Saturday 12 November 2016

© Mark Avery's Report about The Debate

The ‘debate’ – some first thoughts

By Adrian Pingstone (talk ยท contribs) (Self-photographed) [Public domain], via Wikimedia Commons
By Adrian Pingstone (talk · contribs) (Self-photographed) [Public domain], via Wikimedia Commons
On Monday afternoon and evening a Westminster Hall debate was held where UK MPs discussed the idea that driven grouse shooting should be banned because 123,077 people had signed an e-petition. The e-petition system was set up by Parliament so that the people could bring matters about which they felt strongly to the attention of parliament and ask for action.  The threshold of 100,000 signatures to secure such a debate was set up by parliament.  It’s a way for the people to influence those with power which stretches back to Magna Carta and beyond.  It’s generally regarded, and I agree, that it is a better way of getting the attention of those in power than rioting and other illegal activities.  But it does depend for its effectiveness on those in power listening and responding. Here are a few thoughts on Monday’s debate, through all of which I sat, but I will be coming back to some of these subjects in more detail over the next few days.
  • Steve Double MP (he who thinks the Badger is the UK’s largest rodent) behaved appallingly as the MP chosen from the Petitions Committee to introduce the debate.  His role might have been to signal that this was a subject of considerable interest but not to parade his uninformed views which were basically saying ‘The people who signed this e-petition are wrong’.  I would have no problem with him expressing that view as an individual MP, but not in his role as a Petitions Committee member introducing a subject brought to Parliament by a large number of people. Mr Double was disrespectful of the process and of those who signed the e-petition and he ought to be ashamed of himself. I will come back to this.
  • Charles Walker MP, is a very impressive speaker in terms of delivery but traduced my views in his speech. As a holder of a degree in political science he might, perhaps, consider that he is inexpertly qualified to speak quite so dogmatically about science and he was one of several MPs (all Conservative MPs in favour of driven grouse shooting) who referred to me as Mr Avery when in this particular context it might have been more appropriate to recognise my doctorate in science (and a reasonably impressive publication record too). I will come back to this too.
  • The Conservative shooters turned out in very strong numbers including the Chair of the Countryside Alliance, Simon Hart; the chair of the APPG on Shooting (and Conservation ha ha), Geoffrey Clifton-Brown; grouse moor owner and GWCT trustee, Richard Benyon; the former director of public affairs for the British Field Sports Society, Nick Herbert; and last, and obviously not least, the disrespectful Nicholas Soames.
  • There were no Liberal Democrats MPs present in the Hall at any time through the 3-hour debate (unless I missed them – do tell if I did) and none made a contribution to the debate despite Liberal Democrat constituencies (and ex-constituencies of which there are many more) being strong supporters of the e-petition.
  • The SNP were thin on the ground despite Scotland producing a stronger than average support for the e-petition.  Let me thank Richard Arkless for making two useful interventions in the debate (and may I thank several of his constituents for encouraging him to take part in the debate) and Lisa Cameron for one and Margaret Ferrier for attempting three times (rather than the one recognised in the transcript) to intervene in the Minister’s closing remarks.  Having thanked those three, it was a poor show overall from the SNP who had the ability to make a speech in the closing and passed this up.  The Scottish experience, particularly in respect of vicarious liability ought to have been part of this UK debate.  If I had a SNP MP I would feel short-changed.
  • The Labour Party, of which I am a member, was also thin on the ground. Many thanks to those who turned up and most especially to Rachael Maskell and Kerry McCarthy for their excellent efforts. Angela Smith did quite well but lacks the killer instinct in these debates and as the Hen Harrier Champion might have been expected to get stuck in rather more on their behalf.  It was good to see one of the ‘Sodden 570’, Barry Gardiner MP, attend the early part of the debate although he could not speak as he is a Shadow Minister. Thanks too to Stephen Timms for making several interventions, to Holly Lynch for her intervention and to Stephen Twigg for spending some time in the debate. But where were the Labour scourges of the Establishment in this debate, and where were those with large numbers of signatures in their constituencies and where were those with an interest in nature conservation? It was a disappointing turn-out and one which was remarked upon by many Conservative MPs, who were legion, in tones of surprise.  I think the Cosnervative shooters were geared up for a bigger argument, but they were given a very easy time.
  • It was good to see Caroline Lucas arrive in the debate and make a couple of interventions and I know she had other pressing engagements which prevented her longer attendance – but if she had spoken, then in the allocated seven minutes she would have wiped the floor with the shooters on the other side. It’s a pity cloning is not yet possible and nor yet is proportional representation – I wonder which we will get first?
  • the RSPB got quite a lot of criticism (almost as much as Chris Packham and I did) from the Tory ranks, and a little from Labour too, for failing to have a worked-up rather than talked-up licensing system available. but they also got a fair amount of ill-informed and rather random criticism from the Conservative shooters. After being slagged off the RSPB was exhorted to come back into the fold of the Defra Hen Harrier Inaction Plan – the world is a bizarre place.
  • there was a lot of nonsense spoken: mostly by men (although Antoinette Sandbach and Therese Coffey obviously didn’t want to be left out) and mostly by Conservatives.  I will come back to this, for sure.
  • Several MPs were dismissive, or worse, of the views of those who had, through a process that parliament itself had set up, brought this matter to the ancient confines of the Palace of Westminster.  Parliament itself set up this process – it asked the electorate to voice its views through this particular system. And very few subjects, certainly very few as niche in the general scheme of things as driven grouse shooting, get the support necessary for such a debate.  The least that might be expected of MPs in such a debate is that they might recognise that the subject is one of concern. I have no issue with Conservatives who shoot piling out in droves to speak against a ban on grouse shooting, but that they did so with such deplorable bad manners when the 123,077 people had brought them to this debate is bringing parliament’s own process into contempt. But at least the Tories turned up!
  • the minister’s summing up was as complacent as everything else that has come out of Defra in the last couple of years. No change in policy was signalled. No concern about the current state of affairs was mentioned.
Petitions are a much better way of getting the attention of decision-makers than riots, but especially when MPs listen.  We need to keep raising the issues.  We will be heard.

Wednesday 2 November 2016

More evidence from Calderdale Raptor Study Group

Written evidence from Calderdale Raptor Study Group (GRO0267)

I am a former Police Officer and for me this year marks 50 years of enforcing the law. I served with West Yorkshire Police and was appointed a Divisional Wildlife Crime Officer [WCO] in 1992 and Force Wildlife Crime Officer in 1995. Investigating raptor persecution was always high on the agenda of WCOs throughout the country and in 1997 I introduced a national scheme to collect DNA samples from Peregrine Falcons, Goshawk and Merlin. At that time this was a major step forward in the investigation of crimes against birds of prey. Unfortunately since then the volume and frequency of raptor persecution has increased significantly and the number of species involved has risen to include Short-eared Owls, Red Kites and Hen Harriers. All of these species are associated with the uplands and land managed for driven grouse shooting.

Raptor persecution is a Partnership for Action Against Wildlife Crime priority, focusing in England and Wales upon Red Kites, Peregrine, Goshawk and the beleaguered Hen Harrier. In 2003 I was invited by Chief Constable Brunstrom, the ACPO lead on Wildlife Crime to formulate the Police response to Hen Harrier persecution. Research reveals that there is sufficient habitat in England for c300 pairs of Hen Harriers and yet there are only a handful breeding annually and very rarely on land used for driven grouse shooting. Natural England [now English Nature] had already identified persecution of Hen Harriers on grouse moors as the most significant threat to the species. In 2004 I launched ‘Operation Artemis’. The plan was both comprehensive and simple. It set out the issues, the legislation, land owner / professional responsibility, the Police response and the likely outcome of a prosecution case where an individual was convicted of persecuting Hen Harriers. In 37 years of Policing I had never known a Police lead project that was so transparent and honest when dealing with organisations and individuals who may be involved with or tainted by, a criminal activity.

Additionally Operation Artemis asked landowners to assist the Statutory Nature Conservation Organisations [SNCOs - NE, CCW and SNH] throughout the UK, to increase the Hen Harrier population by not undertaking any works, such as erecting fencing during the breeding season or heather burning in areas that had held breeding birds in the previous 5 years and to immediately inform the SNCOs if Hen Harriers were found on their property during the breeding season. Operation Artemis asked for compliance with current legislation, no more.

WCOs and rural Police Officers visited every identified estate with heather habitat, including RSPB, Forestry Commission, National Trust etc., and every land agent and gamekeeper employed by these estates, to deliver the project. I gave presentations to both the Moorland Association representative and the Board to the British Association for Shooting & Conservation seeking their support. These organisations and others that represent the shooting community continually promote the view that they abhor raptor persecution so it would be reasonable to assume that they would welcome and support this project. Not at all. Only the conservation and statutory organisations with heather moor holdings agreed to participate in the project. The private estates refused to take part on block and the shooting community launched their standard tactic – use the shooting media to attack the policy, attack the individuals connected to it, garner support from supportive MPs condemn the plan and lobby Parliament in an attempt to force the Police and Defra to abandon the scheme. A plethora of complaints were lodged with Chief Constable Brunstrom. A check of Hansard will give you an insight into the nonsense that ensued.

What Operation Artemis revealed was that feudalism was alive and well in the UK in the 21st Century. The rich and powerful would not be policed, legislation protecting our natural environment didn’t apply to them. They owned the land, ‘owned’ the people who lived on the land, owned the creatures that lived or crossed their land and nothing and nobody would change that. They have to condemn persecution of course, they can hardly condone it although at one meeting of the Environment Council Hen Harrier conflict resolution a leading member of the shooting lobby demanded that any resolution of the conflict must include lethal control on the basis that ‘if we can’t kill them legally we will continue to kill them illegally’. Hardly a compromise for Hen Harriers that were facing extinction as a breeding species in England at the time, due largely to persecution by individuals involved with the grouse shooting industry. The conflict resolution failed because of the intransigence by the industry and nothing has changed. The English Hen Harrier population remains in a perilous position with just three pairs breeding in 2016.

The shooting industry has softened its demand from ‘lethal control’ to an equally unacceptable brood management scheme. Under this scheme eggs or chicks would be removed from the grouse moors for later reintroduction. The industry claim that without such a scheme grouse numbers would be devastated and commercial shoots could go out of business. Really? How many grouse chicks can three broods of Hen Harriers eat? In fact research, by eminent ornithologists, shows that whilst they do occasionally take grouse chicks two pairs of Hen Harriers per 5000 acres would have no commercial impact and three pairs would have no significant impact. That being the case this demand is just another example of duplicity by the shooting industry when they suggest that a single pair of Hen Harriers is damage the commercial viability of the shoot. By not challenging this assertion successive Governments have been complicit in perpetuating this myth.

Satellite tracking of Hen Harriers reveals that they continue to ‘disappear’ on grouse moors. Hen Harriers named by children from the local communities as ‘Highlander’, ‘Burt’, ‘Hope’ and ‘Sky’, all birds that I have ringed and monitored, have ‘disappeared’. Catastrophic tag failure, insist the industry. Not so say the manufacturers, only 6% of tags fitted to other species, fail. I spent hours searching for these birds with sophisticated ground tracking equipment, none were found. I have also searched for, and found, other birds when the satellite indicated that the birds may be dead. They were indeed dead and post mortems revealed that they had died of natural causes. The conundrum then is ‘why can we find birds that died but don’t find the others?’ It is my considered opinion that we don’t find them because they were killed and the tags were destroyed. Of course it is not just the missing satellite tagged birds that should give us cause for concern, we know what happened to them. We don’t know what happened to the other birds that I and other licenced raptor workers have ringed over the years that weren’t tagged. I am not a man for speculation but I think it likely that many, if not all, of them are also dead and a significant number of those were killed on the northern grouse moors or the associated in-bye land. This is a very depressing thought but the lack of expansion of the English population would tend to support this view.

It is not only Hen Harriers that we should consider when discussing the negative commercial impacts of commercial driven grouse. Other birds of prey are systematically killed in some areas. The National Wildlife Crime Unit identifies Peregrines, Red Kites and Goshawks as being threatened by persecution. I would also add Short-eared Owl and Raven to that list. Statistics gathered over decades by the RSPB show that the majority of this persecution is committed by individuals involved in the game shooting industry. Another example of elements within the industry refusing to comply with the law and of the fact that their representative bodies are merely lobbyists and despite their warm words, apologists for criminals. Government gives credibility to these bodies, treats them as equal partners in the effort to prevent raptor persecution. In reality they are not delivery organisations. I have participated in countless meetings with them in attendance on the Environment Council, Buzzard Stakeholder Group and the PAW Raptor Persecution Delivery Group. At best their tactic appears to stall discussions, wear down the conservation groups and drive expectations down to the lowest common denominator. The grouse shooting industry cannot be trusted to police itself.

As I have already stated I am a licenced Raptor Worker, chairman of my local Raptor Study Group [RSG] and a member of the Northern England Raptor Forum [NERF]. I have been monitoring birds of prey for decades. During that time the local Peregrine population has fallen from six pairs to one, Goshawks are observed on the eastern fringe of the grouse moors at the beginning of spring but they have never been recorded breeding. We have ample habitat for Red Kites but they are absent and we had only one pair of breeding Raven in 2016. Hen Harriers do occupy winter roosts regularly but they have never bred locally. Whilst the absence of these species may not be attributable to local persecution the area is self-evidently a ‘black hole’ as far as they are concerned. The reduction of any species by persecution obviously has a negative impact on both the numbers and expansion of those populations and every grouse moor, whether directly involved in persecution or not, indirectly benefits from the actions of others.

I included Raven in my list of birds that require protection on grouse moors for a number of reasons. Firstly the population in the northern uplands is very low. NERF, which represents RSGs from the South Peak along the Pennine Chain to the Scottish border, the Forest of Bowland, Greater Manchester and the North York Moors has been reporting Raven populations since 2009. In the seven years since that first report the mean average annual breeding population has remained at c45 pairs; the vast majority of which are located in the non-grouse moor areas of South Derbyshire and Northumberland. During that same period 858 chicks fledged in the area, yet the population remained static when I would have expected it to have both increased and expanded.

In the past year there has been a proliferation of gas gun usage on grouse moors. According to the Moorland Association these devises are being used to prevent Raven from predating wader chicks. When I asked for scientific evidence to support the use of gas guns I was told that the evidence was anecdotal. Having regard to the small Raven population in the northern uplands anecdotal evidence that they are problematic does not seem credible. The need for such methods is being driven by the shooting industry, not the RSPB, British Trust for Ornithology or the Wildlife and Wetland Trust. Much of the land in question is designated as Specially Protected Areas and / or Sites of Special Scientific Interest; designated as such for their bird assemblages, including specially protected species listed on Schedule 1 of the Wildlife and Countryside Act 1981. I fail to see how gas guns, which are designed as bird scarers [to be used to protect arable crops at the time of planting or harvest] will only deter Raven from predating wader chicks whilst having no impact upon breeding birds at the same time. In my opinion the claim is ridiculous. I don’t know of any conservationist who believes that gas guns are needed in the uplands, many of which are also National Parks. In my opinion these weapons are being used to persuade both Hen Harriers and Short-eared Owls not to breeding on grouse moors, which is their natural breeding habitat.

We, Raptor Workers and other bird conservation groups, press repeatedly and rightly that the Hen Harrier population should be allowed to reach the habitat carrying capacity. Yet we say nothing about the plight of Raven, northern breeding population 45 annually, and the Government is considering allowing the use of gas guns in protected areas against a species that is also perilously low locally. Gas guns should not be allowed and Government has the power to prevent their use in SPAs and on SSSIs and they should implement that power. What is certain is that the shooting industry cannot be trusted to police the use of gas guns.

We have known for years that lead is not good for the environment or human health and we have consistently banned its use. Every area except game shooting that is. The representative bodies for the shooting industry have continuously lobbied for the continued use of lead ammunition and Government has been complicit by allowing the use of lead in the face of overwhelming evidence that it should be banned. Once again the shooting industry cannot be trusted to override their own selfish desires and do the right thing for the greater environment.

The grouse shooting industry frequently tell us that it is an essential component of the rural economy. Extravagant claims are made about the value of that component both in terms of revenue and employment. I doubt such claims for a variety of reasons:
  • grouse numbers fluctuate naturally and commercial shooting follows the same pattern, incomes are not consistent
  • there are relatively few full time employees in the industry, beaters are simply paid day wages [I wonder how many declare that income to HMRC]. It is self-evident that when there is no grouse to shoot there is no requirement for beater; ergo no employment
  • many shoots are only small syndicates or restricted to friend and family only

These claims should also be set against:
  • the vast amount, many millions of pounds, of subsidy paid by Government to the grouse shooting estates
  • the cost of flood damage and flood alleviation caused by mismanagement of the uplands devoted to grouse shooting
  • the cost to the environment through global warming enhanced by heather burning
  • the loss of carbon sequestration in deep peat
  • the increased cost of flood insurance, if it is available at all, in areas at risk
  • the increase in water charges resulting from discolouration in the water catchment areas

In addition to my experience as a Wildlife Crime Officer, Operation Artemis Co-ordinator, Licenced Raptor Worker, including Hen Harriers, I live in Hebden Bridge. The village is nestled in the Upper Calder Valley in the Pennines. The valley is deep, steep sided and the bottom is very narrow. Hebden Bridge is at the heart of the South Pennines SPA. It is famous for being very beautiful. It is also famous for flooding. When the flood waters pours down Hebden Water there is only one place for that water to go; into people’s homes, the schools, the doctor’s surgery and commercial property; devastating lives and destroying hope. The village was destroyed in the Christmas floods of 2015, not for the first time, and it has still to fully recover. Scientific research paper after scientific paper lays the blame firmly at the door of local grouse shooting estates. Draining the moors, diverting streams, burning the moor, the construction of tracks and car parks on the Walshaw Moor Estate, at the head of Hebden Water, have apparently exacerbated the flood risk. These issues and the lack of supervision by Natural England are currently being examined by the European Courts of Justice.

What price must the residents of Hebden Bridge pay for the privilege of having grouse shooting on its doorstep? The answer lies with Parliament and MPs, particularly local MPs, must not shy away from their responsibility to protect the residents of the Calder Valley from flood risk, higher insurance costs and additional costs of accessing clean drinking water.

By nature and calling I am a left leaning, liberal centralist. I believe in less, rather than more, regulation. Ordinary decent people know what is right and what is wrong, they understand society, their place within it and the value of social cohesion. For the majority of people legislation is largely irrelevant because they, we, instinctively do the right thing for the benefit of our shared world.

Regrettably there are sections of society that do not believe in those shared values. I include a significant number of grouse moor owners and their employees in that group. My natural instincts, and first choice, would be that they should be left alone to police themselves and do the right thing. My experience however shows that they are untrustworthy and incapable of taking any such course of action.

My second choice would be for the driven grouse shooting to voluntarily convert to walk-up’ shooting. This less intensive form of grouse shooting would not be dependent on bird of prey persecution, or the total elimination of all predators, including using sheep to ‘hoover’ up ticks, for that matter, or the mismanagement of the uplands.

My third choice would be for a system of licensing to be introduced, which would not be a problem for law abiding estates, only criminals would be penalised. I don’t see as an issue; I have a licence to drive my car and a licence to ring birds of prey. I will not be committing an offence which will threaten either, consequently my licence to do both will never be under threat. I embrace the licensing system, which will only remove those individuals not fit to hold a licence. Unfortunately I don’t see any appetite for licensing from within the current Government. Additionally the huge reductions in the budgets of Defra, NE and the Police will inevitably mean that these departments will not have the resources available to enforce a licensing system.

My experience in law enforcement, raptor monitoring and interaction with the grouse shooting industry leads me to the unpalatable, but realistic decision that to remove all of the ills associated with driven grouse shooting, and for the benefit of our environment and the communities of both wildlife and people that enjoy our shared environment, the only solution is to ban the practice of driven grouse shooting.

Steve Downing
Chair Calderdale Raptor Study Group

More Written Evidence

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.

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. 

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