The final date is 5th October. Have your say here.
Here is my submission
Living for a time in the Forest of Bowland was an introduction in detail to the raptor persecution problem, both by gamekeepers and egg-collectors. Whilst I was there the RSPB installed a camera to guard the Peregrine nest against thieves and when walking the moors I discovered an unknown Peregrine nest and also stumbled upon historic sites with 24hr manned guards to protect the nests. I would often see Hen Harriers on the moors and I remember our neighbour saying he saw one every day on his way off the moor to drive to work and jokingly worried about his hens. The Peregrine pair on my sisters farm were from a nearby commercial quarry which had been disturbed on at least one of those years by the quarry owner’s son discharging a firearm in the quarry. He claimed ignorance of the Peregrines and was not charged. That particular pair bred successfully at least twice on my sisters farm and the new site which I found was almost certainly of this same pair but was very substandard so any person or fox could have walked in to disturb them. The site at my sisters farm was in a wood and not at all suitable for Peregrines and they have never bred there subsequently because of the increase in tree growth. It is obvious that in those three or four years the Peregrines were disturbed at their favoured territory and that is why they chose inferior sites. That was 25 years ago when the North-west Water (now United Utilities) land was the last stronghold of Hen Harriers in England. Then Peregrines were just starting to make a come back in the lowlands and the uplands, like Bowland, were their stronghold.
Now there are no Peregrines or Hen Harriers breeding on the whole of the Forest of Bowland, none. Something is very very wrong. This is the equivalent of the man made extinction of the Passenger Pigeon and closer to home, the Great Auk. We know what is happening and are doing nothing about it. This is the wildlife equivalent of tobacco or climate change denial which the government is colluding in and supporting.
Experiments are very difficult in the wild but apart from Hen Harriers on Langholm there was another example which was as close to a controlled experiment as can be, which was the Red Kite re-introduction scheme. Red Kite is another good indicator species as it also has a fairly high productivity rate. Red Kites were re-introduced in the Chilterns and the Black Isle at the same time and in the same numbers. The Chilterns population is now beyond counting but well over 800 pairs and doubling every 3 years whilst the Black Isle is almost static at about 60 pairs. The Chilterns population reached that number of pairs in 1997/1998. There is no difference in the productivity on the two populations so there are no natural causes. The only difference is the proximity of driven grouse moors. Persecution has set back the Black Isle population by 17 years. The same thing is occurring in north-east England and Yorkshire (Smart et al. 2010, RSPB 2015). This is another of the many hidden costs of driven grouse shooting.
There is scientific consensus that Hen Harriers are being persecuted on driven grouse moors. This is unequivocal. The most conservative estimates by the Game Wildlife Conservation Trust still point out that in the UK, ‘If all potential habitats were occupied, present numbers could more than double, to an estimated 1660 nesting females’ (Potts 1998). There are now, at the last count, 580 pairs. Scotland is highly representative of English grouse-moors and there, 55-74 females Hen Harriers are killed each year which is 11-15% of the UK population of breeding females and that figure does not include males or immatures (Etheridge et al. 1997).
I won’t go into detail on the science, I am sure many other submissions have covered that and in many ways it is irrelevant to my essential premise. Illegal killing is continuing on a vast scale and the crime figures and maps and the extinction of the Hen Harriers in England and on driven grouse moors throughout the UK is the proof. The Langholm experiment was the proof.
The game lobby will tell us that jobs will be lost and waders will suffer without grouse shooting. This is a binary argument, with and without grouse shooting. No one has done a study to show alternative scenarios with conservation friendly managed moorland which would be an easy and highly beneficial option. The grouse lobby do not include the hidden costs so their figures which have been anyway debunked (LACS News) are biased and nothing more that conjecture. There is some evidence that some waders benefit on some grouse moors but not all waders. This petition is about driven grouse-moors so only studies there and not grouse-moors in general are scientifically valid. Is the grouse lobby producing evidence on wader numbers on only driven grouse-moors? If not it is irrelevant to this debate and should therefore be inadmissible. The same applies to the employment figures and so called income. Are the incomes of the driven-grouse moors including the hidden costs of public subsidies, tax evasion, carbon emissions, lead shot pollution, flood risk, water quality, damage to environment by roads, drainage ditches, car parks etc., loss of biodiversity, financial as well as spiritual cost of loss of raptors and re-introduction schemes, burden to the courts and police and in Scotland the evasion of vicarious liability by off-shore accounts? Can anyone put a price on the first child that dies from accidentally ingesting a poison, which is just a matter of time?
But most importantly no comparison has been made with other conservation management schemes. We can land a craft on a comet millions of miles away, don’t listen to anyone who says conservationists can’t manage a moorland beneficially for waders. Don’t doubt for one second that if these same waders were found to carry any disease that threatened grouse bags that they would not be exterminated as rapidly as are Mountain Hares in Scotland. Any waders which benefit from grouse moors are an accidental by-product which could just as easily be reversed if grouse are threatened. Everything is about grouse numbers and nothing else.
There has been no study to compare the jobs and income of a grouse-moor with a similar moor devoted to wildlife tourism. On Mull eagles have been shown to bring in £5 million to the local economy every year (RSPB News) The grouse lobby are not taking studies like this into account in their biased balance sheet.
But for the sake of argument let’s say the grouse lobby are correct. If driven-grouse shooting is beneficial to waders and gamekeepers we must then as a society ask, are we willing to allow the law to be broken for the sake of profit for the super rich and a few jobs. It needs emphasising that every single grouse moor driven or not is benefiting from the crime of killing Hen Harriers. Hen Harriers take Red Grouse so every time a grouse is taken by a Hen Harrier it eats in to game bag tallies and therefore the profit and marketability of every grouse moor and each Hen Harrier killed boosts the profit and prestige of the moor. This is ABC and especially true when so many Hen harriers are killed that they approach extinction as is the case in England. There are no Hen Harriers in England and on Scottish driven grouse-moors and this profits every grouse-moor owner. I cannot think of any other example of a similar situation where an elite and rich minority are allowed to pursue an activity which is profiting and, as Langholm has demonstrated, is dependent on crime. It doesn’t matter if a particular estate is totally innocent it is profiting and dependent on crime in the form of illegal persecution. Please whoever is reading this take a moment to let this sink in. Where else in society is this kind of situation allowed? I can’t think of one and I certainly can’t think of one where it is condoned by government (as in the response by this government to this petition) and that would survive the smallest public scrutiny.
I cannot state strongly enough, that I feel that this is completely abhorrent and totally unacceptable in this day and age. Is this the price we must pay for the employment of a few gamekeepers which we know contain many criminals? In the UK the most recent figures show that 70% of those convicted of raptor persecution were gamekeepers (RSPB 2009), the figures in Scotland are higher and more representative in habitat of English grouse-moors where the figure was 86%. A high percentage of these gamekeeper crimes occur on grouse moors where 57% of all poisoning crimes occur (RSPB 2015). Does the grouse lobby take into account that those same gamekeepers could also be employed as guides in wildlife tourism? The grouse lobby likes to think in binary, spin doctor terms but lacks in depth research, imagination and willingness in finding innovative solutions (e.g. diversionary feeding worked on Lanhgolm but they rejected it).
So not only are we as a society being asked to turn a blind eye to crimes which profit an elite and rich minority, we are asked to put the employment of a group with a known criminal element, above the law. That same group which serves that same rich elite minority which in England is unaccountable to it’s henchmen through lack of vicarious liability. Worse than that we the public are financing these crimes in the form of farm subsidies. Farm subsidies where sheep are only used to mop up ticks in order to protect grouse. This is feudalism plain and simple.
I presume that those who oppose a ban of driven grouse shooting believe that the innocent should not suffer for the crimes of others but I would argue why should they be allowed to profit from those crimes and why should the tax-payer be supporting it.
If we as a society are willing to put the profits and crimes of a minority above the protection of our birds of prey and the public good and the law of the land then we have to change the law. It is as simple as that. Driven grouse shooting and birds of prey especially Hen Harriers cannot, as proven at Langholm. co-exist. Society has to decide one way or another. The choice is a ban or a change in the law to allow the killing of all birds of prey. There is no other logical conclusion.
Increased legislation has not worked in Scotland as the crimes are almost impossible to detect and even more difficult to prosecute. Nothing short of a ban will work.
Etheridge, B., R. W. Summers, and R. E. Green. “The Effects of Illegal Killing and Destruction of Nests by Humans on the Population Dynamics of the Hen Harrier Circus Cyaneus in Scotland.” Journal of Applied Ecology 34.4 (1997): 1081-105. http://www.jstor.org/stable/2405296?
LACS News. Shooting Animals for Sport: Worthless. League Against Cruel Sports. http://www.league.org.uk/%7E/media/Files/LACS/Reference-material/4pp-Shooting-Briefing-paper.pdf
Potts, G.R., 1998: Global dispersion of nesting hen harriers Circus cyaneus; implications for grouse moors in the UK. Ibis, 1998. 140(1): p. 76-88.
RSPB News http://www.rspb.org.uk/news/details.aspx?id=282239
RSPB 2009. Birdrime 2009. http://www.rspb.org.uk/Images/birdcrime_tcm9-260567.pdf
RSPB 2015. The Illegal Killing of birds of Prey in Scotland 1994–2014: A Review. https://www.rspb.org.uk/Images/illegal-killing_tcm9-411686.pdf