By Katie-Jo Luxton, RSPB Global Conservation Director

A recent UN report, commissioned by Defra, and subsequent responses to Parliamentary Questions continue to cast serious concerns about the resolve of the Westminster government to tackle raptor persecution and other areas of wildlife crime. 

In March last year Defra announced the UK as the first G20 country to have invited a UN-backed assessment of wildlife and forest crime using the United Nations Office on Drugs and Crime (UNODC) toolkit. 

The toolkit - covering legislation, enforcement, judiciary, prosecution and prevention - would provide a comprehensive analysis of our legal system. 

Speaking at the launch, Environment Minister, Minister Rebecca Pow, stated ‘We requested this assessment to help build on our progress and will look closely at the recommendations, working with key stakeholder groups to inform a cross-government response. Together we can reduce these horrific crimes for the benefit of our biodiversity, our precious habitats and our rural communities for generations to come’

This could be a great thing for birds of prey, which continue to endure relentless persecution. But only if the recommendations within the document are put into practice.

Several statutory agencies, the RSPB and others were consulted for the report. Then, on a Friday before Christmas, the UNODC report was published along with a promise that ‘The Government will now consider the recommendations to ensure our legislation and enforcement of wildlife crime is as strong as it can be’. Behind the positive rhetoric is a rather more sobering read: a 209 page report with its 72 recommendations. There is no doubt we should be grateful for the work being undertaken in the UK to tackle wildlife crime by many organisations and individuals, including the Border Force CITES Team, the National Wildlife Crime Unit (NWCU), many committed UK police Wildlife Crime Officers (WCOs) plus the vital support from numerous NGO partners.

However, as the report outlines, there is much to do, and the government now needs to turn their words into actions.


The UNODC report is a clear call to arms – the government now need to step up to the plate

Call to arms

Amongst the 72 recommendations are eight on raptor persecution. The report confirms the involvement of Organised Crime Groups (OCGs) in raptor persecution and other wildlife crime. Whilst Scotland has been the most progressive part of the UK in trying to improve the public accountability of intensive grouse shooting and with the aim of stopping raptor crimes, the report points out that discrepancies with sentencing, vicarious liability, possession of pesticides and disqualification powers are unhelpful. We believe that some ‘levelling up’ is clearly needed to get the best standards of legislation, enforcement and sanctions across the UK.

We see the key recommendations as ‘To enhance powers of licensing authorities to revoke licences for gamebird shoots or amend those licences where abuse occurs with a proven link to estate management’. Whilst no such licensing currently exists across the UK,(though it is planned soon in Scotland), this is a clear call to arms. The RSPB and others have been advocating for many years the need to licence driven grouse shooting to try to push up environmental standards to reduce habitat damage and the illegal killing of raptors and other wildlife. In mentioning all gamebird shoots, the UNODC report goes beyond our current position, and the RSPB will consider this as part of our ongoing review of gamebird shooting

The lack of any meaningful accountability for the employers/managers of those killing raptors remains the key obstacle to effectively tacking raptor crimes. It is abundantly clear the industry cannot self-police, their declaration in January 2020 of ‘zero-tolerance’ for these crimes, contrasts markedly with the unprecedented number of confirmed raptor persecution incidents in 2020 (see the Birdcrime report and a number of more recent incidents and prosecutions, including the recent brutal killing of two buzzards.


Crimes like the recent brutal killing of two buzzards highlights the problem is simply not going away 

Questions in the house

On 1 February 2022, written questions were submitted by Labour MPs Kerry McCarthy and Alex Sobel. These asked, with reference to UNODC report, what steps would be taken to strengthen accountability of estate management for raptor persecution and what the implications were for the licensing of gamebird shoots. Rebecca Pow supplied similar responses, welcoming the report and conceding there was more that could be done. On licensing, she responded simply it was a devolved matter with currently no such requirement in England. Again, there was assurance that all the recommendations would be carefully considered. 

On the 3rd, during a debate in the House of Lords, Baroness Hayman of Ullock (a life peer serving as Shadow Spokesperson for Environment Food & Rural Affairs) asked similar questions about accountability and licensing, referencing the recent buzzard killing case. Lord Benyon (appointed last year as a Parliamentary Under Secretary of State for Defra), appeared to dodge the question, mentioning only the current sanctions available under the law and finishing with the sentence ‘They represent a very small proportion of a sector that does enormous good for conservation and wider natural wildlife benefits in this country’.

A report has been commissioned, recommendations provided and assurances given – but when will we see the required firm Government action?

As if to highlight this whole issue, on 10 February came the shocking news of that two of the white-tailed eagles from the Isle of Wight reintroduction project had been found dead. This incident was understandably covered widely in the media, and we await the results of the forensic tests to establish the cause of death.

One of two white-tailed eagles recovered in southern England – we await forensic tests with concern

What will it take?

As outlined by our Investigations team only a couple of months ago, what exactly will it take for the government to step in and take the necessary measures to protect our birds of prey? In our view this can only be achieved through the enactment of vicarious liability (another measure already in place in Scotland), and licensing of grouse moors including firm sanctions to remove such licences in the event of confirmed criminality against birds of prey and other wildlife by the Police. Otherwise we suspect the grim death toll of raptor victims will continue to rise.

Time to walk the walk

Successive governments have ‘talked the talk’ for decades on raptor persecution and other wildlife crime. But set amongst the backdrop of the deepening climate and ecological emergency, with UK as one of the most nature depleted countries in the world, these words sounds increasingly hollow. Having commissioned the UNODC report, which endorses what we and many others with good knowledge of the level and location of wildlife crime on the ground have wanted for decades, it really is time to ‘walk the walk’. We await further concrete announcements of what the government actually plan to do, and of course specifically in relation to the deaths of two sea eagles, if they are confirmed to have been illegally killed, with great interest.