to have happened, but there have been plenty of cases where gamekeepers have been caught committing criminal offences as part of their daily routine.
I don’t have time (nor the will) to go through each of SLE’s consultation responses but if you’re interested, here it is in full:
For those of us who don’t want to see the status quo remain, and are sick to the back teeth of the grouse-shooting industry getting away with wildlife crimes, especially against birds of prey, there’s still time for you to participate in the public consultation (it is open to everyone). Even if you just tick the boxes (without needing to write additional comments), it all helps to demonstrate to the Scottish Government that this is an issue we care about. If you want to go further and add some commentary, you’ll find suggested guidance here.
The consultation closes the day after tomorrow (Weds 14th December 2022).