In November last year we blogged about some second-hand information we’d received that the Moorland Association (the grouse moor owners’ lobby group in England) was interested in obtaining licences from Natural England for the lethal control of Marsh harriers (see here).
The issue was alleged to have been raised by Amanda Anderson (Director, Moorland Association) at a meeting of the Raptor Persecution Priority Delivery Group (RPPDG – the English/Welsh version of the PAW Raptor Group) on 9 November 2017.
The news was shocking. It was utterly ludicrous that grouse moor owners might consider this species such a significant threat to their over-stocked grouse populations that they would seek licences to kill it.
Marsh harriers are Amber listed on the UK Birds of Conservation Concern and are recovering from a virtual population wipeout – down to one known breeding pair in 1971 thanks to a combination of illegal persecution, habitat loss and DDT and currently with an estimated breeding population of 400-450 pairs.
[Male Marsh harrier by Markus Varesvuo]

Marsh harriers are locally common in some areas such as East Anglia but still extremely rare or absent in many others. They most commonly breed in lowland wetland habitat, particularly reedbeds but increasingly on farmland too. This female was found shot next to a lowland partridge release pen in East Yorkshire in 2016. Very rarely do they breed on upland grouse moors although when they do, they are illegally targeted by men dressed as gamekeepers.
When we blogged about the news that the Moorland Association was interested in licences for this species, Amanda Anderson denied the allegation with a two word tweet: “Complete nonsense“, but ignored all requests to clarify the MA’s position.
Amanda wasn’t the only one wanting to keep a lid on this. Philip Merricks (Hawk & Owl Trust) weighed in, even though he wasn’t at the meeting, and Chief Inspector Martin Sims, then head of the National Wildlife Crime Unit and who was at the meeting told us, “There was never any discussion about Marsh harriers” (see comments on this blog – scroll down towards the end).
It’s taken us a year, but we’ve finally got some pretty damning evidence that suggests this conversation did take place at the RPPDG meeting last November.
It’s taken us so long because DEFRA has given us the run around on a series of FoIs we submitted between Nov 2017 and July 2018. We asked for the minutes of the 9 Nov 2017 RPPDG meeting, and, suspecting that those minutes may be santised given the public furore over the alleged Marsh harrier licensing, we also asked for copies of all correspondence between RPPDG members relating to those minutes before they were finally approved.
DEFRA repeatedly failed to comply with the FoI regulations over a period of eight months and didn’t provide us with the information so eventually we resorted to threatening to report them to the Information Commissioner. Shortly afterwards, in August 2018, DEFRA finally released some (but not all!) the info we’d requested.
As expected, the minutes of the Nov meeting were heavily redacted: RPPDG-minutes_9-Nov-17_final_redacted
We looked for any discussion about licences for killing Marsh harriers but only found this:

There was an inference about licensing but nothing unequivocal, and the redactions meant we couldn’t be sure the subject had been raised by Amanda or another MA rep, nor with whom she/another rep was having the conservation.
The latter question was answered when we realised that whoever had done the redactions on those minutes hadn’t done a very good job and if the redacted version was pasted in to another programme the original, unredacted version appeared: Unredacted RPPDG minutes_9_Nov2017_final
The unredacted version was useful as it confirmed that Amanda was the only representative of the Moorland Association at that meeting and it also revealed that the above conversation had taken place between Amanda and ‘GS’ , who was identified in the minutes as Ginny Swaile from Natural England:

But still no mention of the word ‘licence’ or ‘lethal control’, just an inference.
So then we turned our attention to the correspondence between RPPDG members as they discussed the approval of the minutes. DEFRA released SOME of this correspondence (we know it wasn’t all of it) but did any of the members mention the inclusion/exclusion of a discussion on Marsh harrier licensing in the draft version of the minutes?
From what we can see, most of them didn’t mention Marsh harriers, although some of this email correspondence was redacted in parts and also the marked-up copy of the draft minutes was not made available to us, so it’s hard to be sure that most of them chose to ignore the subject, although that’s what it looks like, apart from Natural England and the Moorland Association who clearly commented on the issue but the redactions hide the details:
BASC comments (British Association for Shooting & Conservation)
CLA comments (Country Land & Business Association)
MA comments (Moorland Association)
NE comments1 (Natural England)
NE comments2 (Natural England)
NGO comments1 (National Gamekeepers Organisation)
NGO comments2 (National Gamekeepers Organisation)
Police comments (National Wildlife Crime Unit)
Welsh Gov comments (Welsh Government)
Yorkshire Dales NPA comments (Yorkshire Dales National Park Authority)
But there were two other RPPDG members whose correspondence we were particularly interested to see – the RSPB and the Northern England Raptor Forum (NERF).
First up, the RSPB’s correspondence. Interestingly, and perhaps tellingly, DEFRA did not release the RSPB’s initial comments made to the RPPDG when the minutes were being discussed in early December 2017. Instead, they released two pieces of correspondence, one dated 18 January 2018 and the other dated 12 February 2018. Why do you think the early December correspondence was missing? Perhaps DEFRA ‘forgot’ to include it.
RSPB comments1 (dated 18 January 2018: Bob Elliot (then Head of RSPB Investigations) just asking DEFRA and RPPDG Chair Police Supt Chris Hankinson what was the status of the minutes)
RSPB comments2 (dated 12 February 2018: a heavily readacted email from Bob Elliot to the group saying he didn’t feel the minutes were an accurate reflection of the meeting but his reasons for this were all redacted):


Then we looked at the correspondence from NERF. Again, DEFRA had released two pieces of correspondence, one dated 7 December 2017 where Steve Downing (NERF Chairman) tells the RPPDG he is out of the country but will respond in detail the following week, and the other dated 17 April 2018 where Steve writes to Supt Hankinson telling him he objects to the sanitised final version of the minutes and that he intends to raise this issue at the next RPPDG meeting. Interestingly, and again perhaps tellingly, DEFRA did not release Steve’s email from December where he laid out his comments on the draft minutes. Hmmm.
NERF comments1 (dated 7 December 2017)
NERF comments2 (dated 17 April 2018, see copy below):

It was pretty clear to us by then that both the RSPB and NERF had objected to the way the minutes had been edited but we were still none the wiser about the specific details.
Having had a belly full of DEFRA’s ineptitude with our long-running FoI requests we decided to approach the RSPB and NERF directly to see if they would be prepared to share their unredacted RPPDG correspondence so we could see exactly what was going on.
Being gentlemen of principle, both Bob and Steve agreed but on the condition that they would only share with us their comments, and would redact the comments of any other RPPDG member. Fine by us, because the redacted names can be pieced together from the unredacted version of the minutes for those who want to look.
Here’s what they sent us:
The unredacted version of Bob’s RSPB email to the RPPDG dated 12 February 2018 (we have added the red box for clarity):

The unredacted ‘missing’ email from Steve to the RPPDG, dated 12 December 2017, outlining his recollections of the meeting on 9 Nov based on notes he’d taken during that meeting (we have added the red text box to highlight the bit about licences for the lethal control of Marsh harriers on grouse moors):



So there you have it. Two members of the RPPDG recall a discussion between the Moorland Association and Natural England about the potential for obtaining licences to kill Marsh harriers on grouse moors. None of the other RPPDG members seem to recall it, not even Amanda. Imagine that.
Here’s a reminder of Amanda’s response to our original blog in November last year:

For the record, we’ve checked with Natural England to see whether anyone has submitted an application for a licence to kill Marsh harriers but according to NE (if you believe them), nobody has. Yet.
This sordid episode of what looks like a massive cover-up /suppression exercise is no more than we would expect from the RPPDG. We’ve criticised this so-called ‘partnership’ for several years because, like many other ‘partnerships’, it has contributed absolutely nothing of any value towards the conservation of birds of prey since it was established in 2011. If Supt Chris Hankinson was still in charge of it we’d be calling for his resignation right about now.
Kudos to Bob Elliot (now Director of OneKind) and Steve Downing (NERF Chair) whose integrity speaks volumes. Bob must be delighted not to have to endure this cabal anymore.
However, as some of you may be aware, there’s a new Chair in town and he’s looking to shake things up at the RPPDG. Police Supt Nick Lyall took on the role in September 2018 and already we’ve seen more action from him in the last seven weeks than we have from Chairs over the previous seven years.
He’s bringing transparency to the group (we’ve already had a conversation about the need to provide un-redacted minutes from RPPDG meetings without having to chase them via FoI requests), he’s writing a blog to keep people informed of RRPDG activities, he’s active on Twitter (@SuptNickLyall), he’s inviting more conservation-focused groups to join the RPPDG to counter the current game shooting industry imbalance, and later this week we’ll be attending his national raptor persecution workshop where he intends to gather ideas to put together an action plan for the RPPDG, with measurable targets, instead of letting it fester from year to year with no direction and no accountability. If any blog readers have any ideas please leave a comment – we know Nick will be reading this post (to his credit, we gave him warning that this blog was coming and he didn’t try to dissuade us from writing it).