Letter summary:
- We support Government plans to licence all muirburn
- Increasing grouse numbers for sport shooting is not an acceptable reason to get that licence
- More of our peat should be protected and not burned upon
- Deep peat should be redefined as 30cm deep to widen this protection
Dear Cabinet Secretary,
We, the signatories to this letter, support the Scottish Government proposal, as part of the Wildlife Management and Muirburn (Scotland) Bill, that all muirburn should require a licence, regardless of whether it takes place on a grouse moor or not.
We also support proposals to redefine deep peat depth. However, we recommend the Scottish Government redefines this as 30cm (as opposed to 40cm). This would take Scotland beyond the ambitions of the UK Government. In addition, we request you consider the purposes under which a licence to muirburn might be requested and accepted.
At least 163,000 hectares of Scotland’s landmass is regularly burned for grouse shooting, particularly concentrated in certain areas of the country. It is estimated that around 40% of the burned area has taken place over deep peat (as it is currently defined).
Even if the muirburn code becomes a mandatory legal requirement of land managers, the large areas in which muirburn takes place will be hard to police without significant resources and without continued significant risk to our vital peat reserves.
We note that BASC Scotland (in response to government plans on February 28th, 2023) said it would be ‘unfeasible, laborious, and impractical for land managers to be expected to measure peat depth across their land as part of a licensing regime’.
We believe this argument fails to account for the Government’s climate change efforts. As the grouse shooting industry has shown time and time again, particularly with regards to raptor persecution, voluntary restraint cannot always be relied upon. Moreover, against the recommendations of the UK Climate Change Committee they simultaneously argue, that best practice is widely followed while attempting to make the case that burning over peat is actually a good thing and should be allowed.
To draw a different conclusion on how muirburn should be handled, to make the regulation of muirburn manageable, in addition to our above points we propose that a licence should not be given for muirburn when the purpose is increasing grouse numbers for sport shooting.
In situations where there is evidence to support muirburn taking place, where alternatives like cutting are not available, we would not oppose this. These situations could include responsible research, creating strips for wildfire breakage points (as opposed to large less effective patches that are common on grouse moors) while peat should be avoided. We also support wider efforts from the Fire Service and the Scottish Government on public education initiatives and training land managers of all types to prevent wildfires where possible.
Large monocultures like heather moorland present their own challenges to fighting wildfires and that a more diverse mosaic of flora, fauna and trees can alter wildfire intensity and make them easier to tackle. Moving away from muirburn on our moors will unlock our land’s potential to provide far better resistance to wildfires over time, and also enable greater biodiversity and carbon sequestration potential.
The main point is that due to the risk of our vital peat reserves; our lack of faith in the grouse shooting industry to look after and prioritise peatland over grouse shooting; the difficulty and resources it would take to effectively enforce the licence; and because keeping so much of our land in state of monoculture stops the development of greater biodiversity: a licence should not be given for muirburn when the reason is as unnecessary as ensuring more grouse can be shot by a few people for sport.
We strongly urge you to consider and adopt the above position. To do so would be to aid the Government’s own stated goal to transition to more appropriate, economic and biodiverse land uses for our people, our wildlife and the environment.
Signed,
REVIVE
John Muir Trust
Friends of the Earth Scotland
Scottish Raptor Study Group
Rewilding Britain
League Against Cruel Sports Scotland
Raptor Persecution UK
Reforesting Scotland
Common Weal
North East Mountain Trust
