In June we asked our supporters to consider writing to the Scottish Government Minister, responsible for grouse moor reform, to ask them to end the 'Killing to Kill' on grouse moors. Killing to Kill is a grouse moor activity in which hundreds of thousands of animals that are killed - so more grouse can be shot for sport.
The Minister has responded with a letter, noting that our campaign "appears to have generated a considerable amount of correspondence". The letter is reproduced below word for word but first, some analysis of where we are.
We know that an announcement of the parliamentary timetable for grouse moor reform is to be announced in due course, and with the programme for government, due in a few weeks time, may be when we hear more. We also now know that " work on proposals for a licensing system has begun." But, while it's good to hear that the reform agenda will address many elements of the circle of destruction that surrounds this brutal and unnecessary industry, it's the strength of reform REVIVE is concerned with now.
REVIVE's radical reform policy for grouse moors is an inherently sensible middle-ground solution which we hope the government will endorse in full:
No licence to moor burn for grouse shooting
The Government plan to make sure that muirburn (the burning of heather to make conditions better for grouse) will be a land management activity that will require a licence. Very simply, a licence should not be granted to muirburn if the reason is just to increase grouse numbers for sport shooting. It's not ethical, it's not good for the environment and it's completely unnecessary. Scotland should not jump through hoops to let grouse moors do it.
End mass chemical medication
Medicated grit will be looked at by the Government, who are rightly cautious about the mass-use of this toxic chemical medication of grouse, a supposedly wild bird. The only reason for its use is keeping the numbers of this bird unnaturally high for sport shooting. It threatens the environment, other species and is known to aid the spread of disease amongst dense grouse populations. It needs to go.
Stop the 'Killing to Kill'
The main purpose of so many of your letters. The reply from the Minister said that "Ourselves and Nature Scot are eager to hear the views about how the shared approach can take on board points from the International Consensus Principles for Ethical Wildlife Control." This means that they are open to adopting sensible principles into wildlife management legislation which is an encouraging sign. However, the issue of stopping the killing to kill on grouse moors is open-ended. No animal should die just so more grouse can be shot for sport and this simple principle should be adopted by the Government without question.
Conclusion
There are not too many surprises in the letter from the Minister and it's quite consistent with previous statements. The most encouraging aspect is that no doors appear to be closed to the kind of reform we're pushing for, that they will cover all the areas we are pushing on and that announcements could be made relatively soon. Moreover, it's clear the Government are determined to deal with raptor persecution but the legislation must get to the heart of the problem - intensive grouse moor management - or we risk these crimes continuing for the next several years and decades. The strong public support for our calls, is continuing to make a difference and the message is simple enough to break though - that no unsustainable things should take place, so more grouse can be shot for sport.
16 August 2022
Dear _____,
Thank you for your correspondence of 17 June 2022 on behalf of _____, regarding your support of REVIVE (The coalition of grouse moor reform) and its news release of 17 June 2022 regarding the licensing of grouse moor management and the International Consensus Principles for Ethical Wildlife Control. This appears to have generated a considerable amount of correspondence and I would therefore be grateful if you could disseminate my response below to your _____. I have copied in Max Wiszniewski, Campaign Manager for REVIVE, to enable this response to be shared with REVIVE’s coalition of environmental and animal protection groups.
Wildlife crime
The Scottish Government is absolutely clear that the wildlife crime is abhorrent, and that is why we have taken steps over recent years to strengthen the protection of wild species. Most recently, that has been through the Animals and Wildlife (Penalties, Protections and Powers) (Scotland) Act 2020 which was passed into law in July 2020 and makes a number of important changes to the law to strengthen protections for wildlife, including;
- increasing the penalty for a range of wildlife offences to a maximum of 5 years imprisonment
and/or an unlimited fine, including
- killing and injuring wild birds,
- destroying their shelters, nests and resting places,
- possession of certain banned pesticides,
- sale and possession of wild birds eggs, and
- hunting wild mammals with dogs - extending the time allowed to investigate wildlife crimes
- extending the offence of vicarious liability to apply to offences relating to the illegal use of
traps and snares - bringing forward a power to introduce fixed penalty notices for wildlife crimes.
Furthermore, we have committed to reviewing, via an independent taskforce, whether the Scottish Society for the Prevention of Cruelty to Animals should be given extra legislative powers to investigate wildlife. That report is expected later this year.
Licensing of grouse moor management
In regards to grouse moors, following a report Scottish Natural Heritage (now known as NatureScot) which showed that around one-third of tagged golden eagles had disappeared on or around driven grouse moors we commissioned an independent review of grouse moor management. The Grouse Moor Management Group’s report (the ‘Werritty Review’) was published on 19 December 2019.
The Group’s remit was to examine the environmental impact of grouse moor management practices such as muirburn, the use of medicated grit and mountain hare culls and advise on the option of licensing grouse shooting businesses. In doing so, the Group also looked at what could be done to balance the Government’s commitment to tackling wildlife crime with grouse moor management practices, so that this form of management continues to contribute to our rural economy, while being sustainable and compliant with the law.
We published our response to the recommendations of the Grouse Moor Management Group, an independent group tasked by the Scottish Government with assessing the environmental impact of grouse moor management, on 26 November 2020 – Grouse Moor Management Group recommendations: Scottish Government response - gov.scot (www.gov.scot). In responding to that report, the Scottish Government was clear that greater
oversight of the practices associated with grouse moor management is necessary.
And as we set out in 2021 Programme for Government we will – ‘deliver the recommendations of the Grouse Moor Management Review Group as a matter of urgency, including the licensing of grouse moors. Licensing or further regulation will cover the key areas identified in the review, including muirburn, wildlife control, the use of medicated grit and wildlife crime. Licensing will be supported by clear penalties to encourage compliance, as well as additional effort to detect wildlife crime’.
We will announce the parliamentary timetable to implement the recommendations of the Grouse Moor Management Review Group in due course, it is our intention to deliver the recommendations as soon as possible and work on proposals for a licensing system has begun.
A muirburn licensing scheme will include tighter regulation and oversight of muirburn, and a ban on burning on peatland (except in very limited cases as part of an approved habitat restoration programme), as well as clear penalties to encourage compliance. The Scottish Government is currently working with NatureScot to look at options for increased regulation of muirburn. A review of the full Muirburn Code will be undertaken taking into account all relevant evidence, and we will also undertake a review of the current definition of peatland, taking expert advice on whether it should be revised and a stricter definition imposed.
We must continue to protect and restore Scotland’s iconic peatlands which can help us fight climate change and support biodiversity. That’s why we’re also investing £250 million over ten years to support peatland restoration, with a target of restoring 250,000 hectares of degraded peatland by 2030.
Regarding trapping and snaring, The Animals and Wildlife Penalties, Protections and Powers Act was passed in June 2020 and extends vicarious liability to offences involving the illegal setting of traps and snares. Although there are already strict regulations governing the use of traps and snares in Scotland and failure to follow these regulations is a wildlife crime, and anyone doing so may be prosecuted; we will introduce tighter regulations governing the use
of traps on grouse moors as part of our licensing proposals.
We recently completed a statutory review of snaring Snaring: review - February 2022 - gov.scot (www.gov.scot) and will consider any recommendations from the review and will take further action if necessary, including introducing further legislation. Scotland has the most robust laws on snaring in the United Kingdom and we remain committed to highest possible animal welfare standards. However, I have commissioned an additional review, which will look beyond the terms of the Wildlife and Countryside Act 1981 to consider a potential ban on snaring. It will look at land management aspects of the matter, as well as animal welfare.
We recognise that grouse shooting provides benefits for the rural economy and we note that the review of grouse moor management does not recommend the banning of grouse shooting. However, we are determined to ensure that this form of land management is sustainable and compliant with the law. Grouse shooting must, like any other activity, comply fully with laws protecting wildlife and the environment.
International Consensus Principles for Ethical Wildlife Control
Animal welfare remains at the heart of our wildlife management policies. The Scottish Government commitment to introduce a “strategic approach to wildlife management that puts animal welfare at the centre” has been developed and is being implemented through NatureScot’s Shared Approach to Wildlife Management.
Welfare was one of the key considerations of NatureScot’s Shared Approach, and I know this was an area that stakeholders took a great deal of interest in as the approach was developed. The group came to agreement that taking explicit account of animal welfare in wildlife management decisions, and focusing on following best practise was most practicable. As a result, there was no one framework which was adopted as being best.
Ourselves and Nature Scot are eager to hear the views about how the shared approach can take on board points from the International Consensus Principles for Ethical Wildlife Control. The Scottish Government and NatureScot have invited the Scottish Animal Welfare Commission and the Wild Animal Welfare Committee to work with us on where they think we can go further in regards to animal welfare.
The Scottish Government and NatureScot were also recently part of a workshop exploring the where the 7 principles wildlife welfare could be introduced for deer management and we will continue to explore options with stakeholders. I hope this proves helpful.
MAIRI MCALLAN
