Tag: scottish gamekeepers association

This is a guest blog from Duncan Orr-Ewing, Convenor of the Scottish Environment LINK Deer Group.

LINK Deer Group comprises of RSPB Scotland, National Trust for Scotland, John Muir Trust, Scottish Wildlife Trust, Woodland Trust Scotland, Trees for Life, Ramblers Scotland, and Nature Foundation.  

Duncan’s blog encourages readers to participate in the Scottish Government’s current consultation on Managing Deer for Climate and Nature (details at the foot of this blog). The consultation closes this Friday (29th March 2024).

A POSITIVE FUTURE FOR SUSTAINABLE DEER MANAGEMENT IN SCOTLAND

Alongside the progress of the Wildlife Management and Muirburn Bill, which was approved by the Scottish Parliament last week, reforms to deer management in Scotland are also being considered by Scottish Government.

Measures to update the Deer (Scotland) Act 1996, and to bring it into line with modern day expectations around the need to restore nature and to combat climate change are making steady progress, and are now out to public consultation. New deer legislation will be included in a Natural Environment Bill expected to be laid before the Scottish Parliament in late 2024.

In the absence of natural predators, such as lynx or wolf – both exterminated in Scotland several centuries ago – deer populations are managed by humans to prevent damage to a wide variety of public interests. Damage can be caused by high deer populations to the natural heritage; to agriculture; to forestry; and also to human health and safety (road traffic accidents and Lyme disease).

Deer management is carried out to high humane standards by expert stalkers following Deer Management Best Practice, and of course most of the end product – venison- then goes into the human food-chain, and is widely regarded as a healthy alternative to farmed meats.    

Most of Scotland’s uplands are managed either as grouse moor or as deer forest, and therefore along with grouse moor management, the land management practices which occur in deer forests are hugely important for protecting and enhancing our native wildlife and their habitats in the uplands.

The latest population estimate for the combined four species of deer (two native and two non-native) that occur here is over 1 million animals. This represents a doubling of the deer population in the last twenty years. For further background and deer timelines see here.

As with grouse moor management and the independent Grouse Moor Management Review Group (“Werritty Review”), the Scottish Government commissioned an independent review of deer management in 2017 and which reported in 2020, here. It came up with 100 recommendations for improvements to current systems and processes, and to foster better sustainable deer management practices in Scotland. These recommendations were largely accepted by Scottish Government – see here.

These recommendations of the independent Deer Working Group now form the backbone of the deer legislative proposals for the Natural Environment Bill.

However, in addition the Scottish Government is proposing a few further, and we think largely beneficial measures. These include provision for what are being called Deer Management Nature Restoration Order powers to NatureScot, the competent deer authority, to take compulsory action to reduce deer numbers to enhance habitats and species in targeted areas. This is intended to help deliver the outcomes of the Scottish Biodiversity Strategy.

We encourage individuals to respond to the current public consultation on new deer legislation in Scotland which closes on Friday 29^th March. This a relatively straightforward exercise and can be done quite quickly – here.

See also the LINK Deer Group response for further advice and suggestions on how you might respond – here.

Duncan Orr-Ewing

Convener, LINK Deer Group

ENDS

Editor writes: Some of you may have seen the Scottish Gamekeepers Association’s hysteria in response to the Government consultation, refusing to engage with it and claiming that their members may suffer a ‘mental health toll’ if they have to cull heavily pregnant hinds due to the proposed changes in the deer hunting season- see here.

As usual, the SGA hasn’t provided proper context. There are proposed changes to female deer seasons to essentially make them all the same for all species. It is still entirely discretionary when deer are shot within the proposed new seasons.

If folk are worried they can take their cull earlier in season. It’s the same with the now abolished season for male deer. It does not mean stalkers have to cull male deer all year round and some people may stick to the old male deer season.

The bottom line for conservation though is more deer need to be culled, especially hinds, to reduce burgeoning deer populations. It is the female deer that are critical in that respect.

If you’re able to complete the consultation by Friday (no specific deadline has been given on Friday) that would be great, thanks. The link is here.

The passing of the Wildlife Management & Muirburn (Scotland) Bill yesterday, voted for by almost everyone (except the Scottish Tories and the SNP’s Fergus Ewing MSP) has been the hot topic of conversation today.

For many, the Bill has been the focus of daily life for exactly one year, when it was first introduced on 21 March 2023. And of course, the issue of raptor persecution on grouse moors, which is what triggered this Bill in the first place, has been the focus of daily life for many of us for longer than we care to remember, well before the introduction of the Bill.

With such a long history of campaigning, the responses to the passing of the Bill yesterday were entirely predictable. Conservationists are very happy with it, recognising it as an important stride forward but fully cognisant that our work here is not yet done. You can read responses from REVIVE, the coalition for grouse moor reform here, from OneKind here, and from RSPB Scotland here.

The grouse shooting industry is furious with it, mainly, from what I can tell, because it feels humiliated. It’s an industry founded on privilege and self-entitlement and has done pretty much what it wants for about 150 years, unhindered by the societal rules by which the rest of us must abide. To have the Scottish Parliament vote to introduce legislation that will finally hold the industry to account is hugely embarrassing. Imagine having to listen to a Government Minister say this about you in the Parliament’s debating chamber:

“There were those who disagreed with the principles of the bill, but if the grouse-shooting community had shut down raptor persecution— stopped the killing of our most iconic birds of prey—we would not have had to legislate in this way. Sadly, that community did not shut it down, so it is now up to us to make sure that it does so. It is for that reason that the bill is before us today”. – Scottish Agriculture Minister Jim Fairlie, 21 March 2024.

I guess that’s why there wasn’t a single representative from the industry sitting in the public gallery at Holyrood yesterday.

Not that I have any sympathy. The grouse shooting industry has been given chance after chance after chance to rid itself of the criminals within. It has failed to do so, instead going on the offensive, repeatedly denying that raptor persecution even exists and conducting a disgusting campaign of hate, smear and abuse targeted against those who were prepared to call them out.

I don’t believe that every grouse shooting estate is ‘at it’, but I do believe that there are more ‘at it’ than are not. And even the ones that are not, they do know who is responsible – the entire industry knows – but the industry has refused to blacklist. Now they’re all going to suffer the consequences.

You can read the responses to the passing of the Bill from the Scottish Gamekeepers Association here, from Scottish Land & Estates here and from BASC here.

BASC’s response is particularly interesting as it claims the new legislation “is unworkable for gamekeepers and land managers” and “will be ruinous to the rural economy“. Does that mean that BASC thinks that sustainable grouse moor management isn’t viable? That grouse moor management relies upon the illegal persecution of birds of prey, the use of inhumane snares to trap foxes and other wildlife and the routine setting alight of deep peat moorland? That would be an extraordinary admission!

So what happens next?

Now the details of the Bill have been finalised and passed, NatureScot can get on with finalising the details of the codes of practice for grouse shoot licensing and muirburn licensing that will be used to support the implementation of the new legislation. I’ll post details when they become available.

The timing of the ban on snares and wildlife trap licensing is yet to be determined.

It is fully expected that grouse shoot licensing will be in place for the start of the 2024 grouse shooting season on 12th August. The muirburn licence is more complicated and it is anticipated that won’t be in play until September 2025.

Here is a copy of the Wildlife Management & Muirburn (Scotland) Bill as passed:

UPDATE 26 March 2024: More reactions to grouse moor licensing in Scotland (here)

In news that will come as no surprise whatsoever, a new study has revealed that toxic lead ammunition is still being used widely to shoot birds in coastal intertidal and riparian habitats across Scotland, even though its use was banned in these habitats 18 years ago.

The new study, which has just been published in the journal Conservation Evidence, analysed discarded shotgun cartridges at various wetland locations and found that approximately half appeared to contain lead shot, which hasn’t been permitted for use over Scottish wetlands since 2005.

The ban on using lead shotgun ammunition over wetlands was introduced to try and reduce the amount of lead poisoning in wetland birds and the subsequent poisoning of predators that might scavenge the shot birds, particularly certain raptor species (e.g. see here and here).

Here’s the summary of the study (full paper available at the foot of this blog):

Similar legislation (with slight variations) was introduced in England in 1999 after a voluntary ban on the use of lead shotgun ammunition over wetlands failed.

However, a number of studies since that new legislation was introduced (see here) have shown high levels of non-compliance with the law, for example 68% non-compliance in 2001-2002; 70% non-compliance with the law in 2008-2009 & 2009-2010; and 77-82% non-compliance with the law in 2013-2014.

Another study published in 2021 concluded that since the regulations were introduced in England in 1999, an estimated 13 million ducks have been shot illegally using lead shotgun ammunition, with an annual average of approximately 586,000 ducks, representing approximately 70% of the total ducks shot (see here).

Tellingly, this 2015 paper that included the findings of a questionnaire survey of shooters’ behaviour and attitudes revealed that one of the main reasons for non-compliance with the law was the shooters believed they “were not going to get caught” i.e. shooters knew that using lead ammunition would not involve penalties as the law is not enforced. This is a really common feature of wildlife crime in general, but particularly raptor persecution crimes, which I’ve written about before (e.g. here). It doesn’t matter how stiff the penalty is, if the offender thinks there’s little to no chance of being caught then it’s worth the risk of committing the crime.

The 13 million illegally shot ducks also provide an excellent example of why it’s idiotic to calculate the extent of a crime based on the number of convictions (as Professor Simon Denny tried to do in his recent ‘truly objective‘ claim that raptor persecution isn’t a widespread issue on grouse moors – see here). If we classify every one of those shot ducks as a separate crime, there has only ever been one successful prosecution out of a potential 13 million crimes (and that prosecution only happened because the offender shot a swan in front of witnesses, mistaking it for a goose whilst on a pheasant shoot in North Yorkshire). One conviction from 13 million crimes demonstrates quite clearly that a lack of prosecutions / convictions does not equate to a lack of crime!

It’s an important lesson for the Scottish Parliament as it considers the Wildlife Management and Muirburn (Scotland) Bill – if there is insufficient monitoring and enforcement accompanying the new legislation on grouse moor management practices, the offenders will continue to commit their crimes (i.e. killing birds of prey and lighting fires on deep peat) because they’ll know the chances of being caught are pretty slim.

The Westminster Government is currently considering a range of options for phasing out the use of lead ammunition (see here), after ignoring the overwhelming scientific evidence for years and instead choosing to support the shooting industry’s (then) refusal to get rid of toxic lead ammunition (e.g. see here and here).

Three years ago some (but not all) in the game-shooting industry realised the game was up and proclaimed a five-year voluntary phase-out of toxic lead ammunition (largely, I believe, because they didn’t want to have a ban enforced upon them). However, three years into that five-year phase out, things aren’t going too well (see here) and many UK supermarkets are still selling poisonous game meat to unsuspecting customers for both human consumption (here) and for pet food (here).

The HSE is due to report its recommendations about the use of toxic lead ammunition to Government by 6th November 2023. DEFRA Minister Richard Benyon told Green peer Natalie Bennett recently that the DEFRA Secretary of State ‘will be required to make a decision within three months of receipt of the opinions, with the consent of Welsh & Scottish Ministers‘ (see here).

Anything less than an immediate ban on the use of toxic lead ammunition for killing any species in any habitat (not just some species in some wetland habitats), will be challenged.

Here’s the full paper on the significant non-compliance of the law by shooters in Scotland, who are still using toxic lead shotgun ammunition to kill birds over wetlands, 18 years after it was banned. Well worth a read:

UPDATE 13th September 2023: Is DEFRA can-kicking the decision to phase out use of toxic lead ammunition by gamebird shooters? (here)