In the first of two guest blogs from Logan Steele, Communications Secretary for the Scottish Raptor Study Group (SRSG), he reminds us of the background to the SRSG petition to the Scottish Parliament in 2016, which called for a state regulated system of gamebird hunting in Scotland. This petition was instrumental in securing the independent “Werritty Review”, which is now considering recommendations on how grouse moors can be managed sustainably and within the law, and which is expected to report in July 2019.

A view from the Scottish Raptor Study Group on the licensing of grouse moors

What is the Scottish Raptor Study Group?

The Scottish Raptor Study Group, founded in 1980, is a network of about 300 voluntary raptor experts who monitor and record the fortunes of raptor species across Scotland, and who contribute to national population surveys of these species.

We check thousands of raptor territories for occupancy each year, and record the status, distribution and breeding success of each species. We have a unique long-term dataset of raptor records, and this information is vital for understanding population trends. Our results are published annually as part of the award-winning Scottish Raptor Monitoring Scheme. It has contributed to hundreds of scientific publications and is used by conservation agencies to inform local, regional and national conservation plans and policies.

Our work is undertaken on a voluntary basis and between us we contribute thousands of days to fieldwork and data collection every year. Our members have varied backgrounds and are from many different professions, but we are united by our commitment to the protection and conservation of Scotland's raptors.

Why we launched a petition

While we acknowledge the wider social and economic role grouse shooting plays in the Scottish countryside, we want to see this land management being conducted in an environmentally friendly and sustainable manner.

After decades of various joint working initiatives, committees, promises and many fine words intended to better protect raptors, we find that, particularly on grouse moors, little has changed. The illegal persecution of many raptors continues with no sign of stopping. The shooting industry have failed to show leadership. They have deliberately ‘kicked the can down the road’ for many years by promoting inadequate voluntary approaches to tackling cultural prejudices in their sector, as well as illegal behaviours towards native raptors and other predators.. Our patience has finally run out, which is why we called for the licensing of grouse moors.

In recent decades, there has been a commercialisation and intensification of grouse shooting where the illegal killing of birds of prey is seen as a necessary part of the ‘business model’. These businesses claim that they must produce large surpluses of grouse otherwise shoots could become unviable. Tips from sporting clients to gamekeepers, based upon providing large numbers of grouse to shoot, create a further and often unseen incentive to break the law, and we are told that this income can form a significant part of gamekeepers’ annual salaries. 

We know where raptor persecution happens; we know how it happens; we know why it happens; we know the regional blackspots; we know the estates and sometimes even the individuals involved; yet it remains very difficult to get successful convictions due to the difficulties in detecting crimes on remote moors. Effectively, wildlife protection laws are of little deterrence to these criminals, and the low chance of detection is seen as a risk worth taking, in what is essentially an organised crime setting. 

With little prospect of any genuine change, we launched our petition in July 2016 to the Scottish Parliament to ask for the introduction of licencing for game bird shooting. As the petition progressed through this process, the focus for licencing narrowed down to grouse shooting, due to the associated endemic criminality (although we note that some of the ills of driven grouse shooting can be found in parts of the pheasant shooting sector as well). In just six weeks our petition on the Scottish Parliament website secured an amazing 7,600 signatories.


Our experience of giving evidence

We attended two committees of the Scottish Parliament to give evidence; the Petitions Committee and the Environment Climate Change and Rural Affairs Committee. We were supported by RSPB Scotland. Following complaints by game shooting interests, that their voice was not being heard, they also had an opportunity to provide evidence. 

Initially the experience was daunting, especially when the entire event was being streamed live online. We undertook a considerable amount of advance preparation work to support our case, and to prepare for likely questions from MSPs.  However, we found that the MSPs were very professional, respectful, polite and supportive, which helped to allay our concerns and nerves. 

At the first evidence session during the Public Petitions Committee, the MSPs were so struck by the compelling evidence that they refused to close their engagement with the Petition until the Environment, Climate Change and Land Reform (ECCLR) Committee had formally agreed to take the matter on to the next stage. This helped reinforce to us that this matter was being taken very seriously. We were also very reassured that MSPs from all political parties clearly understood the scale and impact of crimes against Scotland’s raptors, both on the populations of these species, and more widely on Scotland’s international reputation in the 21st Century.


Our arguments to the Scottish Parliament

Our petition urged the Scottish Parliament to urgently introduce a state regulated system of licensing of gamebird hunting, that addresses the adverse environmental impacts of this sector; provides for the revocation or amendment of licences where a licence-holder fails to comply with their terms and conditions; and implements the recommendations of the Review of Wildlife Crime Penalties in Scotland.

We reminded both the Petitions and Environment Committees that;

  • There is an overwhelming body of peer reviewed science, as well as national raptor population survey data, and criminal incidents reported to the police, which all point clearly to illegal killing of raptors on many grouse moors in Scotland.
  • There is disregard for the law by the perpetrators, where illegal killing of protected wildlife is a key part of the culture and ‘business model’.
  • Decades of talks with the shooting sector, as well as warnings by the public authorities of the need to tackle criminal behaviours, have produced very little progress.
  • There is mounting evidence of wider environmental damage caused by grouse moor managers, such as the unregulated culling of mountain hares; burning on deep peatland; the use of lead ammunition; the unregulated medication of ‘wild’ red grouse; and the scars on the landscape caused by the construction of hill tracks
  • Although helpful, Vicarious Liability (VL), a measure designed to make landowners responsible for the illegal actions of their employees in relation to raptor killing, was not “the silver bullet” as was hoped. This has been partly due to the difficulty in identifying owners, with many sporting estates registered in tax havens; and due to the way the Crown Office has required a conviction prior to pursuing rogue landowners. Convictions for wildlife crimes are rare, although we know that incidents are frequent. Our understanding of the legislation is that a criminal conviction is not required prior to pursuing VL, rather sufficient evidence to satisfy the public authorities that criminal killing of raptors is occurring on a certain landholding.  
  • In almost all other European countries shooting of gamebirds is licenced. SNH has produced a comprehensive report documenting the approaches taken elsewhere. The extraction or harvesting of other natural assets such as water, forestry, deer and salmon are all regulated, so why not the shooting of gamebirds?
  • The UK is unique in that there is a culture of ‘big bags’ in gamebird hunting unlike European countries which hunt ‘one for the pot’. Our gamebird shooting culture is one of ‘sporting’ as opposed to ‘hunting’. This approach is now widely seen as unsustainable.

In summary, there is public abhorrence that grouse moor managers are allowed to continue operating outside the law and in full view. A step change in enforcement action must now be taken by Scottish Government to better protect public interests. We recommend a licensing system, including sanctions for licence removal where criminal actions are identified by the public authorities, as a proportionate approach.  


Logan’s second guest blog, which explores the hopes amongst voluntary raptor workers from across Scotland for outcome of the Werritty Review can be read here

  • I hope that my petition PE1705 to parliament, which has recently been forwarded to the Environment, Land Reform and Climate Change committee may assist. I am still working on this, suggesting to the government  suitable changes to the law which I have no doubt will be supported by the vast majority of MSPs but will still face powerful opposition who may well be able to delay implementation. The Poustie recommendations from 2015 for sentencing length increases have still not been implemented, although it is still being claimed that it will be completed in this session. 

    If there is a call for submissions or an evidence session for my petition, the arguments put forward in this article would add powerful assistance to the documents I am preparing.