Author: RaptorPersecutionUK

The ability for Scottish Natural Heritage (SNH) to impose a General Licence (GL) restriction order on land where there is evidence of raptor persecution taking place came in to force on 1 January 2014. This measure, based on a civil burden of proof, was introduced by then Environment Minister Paul Wheelhouse in response to the continuing difficulties of meeting a criminal burden of proof to facilitate a criminal prosecution.

Four years on, SNH has only imposed four GL restrictions. The first two were imposed in November 2015 (one for Raeshaw & Corsehope Estates in the Borders and one for Burnfoot & Wester Cringate Estates in Stirlingshire). Then there was a temporary halt for almost two years as Raeshaw & Corsehope Estates made a legal challenge which resulted in a judicial review in January 2017. The court’s decision was announced in March 2017 and SNH was found to have acted properly and lawfully. Since that decision was announced in March 2017, SNH has imposed two more GL restrictions: one for Edradynate Estate in Perthshire in September 2017 and one for an unnamed mystery gamekeeper in Aberdeenshire in September 2017.

In early October 2017 we submitted an FoI request to SNH to find out how many more cases were currently under consideration for a GL restriction. We were pretty shocked with the response:

“At the time of your request, no General Licence restrictions were under consideration”.

This surprised us as we knew of at least nine other cases that would potentially qualify for a GL restriction. Those nine cases were as follows:

Newlands Estate, Dumfriesshire. Gamekeeper William (Billy) Dick was convicted in 2015 for killing a buzzard on the estate in April 2014. He had thrown rocks at it and then stamped on it. The estate owner, Andrew Duncan, was prosecuted for alleged vicarious liability but then the Crown Office dropped the prosecution in April 2017, saying it wasn’t in the public interest to proceed (see here).

Brewlands Estate, Angus Glens. A gamekeeper was prosecuted for the alleged repeated setting of a pole trap on this estate between 9-17 July 2015. The Crown Office dropped the prosecution case in April 2017 because the video evidence was deemed inadmissible (see here). Another gamekeeper on this estate thought this result was hilarious.

Unnamed pheasant-shooting estate, Lanarkshire. In September 2015 a set pole trap was discovered on a bench directly outside a pheasant-rearing pen on an unnamed estate. Police Scotland apparently dropped the case, for unknown reasons.

Gamekeeper in Ayrshire. In May 2016 a named gamekeeper was charged after allegedly being caught using gin traps on a neighbouring farm of the estate on which he was employed. The Crown Office dropped the prosecution in March 2017 after reportedly ‘getting the dates wrong on its paperwork’ (see here).

Invercauld Estate, Aberdeenshire. In June 2016, walkers discovered a number of illegally-set spring traps staked out on a grouse moor. Two of the traps had caught a Common Gull by the legs. The bird had to be euthanised. There was no prosecution. ‘Some action’ was taken by the estate but whatever this action was it has remained a closely-guarded secret between the estate, the Cairngorms National Park Authority and the Scottish Government (see here).

Glendye Estate, Aberdeenshire. In January 2017 a number of illegally-set spring traps were discovered on a grouse moor on this estate. The Estate Factor and gamekeeper reportedly removed the traps and denied all knowledge of who had set them (see here). According to Police Scotland, there was insufficient evidence for a prosecution.

Leadhills Estate, South Lanarkshire. On 4th May 2017, witnesses observed the alleged shooting and killing of a hen harrier on this estate. Police Scotland appealed for information (see here & here). As far as we’re aware, there are no impending prosecutions.

Leadhills Estate, South Lanarkshire. On 31 May 2017, witnesses observed the shooting and killing of a short-eared owl on this estate. The corpse was retrieved and sent for a post-mortem. Police Scotland appealed for information. As far as we’re aware, there are no impending prosecutions.

Unnamed grouse shooting estate, Monadhliaths. On 7 June 2017, a member of the public found a buzzard caught in an illegally-set spring trap that had been staked out on an unnamed grouse moor in the Monadliaths. The buzzard was released. Police Scotland appealed for information. Inspector Mike Middlehurst of Police Scotland commented, “Unfortunately, there are some who continue to deliberately target birds of prey; there is nothing accidental in the setup of these traps“. As far as we’re aware, there are no impending prosecutions.

In late October 2017 we submitted another FoI to SNH to ask about these specific cases, to find out if any were under consideration for a GL restriction and if not, why not.

SNH has now responded as follows:

Part of this response makes sense, but part of it makes no sense at all.

As we’ve said on this blog before, it’s perfectly right and understandable that if SNH is actively considering a GL restriction for a particular estate or individual, then those details should not be published until the decision to impose a GL restriction has been made and the estate/individual has had a chance to appeal that decision. We fully accept that position. [And we note that according to the above response, SNH is now actively considering two cases for a potential GL restriction, although we don’t know whether those two cases are included in our list of nine potential cases. Time will tell].

However, if a decision has been made NOT to impose a GL restriction, for whatever reason, we do not accept, as SNH claims, that publishing that information would ‘prejudice the process’. How could it, if the decision has already been made?

We also don’t accept, as SNH claims, that ‘it is in the public interest not to release the information’. How can this lack of transparency possibly be in the public interest?

Defining what is meant by ‘public interest’ is a tricky thing to do. This article from The Guardian in 2012 provides an excellent overview from the perspective of various journalists and explains that it can be more of a philosophical interpretation rather than a definition set out by statute. However, the Press Complaints Commission defines it as ‘including but not confined to detecting and exposing crime, or serious impropriety; protecting public health and safety and preventing the public from being misled by an action or statement of an individual or organisation‘.

In the nine cases we’ve listed above, information about the crimes that were allegedly committed are already in the public domain, so it’s difficult for us to understand that if SNH has made a decision NOT to consider a GL restriction in any of those cases, why SNH believes it to be in the public interest NOT to explain those decisions.

We’ll be appealing SNH’s decision to withhold this information from the public.

Intensive grouse moor management not only has catastrophic consequences for the environment (and especially for raptors), but the end product carries serious public health risks, too.

A couple of years ago we wrote a blog about the use of medicated grit to dose red grouse with a parasitic wormer drug called Flubendazole.

There is a statutory requirement to remove veterinary drug residues from food destined for human consumption no later than 28 days before the food is available for sale.

We’d learned that the use of medicated grit on grouse moors was largely unregulated (surprise!), that some grouse moor managers were using a super-strength drug that was 10 times, and sometimes 20 times, the strength permitted for use in the UK, and, most incredibly, that the Government’s statutory agency (Veterinary Medicines Directorate (VMD)) responsible for monitoring meat to ensure harmful drugs are not entering the human food chain, had not ever tested a single red grouse for residues of Flubendazole because, staff said, they didn’t know where to find dead red grouse (see here).

Photo of a medicated grit tray on a Yorkshire grouse moor, by Ruth Tingay

Prompted by our investigation, the VMD said it would begin to screen recently shot red grouse for veterinary drug residues in 2016, but that VMD staff wouldn’t visit grouse moors to examine whether medicated grit had been withdrawn within the statutory 28-day period because that was beyond their remit. Instead, they would rely on the grouse moor managers to act within the law (ha!).

We followed up on the new testing regime and in 2016 we learned that the VMD had managed to screen a pathetic total of six (yes, six!) red grouse in the whole of the UK (4 in England, 2 in Scotland), out of a conservatively estimated 700,000 shot birds.

Last month, at the end of the 2017 grouse shooting season, we asked the VMD how many red grouse they’d managed to test for veterinary residues in 2017. Here’s their response:

Are they taking the piss? Eight red grouse tested in the whole of the UK? That’s hardly reassuring for consumers, is it?

And once again, the VMD claims not to know the origin of the birds it tested. Talk about incompetent. What if one of those birds had tested positive for residues of Flubendazole? The VMD wouldn’t have been able to take follow-up action because they wouldn’t have known the name of the grouse moor on which the bird had been shot!

So, yet another reason not to risk your health by eating potentially contaminated red grouse. Not only might it contain unknown quantities of the anti-parasitic worming drug Flubendazole, it might also contain:

• Excessive amounts of toxic poisonous lead (over 100 times the lead levels that would be legal for other meat – see here)
• Unknown quantities of the veterinary drug Levamisole hydrochloride (also used in chemotherapy treatment for humans with colon cancer – see here)
• Unknown quantities of the pesticide Permethrin (used topically to treat scabies and pubic lice; probably not that great to ingest – see here)
• There’s also a high risk the grouse will be diseased with Cryptosporidiosis (see here).

Two shot red grouse ready for cooking, yum yum. Photo by Ruth Tingay

Time for the filthy grouse shooting industry to be better regulated? God, it’s well overdue. You can sign this new petition calling for the introduction of a licensing scheme for driven grouse moors, here.

If you think licensing wouldn’t go far enough, you can also sign this new petition calling for a total ban on driven grouse shooting, here.

These two petitions apply only to England. The Scottish Government is way ahead of the Westminster Government on this issue and an independent review of grouse moor management practices has just begun, and many of us anticipate that it will result in the almost inevitable conclusion that licensing needs to be introduced. We know the review group will be examining the use of medicated grit as part of its remit, and we expect the group to find these latest results from the VMD’s inadequate testing regime to be of great interest.

A couple of days ago we blogged about an article in the Gazette & Herald that showed sackfuls of shot pheasants that had been dumped in woodland in the North York Moors National Park (see here).

Here are some of the photographs the newspaper didn’t publish, presumably as they’re too grim. Thanks to the blog reader who sent them to us.

Welcome to the National Park!

In November 2017, a small group of conservationists was invited to visit 10 Downing Street for a conversation about their environmental concerns with Sir John Randall, Theresa May’s recently appointed special advisor on the environment.

There’s nothing unusual about that. Conservationists routinely meet with advisors, MPs and Ministers to discuss such issues. But this was no ordinary group. It comprised a bunch of committed and environmentally aware teenagers, as follows:

Findlay Wilde, aged 15, schoolboy.

Jordan Havell, aged 16, schoolboy.

Josie Hewitt, aged 19, first year ecology student at University of East Anglia.

Georgia Locock, aged 18, first year ecology and economics student at University of York.

Incredibly, and hilariously, the discussion at this meeting, and subsequent correspondence between Sir John Randall and schoolboy Fin Wilde, has resulted in a number of pro-hunting/shooting MPs accusing Ministers of ‘plotting war on fieldsports’!

This was the headline for an article in yesterday’s edition of The Telegraph, heralded as an ‘exclusive’, no less:

The furore seems to have stemmed from somebody reading Fin Wilde’s most excellent blog (here) where he wrote about the meeting at Number 10 and shared some of his later non-confidential correspondence with Sir John.

If you actually read Fin’s blog, and the comments made by Sir John, you’ll see nothing there to suggest a ‘war’ on fieldsports, just a series of concerns held by most reasonable-thinking members of society and a desire for the game shooting industry to clean up its act.

Sir John shared many of Fin’s concerns, including the continued illegal killing of birds of prey on driven grouse moors, other environmentally damaging practices associated with intensively managed driven grouse moors, the need to increase sentences for wildlife crime, the removal of firearms certificates for those convicted of wildlife crime, the problems associated with the industrialisation of some pheasant shoots, the continued use of lead ammunition, educating children about climate change, the impact of Brexit on environmental legislation, and the continued single use of plastics.

You’d think that MPs would welcome such thoughtful contributions from a group of teenagers who care enough about the environment to stand up and exercise their democratic right to voice their concerns, wouldn’t you? These are engaged and motivated youngsters who are a credit to society.

But no! A number of (unnamed) MPs are apparently up in arms, feeling threatened and apparently feeling ‘privately appalled’ by it all!

What are they actually saying here? That they don’t think firearms certificates should be removed from convicted criminals? That the illegal killing of raptors on grouse moors doesn’t need to stop? That the use of lead ammunition doesn’t pose a serious health and environmental threat?

We were particularly taken aback that the Telegraph article noted that Georgia Locock ‘has marched in protest against grouse shooting‘. So what? Why mention it? Are they trying to portray Georgia as some sort of militant extremist whose views should be taken with a pinch of salt? They couldn’t be further from the truth.

It’s a shame the Telegraph article didn’t mention the pro-shooting MPs who were recently photographed smiling at a parliamentary reception held for the Moorland Association with a number of gamekeepers in attendance, one of whom has a criminal conviction for, er, wildlife crime on a driven grouse moor.

Well done Fin, Jordan, Josie & Georgia – keep going, you’re doing a terrific job.

UPDATE 4 January 2018: In response, Fin Wilde has written a brilliant open letter to the Telegraph’s Chief Political Correspondent, Christopher Hope. Read it here.

Two new peer-reviewed papers from the GWCT confirm the significant spread of a disease in red grouse on intensively managed driven grouse moors, transmitted through the unregulated use of communal medicated grit trays.

The disease, respiratory cryptosporidiosis (also known as ‘Bulgy Eye’) has been, until recently, almost entirely associated with captive poultry flocks that have been kept at high density, usually for breeding purposes. It was first detected in wild red grouse in 2010 and since then has spread rapidly and has affected high density red grouse on half of the 150 grouse moors in northern England and has also been recorded in Scotland, although the extent of its spread in Scotland appears to be a well-kept secret. Perhaps we’ll learn more through the Scottish Government’s review of grouse moor management practices, particularly as one of the review group’s special advisors is Adam Smith from the GWCT.

We’ve known about the spread of this disease for a couple of years, and learned a great deal from a GWCT-led grouse moor seminar in 2015 where the preliminary research findings were presented (see here). The latest publications confirm the findings, although it’s worth bearing in mind the disease may well have spread further since these studies were conducted (2013-2015).

The first of the new papers was published in November 2017 and confirms that communal medicated grit trays distributed across grouse moors act as a reservoir for disease transmission via the faecal droppings of grouse visiting the trays:

Baines, D., Giles, M. & Richardson, M. (2017). Microscopic and Molecular Tracing of Cryptosporidium Oocysts: Identifying a Possible Reservoir of Infection in Red Grouse. Pathogens 6: 57.

This paper is open access which means we’re allowed to share it in full:

Crypto_Identifying infection reservoirs_red grouse_Baines et al2017

A typical grit tray contaminated with grouse faecal droppings on a Scottish grouse moor, photo by Ruth Tingay

The second paper has recently been accepted by the British Ornithologists Union journal Ibis and details the impact of Bulgy Eye on red grouse populations and highlights the economic loss this may cause to the driven grouse shooting industry:

Baines, D., Allison, H., Duff, J.P., Fuller, H., Newborn, D. and Richardson, M. (2017). Lethal and sub-lethal impacts of respiratory cryptosporidiosis on Red Grouse, a wild gamebird of economic importance. Ibis: accepted online 26 December 2017.

Unfortunately this paper is not open access so we’re only permitted to share the abstract (although we have read the full paper):

The significant spread of this disease is entirely of the grouse-shooting industry’s own making. If they weren’t so keen on cramming as many red grouse as possible on to their driven grouse moors (sometimes up to x 100 the natural density) and then using medicated grit to prevent the natural strongyle worm-induced grouse population crashes every few years (which they have successfully achieved), then Bulgy Eye should never have been a problem.

The question now is, what, if anything, are they going to do about it?

Presumably they’ll do something, if not in the interests of animal welfare or conservation, then certainly in the interest of stifling the economic losses caused by the widespread prevalence of this disease.

In the concluding remarks of the second paper, Baines et al say: “…. a general reduction in grouse densities, brought about through either de-intensified management, increased shooting rates or both may need to be carefully considered“.

May need to be considered? Good grief, you’ve got a disease epidemic on your hands, all of your own making, and you say these proposals may need to be considered?

We’d say the industry needs to do something pretty damn quickly, and the immediate removal of communal medicated grit trays should be right up there as the first obvious step.

An article in yesterday’s Gazette & Herald reports how hundreds of shot pheasants have been dumped in sacks near Helmsley, in the North York Moors National Park.

The article (here) says a local rambler first found four sacks of dead gamebirds in Hawnby Road on 26 November 2017. The rambler returned to the site last week and reportedly found several hundred more dead pheasants piled up in heaps.

According to a quote attributed to Liam Stokes of the Countryside Alliance, “It is worth pointing out that these birds all appear to have been breasted – the breast meat has been removed. Of course the rest of the carcass should have been disposed of appropriately, but it does appear that the meat from these birds has in fact entered the food chain“.

Amazing how Liam can see that “all these birds appear to have been breasted”. Can he see inside the sacks? Has he examined every one of these hundreds of dumped birds? Or is he in fact just trying to exert some serious damage limitation because he knows how politically damaging these images are for the game shooting industry?

It’s not the first time shot gamebirds have been dumped as waste in the countryside – as we’ve seen before here, here, here. Indeed, it’s a growing problem for the game shooting industry, as we blogged about just last month (see here).

It’s bad enough that an estimated 50 million non-native pheasants and red-legged partridge are released, unregulated, in to the countryside every year (yes, that’s 50 million EVERY YEAR) for so-called sport shooting, including inside our national parks, but then to just dump them as a waste product is a PR disaster for an industry under increasing scrutiny for its environmentally damaging activities.

Have a read of this article written by Charles Nodder of the National Gamekeepers Organisation who revealed in July that even though many shoots are struggling to get their shot birds in to the food chain, they are still releasing (and shooting) more and more and more every year.

Responsible? No.

Sustainable? No.

In dire need of regulation? Yes.

UPDATE 31 December 2017: More shot pheasants dumped in North York Moors National Park (here)