More Written Evidence to the Driven Grouse Shooting Debate

Written evidence from name withheld (GRO0321)
Executive Summary
  • The shooting industry and its representatives should be removed from all positions of power where wildlife crime law enforcement policy are discussed or decided upon.
  • Driven grouse moors should be rewilded.  This at a stroke, would remove the many very serious problems of driven grouse moors and provide real, significant, tangible benefits for the whole of society.
  • Driven grouse moor management normally involves very high levels of wildlife crime as well as a range of very serious conservation issues.
  • The illegal persecution of birds of prey in the UK has a very serious detrimental effect, especially on hen harrier and golden eagle populations.
  • Raptor persecution should be treated as organised crime.
  • Detection of wildlife crime on grouse shooting estates is currently ineffective.  Enforcement need to be far greater, with clear and strong backing from political leadership.  A dedicated Wildlife Crime Enforcement team should be set up comprising perhaps 10 officers for Scotland.  Employers and managers must be targeted for prosecution, not simply those actually undertaking the illegal killings
  • Penalties for raptor killings should reflect the fact that these crimes are of a commercial nature.  Custodial sentences should be made routine for employers, managers and employees.  Financial penalties should be linked to the value of the business.
  • The industry has consistently shown no will to reform itself, despite much help to that end for many years.
  • There is practically no accountably to ensure that those managing driven grouse shooting estates adhere to lawful and decent environmental practise.
  • It is clear that driven grouse shooting should be banned.  However, in the absence of such a ban, it is essential that vicarious liability and shoot registration are urgently required.
  • Society is failing to get any benefit from the huge subsidies given to driven grouse shooting estates, indeed these monies are funding very serious environmental degradation.

Introduction
1.  I have a long held interest in environmental issues. After serving as a Royal Air Force Officer, the rest of my career has been in nature conservation and for the last 20 years I have been employed by the RSPB as an Investigations Officer where I have been exposed, first hand to wildlife crime, particularly on grouse moors.  Other than criminals, I am one of the few people who has first hand experience of witnessing raptor persecution on multiple occasions.  This response is provided in a personal capacity.

2.  For the last 20 years, I have had extensive involvement with raptor persecution across the UK.  I have assisted police and other agencies with many criminal enquiries.  I have very extensive fieldwork experience relating to driven grouse shooting.    This has provided me great insight into some of the very serious problems associated with driven grouse moor management.

3.  The massive support for the e-petition to ban driven grouse shooting reveals increasing public concern about grouse moor management and its wide ranging environmental implications.  It is entirely understandable that so many are calling for a ban, given the very long list of significant concerns, a few being:

  • Threats of local extinctions of raptor species such as hen harrier.
  • Widespread, routine illegal killing of legally protected wildlife in large numbers that significantly affects populations and their conservation status.
  • Widespread, routine killing of other species such as mountain hares, stoats, weasels, crows, jays, magpies, rooks, etc.  The extent of this killing is such that it fundamentally changes the biological character of an area.
  • Animal welfare issues relating to how animals are killed.  The use of poisons, traps, shooting and other ways of killing frequently results in a slow, lingering and excruciating death.
  • Loss of biodiversity.  Regular heather burning prevents woodland regeneration.
  • Water pollution.  Heather burning causes particulate matter to be released into the water supply, resulting in increased costs to treat water for domestic use.
  • Increased flood risk.  Heather burning reduces the capacity of the land to hold water, resulting in increased rate of water run off, as was seen recently at Hebdon Bridge.
  • Land use.  An incredible amount of land is dedicated to driven grouse shooting which has no direct benefit for society, provides minimal employment and prevents the land being used in ways which would benefit the whole of society.

I believe it is essential that the government takes these concerns seriously and looks to the benefits for society for alternative land use, particularly rewilding. 

4.  The illegal persecution of birds of prey is well documented.  The link between grouse moor management and raptor persecution is crystal clear, as evidenced by a large number of peer-reviewed scientific papers, the physical location of where hundreds of confirmed incidents of raptor persecution has taken place (on a huge number of individual grouse shooting estates) and the fact that gamekeepers have been convicted for raptor killing crimes far more commonly that all non-gamekeepers combined.

5.  Raptor persecution has a serious, negative conservation impact.  There are huge areas of Scotland (and England) where the distribution, population and breeding success of several raptors is seriously affected by illegal persecution.  Golden eagles, white-tailed eagles, hen harriers, kites, peregrines and goshawks are badly affected by illegal persecution on and around areas managed for grouse shooting.

6.  In 2009, the UK Government made raptor persecution one of the top wildlife crime priorities.  This has not led to improvements in the fortunes of raptors.  The police remain unable to investigate offences in an effective way and to carry out no pro-active or covert work that is essential for effective law enforcement.  Enforcement action need to be far greater, with clear and strong backing from political leadership.  A dedicated, well resourced Wildlife Crime Enforcement team should be set up comprising perhaps 10 Officers for Scotland.  As well as those actually undertaking the illegal killings, employers and managers must be targeted for prosecution.  In Scotland, the SSPCA should be given additional powers.

7.  It is essential to understand that raptor persecution is committed on remote land that is normally free from potential witnesses and by individuals with an intimate knowledge of the land, often operating at night with high tech, essentially military, equipment.  The risk to them of detection is extremely low.  Around 100 confirmed incidents of raptor persecution are recorded each year.  It is not known what percentage of actual incidents this number accounts for, but I believe it will certainly be far, far less than 1%.  The RSPB has received multiple reports of in excess of 100 raptors being killed on individual shooting estates in one year.  Apart from the extremely low detection rate, of the confirmed incidents, the subsequent successful prosecution rate is less than 5%.  As such, the chances of an individual gamekeeper killing a raptor and actually being prosecuted for it are extremely low.  For every successful gamekeeper prosecution, I estimate that there will have been, very roughly, far, far more than 2000 other offences.  Having been convicted, it is likely that the employer will pay any fine, meaning that there is effectively no consequence for a gamekeeper illegally killing raptors or other legally protected wildlife.  [Only one gamekeeper ever, has received a custodial sentence for raptor killing in Scotland.  This is probably the one and only time ever, that a significant deterrent was handed down, and the only occasion where managers or owners were unable to protect their employees from the law.]  When gamekeepers are prosecuted in court, they are normally unusually well represented in court, often by QC’s, even for minor offences, by specialist defence firms.  Having been convicted of wildlife crimes, gamekeepers invariably retain their employment.  This arrangement allows managers and employers to remain very distant from the criminal actions of their staff.  If a gamekeeper was ever to give evidence against his employer or manager, he would have practically no chance of working as a gamekeeper ever again.  Gamekeepers coming forward publicly with information about raptor persecution would effectively make themselves unemployable.

8.  Whilst it is invariably gamekeepers committing the offences on grouse shooting estates, they are not the primary problem.  It is the shooting industry, the managers and employers of gamekeepers, who are the real problem and who create the environment for gamekeepers to operate in and who direct the widespread criminal practices taking place.  The desire to produce incredibly high, unnatural numbers of grouse for driven grouse shooting is the motivation for widespread illegal predator killing.  For many years, there has been numerous partnership working projects between conservationists and the shooting industry to find ways to enable this hobby to continue legally, but despite much help, there has never been any serious engagement from the shooting industry and the illegal killings continue.  If the driven grouse shooting industry was serious about tackling problems like raptor persecution it could easily do so very quickly.  It is essential to fully comprehend that this will never happen without serious and meaningful governmental action.

9.  The shooting industry has a long and consistent history of acting without honour; it is of fundamental importance to understand this.  It abuses pseudo-science to its own predetermined ends.  It manipulates data.  It sources obscure scientific studies which are irrelevant, portraying them as of fundamental importance.  It is disingenuous.  It lies blatantly.  It says it will do one thing and then does another.  This sort of behaviour, this desire to corrupt when it has effect on such large areas of our country and on so much of our wildlife is unacceptable and has no place in civilised society. As such, the shooting industry must be removed from all bodies that have any power to influence policy on law enforcement relating to shooting estates.

10.  I have absolutely no doubt that any voluntary approach or code of conduct will never be effective.  It is clear a robust and enforceable legal framework, backed up with the resources for rigorous enforcement, is needed to ensure the environment is properly protected. 

11.  It appears that sometimes employers/managers may be aware that their gamekeepers are illegally killing raptors, but ignore it.  On others estates, it appears that gamekeepers are given explicit instructions to illegally kill raptors and are given specialist equipment to that end.  Some estates spend vast sums of money supplying specialist equipment, firearms, night-sights, thermal imaging sights, illegal poisons, to enable their gamekeepers to commit crimes and avoid detection. 

Conclusion. 
12.  Without major legislative change, there is no prospect that the very serious problems associated with driven grouse shooting will change. 
Given that grouse moors cover such a large area of our country and that they impact in such a massive and detrimental way, on all sections of our society, this demands that government acts decisively. 
A ban on driven grouse shooting would at a stroke, terminate a wide range of very serious problems.  Also, this would free up a large area of land for rewilding which would significantly benefit the whole of society and create new employment opportunities.
October 2016