The Field at the Camping Barn

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Spring Lambs

© Mark Avery's Supplementory Evidence for the Petition to B.D.G.S

Supplementary written evidence from Dr Mark Avery (GRO0530)

Summary:

1. The situation in Wales does not support the contention that management for grouse shooting in Wales would be of great conservation value. The study cited is weak and has few data on species other than Red Grouse. Its findings with respect to Hen Harriers conflict with much better and more comprehensive data.

2. The ecology of the uplands would be much improved by the banning of driven grouse shooting and the National Trust is moving strongly in that direction with its High Peak vision.

3. Whatever might be the claimed economic benefits of driven grouse shooting since they depend on wildlife crime of an ongoing and immense scale they do not provide a legitimate argument for the continuation of driven grouse shooting.

Clarification and expansion of oral evidence

4. I am grateful to the Petitions Committee for holding this inquiry and for inviting me to give oral evidence for a ban on driven grouse shooting alongside three witnesses who oppose that ban.
5. I am also grateful for this opportunity to expand on and clarify my evidence.
6. I was asked about the situation in Wales (Q27) and a study of this was mentioned. The study referred to was ‘Changes in the abundance and distribution of breeding birds in the Berwyn Special Protection Area, North Wales 1983-2002’ by staff of the Game and Wildlife Conservation Trust which was published in Birds in Wales1. These data are interesting but not at all convincing to the proposition that grouse moor management benefits the conservation of birds (and includes no data on other wildlife). I was right to describe it as anecdotal in my oral evidence.
7. The study includes detailed long-term data on the numbers of Red Grouse shot but very little data on other species. It does not cover all of the Berwyn SPA, only selected parts of it. It does not provide data throughout the period 1983-2002 (except for Red Grouse), merely data from 1983-5 and 2002.  Grouse management  ceased in ‘the late 1990s’ and no data are given for bird numbers (except Red Grouse) in the period between 1983 and the cessation of grouse shooting, nor between the cessation of grouse shooting and 2002. In other words, we are asked by the Moorland Association to ascribe all the changes in bird numbers over almost 20 years to one event which happened in the middle of that period and to ignore all the other changes in Wales during that time, and their conclusions are only based on four years data, just one of which was after grouse shooting ceased. This is a very weak ‘post hoc, ergo propter hoc’ argument.
8. An indication that at least some of the conclusions of this article are wrong is provided by its findings on Hen Harrier (as flagged in my oral evidence). The paper states ‘Numbers of Hen Harriers declined by 49%’.  I see from the written evidence2 that some supporters of driven grouse shooting claim that Hen Harriers are absent from Wales and that they would not be if grouse shooting were maintained at high levels in Wales.  We know from carefully conducted national surveys of Hen Harriers that the Welsh population of Hen Harriers has increased in numbers from 28 pairs in 19983, to 43 pairs in 20044 to 57 pairs in 20105 (and we await the results of the 2016 survey which will bring these figures up to date. 
9. Table 5 of the Game Conservancy article demonstrates that the limited bird counts in this study from the Berwyn SPA were in line with general trends in Wales as a whole.
10. I was also asked (Q28) about the situation on one particular unnamed moor in Wales, where grouse shooting ceased. I am informed that Chris Davies MP, who asked the question, was a member of the Brecon Beacons National Park Authority when that decision was taken. If this is correct, then I am surprised that he did not mention it. I see from the initial written evidence submitted6 that informed local views are not so complimentary about the situation and support a ban on driven grouse shooting.
11. I was asked (Q33) about a risk assessment of banning driven grouse shooting and Mr Hart and I got rather bogged down in the economics and I neglected to say much about a vision for the uplands after grouse shooting is banned.  I’m grateful for this opportunity to make my views clearer now on both the ecological and economic aspects.
12. First the ecology. We can move from a intensively-managed ugly landscape of burned patches to one which is much more natural and beautiful in aspect. A more natural, less intensively managed upland landscape more akin to Scandinavia (where they do not feel the need to torch their hills as we do) and in many parts of the UK such as north and west Scotland and on National Nature Reserves and other nature reserves in the north of England. Such a landscape would be better at storing carbon, better at reducing flood risk and better at providing clean drinking water and would provide more benefits to society as a whole. It would have a more varied wildlife, maintaining all the species that are found on driven grouse moors – some at densities higher than now and some at lower densities.  There would be more trees and less heather, but heather cover would still be an important part of the upland scene. People would be more welcome and would spend more time visiting this more varied landscape and that would open up opportunities for more local, and truly local, businesses to flourish. There would still be opportunities for walked up grouse shooting, limited heather burning and legal predator control.  This view is very similar to that of the National Trust in its High Peak vision7 for its land in the Peak District National Park.  Our National Parks in particular should be places where nature thrives rather than where it is subjugated in the interests of shooting wildlife for fun.
13. The alternative to driven grouse shooting painted by the Chair of the Countryside Alliance and witnesses from the Moorland Association and Countryside Alliance (Qs 63 and 64) is not credible. They seek to scare us with the prospect of windfarms, forestry plantations and overgrazing in place of driven grouse shooting.  Given that much driven grouse shooting occurs in National Parks, Areas of Outstanding Natural Beauty, Sites of Special Scientific Interest, Special Protection Areas for Birds and Special Areas for Conservations the land use shift that was envisaged cannot occur. All of the imagined scenarios are against current government policy and they are not occurring on land with similar designations that is not managed for grouse shooting.
14. I would like to turn back to the economics briefly. Mr Hart seemed to want a fully costed economic analysis of grouse shooting and that is an area where he and I agree. It is something that government should do in order to test the claims of the grouse shooting industry (which has no such analysis in its support).
15. The industry’s claims of economic benefit from grouse shooting are small, in the order of tens of millions of pounds (see Q56 and the Moorland Association written evidence8) and have been shown to be overestimates based on flawed methods9. They do not take into account increased flood risk, water treatment costs, greenhouse gas emissions or lost revenue from alternative activities such as eco-tourism. But let us imagine, difficult though it is, that they are true.  These economic claims depend on wildlife crime (see my written evidence10). Given that any economic benefits of driven grouse shooting depend for their existence on widespread crime they should be ignored. Whatever the case for driven grouse shooting is, it is not an economic case.
16. I have asked the Moorland Association for the source of their estimate of a million pounds a week spent on grouse moor management as the source of this figure is unclear from their written evidence. They have not provided me with that source but if it is the PACEC reports then we know those to be flawed.

References:

1. Warren, p. and Baines, D. 2014. Changes in the abundance and distribution of breeding birds in the Berwyn Special Protection Area, North Wales 1983-2002. Birds in Wales 11.
2. Written evidence to this inquiry GRO0060.
3. I.M.W. Sim, D.W. Gibbons, I.P. Bainbridge, and W.A. Mattingley. 2001. Status of the Hen Harrier Circus cyaneus in the UK and the Isle of Man in 1998. Bird Study 48.
4. Innes M.W. Sim, Ian A. Dillon, Mark A. Eaton, Brian Etheridge, Patrick Lindley, Helen Riley, Richard Saunders, Chris Sharpe, and Matthew Tickner. 2007. Status of the Hen Harrier Circus cyaneus in the UK and Isle of Man in 2004, and a comparison with the 1988/89 and 1998 surveys. Bird Study  54.
5. The status of the Hen Harrier, Circus cyaneus, in the UK and Isle of Man in 2010. 2013. Daniel B. Hayhow, Mark A. Eaton, Stephen Bladwell, Brian Etheridge, Steven R. Ewing, Marc Ruddock, Richard Saunders, Chris Sharpe, Innes M.W. Sim, and Andrew Stevenson. Bird Study 60.
6. Written evidence to this inquiry GRO0063.
7. National Trust. High Peak Moors and Vision in the Dark Peak.  https://www.nationaltrust.org.uk/kinder-edale-and-the-dark-peak/features/high-peak-moors-vision-and-plan-in-the-dark-peak
8. Written evidence to this inquiry GRO0308 para 20.
9. Cormack, P. & Rotherham, I.D. 2014. A review of the PACEC reports (2006 & 2014) estimating net economic benefits from shooting sports in the UK.  http://www.league.org.uk/~/media/Files/LACS/Publications/Cormack--Rotherham-2014--A-review-of-the-PACEC-reports-2006--2014-EXECUTIVE-SUMMARY.pdf
10. Written evidence by Dr M.I. Avery GRO0248 paras 24-30.

Gems from the written evidence of the raptor workers © Mark Avery

Gems from the written evidence 6 – the raptor workers (1)

Mark ♦ October 25, 2016 ♦ 8 Comments

Raptor workers give up their time voluntarily to monitor the numbers of these fabulous birds. Their evidence on raptor numbers and raptor persecution should carry considerable weight. Here are some extracts from the evidence that has appeared so far (more is to come I am sure) and from a professional academic too:
North of England Raptor Forum:

• Hen Harrier – now almost extinct as a breeding species across northern England and satellite tagging has revealed additional vulnerability to persecution at its upland winter roost sites (eg the case of the satellite tagged “Bowland Betty”).  Red Kite – there has been very limited expansion from the centres of reintroduction outwards to upland areas. Goshawk – populations in all areas of close association with grouse moor have suffered serious decline and are now critically low.  Peregrine Falcon – populations and breeding success is severely restricted in upland areas close to grouse moor. Upland populations are highly threatened and declining yet lowland populations are increasing.  Short-eared Owl – local examples of illegal persecution may be affecting breeding numbers.  Raven – very locally distributed and absent as a breeding bird across large areas of the uplands.
• The North Pennine and Bowland Special Protected Areas (SPAs & SSSIs) each have Hen Harrier and Peregrine Falcon as citation species yet their respective populations now consistently fall well below the targets given and continue to deteriorate.  Clearly the UK Government has a responsibility to remedy this failing.
• Responsible self-regulation by the grouse shooting industry has failed to deliver any tangible benefits. Changes in attitudes and legislation are now urgently needed to finally stop the illegal persecution of raptors in all its forms.  It is recommended that consideration be given to the formal licensing of shoots and in the case of proven transgression against licence terms, such as illegal raptor persecution, then the licence holders should face consequences including the withdrawal of any land use grant payments.

Calderdale Raptor Study Group:

• 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.
• 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.
• 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.

Shropshire Peregrine Group:

• The Group strongly supports the petition to ban driven  grouse shooting for sport on the grounds that the intensive management of grouse moors has an adverse effect on biodiversity and the environment, and frequently leads to the deliberate killings and organised persecution of protected birds of prey including Hen Harriers and Peregrine Falcons.

Manchester Raptor Club:

• Thirty years ago, it was relatively common to see Hen Harriers wintering on Chat Moss, a large area of farmland and former peat workings in the west of Greater Manchester, part of which is a SAC. Today it is a rarity, reflecting the dramatic decline due to the extermination of this wonderful bird by grouse shooting interests.
• Grouse shooters  have grossly abused the upland countryside, and it has been proved that “management” is causing serious damage, notably increasing the frequency and intensity of flooding (eg Hebden Bridge) and releasing carbon through burning. And they are getting a government subsidy of £56 per hectare for this!  This tiny, wealthy minority apparently have the resources to flout the law. But the will of the majority of the people of this country must prevail. Grouse shooting should be banned completely and the law of vicarious responsibility, already in force in Scotland, extended to England and Wales.

Dr Arjun Amar:

• I am a Conservation Biologist, with over 20 years of research experience on birds of prey and the British uplands, including a PhD from Aberdeen University on the conservation ecology of hen harriers. I have published over 65 peer-reviewed scientific papers in some of the world’s leading ornithological and conservation journals. I am currently employed as a Senior Lecturer at the FitzPatrick Institute at the University of Cape Town, a world renowned ornithological institute at the University of Cape Town. I was previously employed by both the Royal Society for the Protection of Birds (RSPB) and the Game and Wildlife Conservation Trust (GWCT), where I conducted research on raptors in the British uplands.
• Thus, this paper showed that breeding performance of Peregrine Falcons was considerably lower in areas managed for grouse shooting in northern England and that direct persecution was the most likely cause for these differences. These results therefore suggest that contrary to the assertions of many associated with grouse shooting, persecution is not isolated to one or two ‘rogue’ estates but rather that it is systemic within the grouse shooting industry.
• In this paper, we show that on driven grouse moors in the UK in the absence of persecution we might expect there to be around 500 successful pairs of hen harriers. This estimate is based on the known hen harrier densities on grouse moors where persecution was relaxed and the approximate amount of land managed for driven grouse shooting in the UK. However, in 2008 there were only 5 successful hen harrier pairs on driven grouse moors. Thus, only around 1% of the potential number of successful pairs that might be expected in the absence of persecution. This again shows the extent of illegal persecution of raptors that occurs in the British upland managed for driven grouse shooting.
• I think it needs to be made very clear that this issue is with driven grouse shooting, which requires very high densities of grouse to operate. Other forms of grouse hunting, such as walked up shooting, do not require the same densities of birds, and therefore do not require the same level of intensive management or the same levels of illegal practices.
• I believe that there needs to be more regulation of the grouse shooting. The UK is one of the only countries in the world where shooting is not tightly regulated, as a result we (the UK government, the statutory nature conservation agencies, the police, and local communities) have very little control over land owners and managers who damage the environment and undertake illegal activity. I would therefore support the suggestion that a licensing system for grouse shooting be adopted

Dr Ruth Tingay:

• It is quite clear that the driven grouse shooting industry is unable and/or unwilling to abide by the law. It is also eminently clear that the statutory authorities are unable to enforce the relevant legislation effectively.
• It is my view that introducing a licensing system for driven grouse shooting would be futile. It is already illegal to kill birds of prey, although this is happening with impunity across the UK uplands and the statutory authorities consistently fail to enforce the law. There is therefore no reason to expect them to effectively enforce a licensing system. For this reason, I fully endorse a ban on driven grouse shooting.
• Mark writes: have a look at the Appendix in Ruth’s evidence of 252 wildlife crime incidents in grouse moor areas over the last 10 years for an eye-opener of the tip of the tip of the iceberg.

Heather Burning and Climate Change © Mark Avery

Heather burning, water quality and greenhouse gas emissions

Mark ♦ October 4, 2016 ♦ 12 Comments

Heather burning on commercial grouse moor. Glenfeshie. Scotland. April 2007. http://scotlandbigpicture.com/

The Committee on Climate Change made a written submission to the Environmental Audit Committee inquiry into soil health in January this year. In it they wrote:
‘The English uplands are dominated by blanket bog and heathland habitats, which tend to have highly organic and peaty soils. When in good condition, peat bogs actively soak up carbon, accumulating between 3 and 7 tonnes per hectare per year.  Peatlands also play a vital role in the provision of drinking water to millions of people, as they form the headwaters for some of England’s major water supply catchments.‘
…and…
‘The area of burned moorland has increased significantly in recent decades across much of northern England. A comparison of aerial photography from the 1970s and 2000 of over 200 km2 of the English uplands found that the extent of new burns had doubled (from 15% to 30%) over this period. A recent study found that the annual number of burns between 2001 and 2011 increased by 11% per year, with an accelerating trend in more recent years.’
…and…
‘There is increasingly strong evidence that managed burning reduces peat accumulation, causes declines in carbon storage, and increases dissolved organic carbon (DOC) levels in watercourses.  Levels of DOC in UK upland water bodies have doubled over the last 30 years. Some of this observed increase in DOC is likely to be due to reductions in sulphur deposition (more commonly known as acid rain) since the 1990s. However, there is evidence that managed burning is the primary cause of DOC export in parts of the English uplands.‘

…and…

‘…the on-going declines in soil carbon, increases in the area of some high erosion

risk crops (e.g. maize) and the degraded condition of upland peats suggests that current policy interventions will not deliver the 2030 aspiration for all soils to be sustainably managed.‘

Brian May and Chris Packham discuss grouse shooting © Mark Avery

Mark ♦ September 5, 2016 ♦ 8 Comments

Here are two wildlife enthusiasts talking about driven grouse shooting.
Please sign this e-petition to ban driven grouse shooting, alongside Brian May and Chris Packham.

Raptor Persecution in the Uplands © Anand Prasad

This is a letter I have sent to friends who I thought might be interested in the ‘Conflict in the Uplands‘.
Please feel free to copy and paste and send to as many UK citizens as possible before 20th September.

Without going into details:
The UK petition to ban driven grouse moors can be signed here (UK citizens or residents only). It needs you to click on the e-mail you will then receive to confirm your ‘vote.’

Going into details:
As I write the petition is approaching 75% of the 6 month time limit but only 70% of the necessary signatures to get a government debate, so it needs a boost. If this is passed around it could easily reach the 100,000 target. If everyone who signs can get one more person to sign it will happen.
It can be signed for the obvious reason, to support a ban on driven grouse shooting, but also as a way to get a parliamentary debate on this issue because to be realistic it isn’t going to happen any time soon. A debate would raise the possibility of a compromise such as licensing of grouse moors or all game shooting. The problem with licensing is that it would be as hard to police as the law is now, which is clearly not working but it would be a start.
There is another non-government petition asking for licensing in Scotland. Everyone can sign no matter where you live. Sign both if you care about birds of prey.
https://www.parliament.scot/GettingInvolved/Petitions/PE01615
What is the problem?
The illegal killing of birds of prey on driven grouse moors is preventing the spread of re-introduced raptors (Red Kites and White-tailed Eagles) and is creating black holes where species such as Hen Harriers, Golden Eagles and Peregrines are virtually absent. This is restricting the overall population of Golden Eagles and decreasing the numbers of Hen Harriers to the point of near extinction in England. The only reason they haven’t been made extinct in England is because of the attempt at re-colonisation every year by Scottish birds. Peregrines are only doing well away from grouse moors.
It has been illegal, since 1954, to kill birds of prey but today it is still happening on a huge scale and if anything, is getting worse. Decades of talks and committees involving groups of conflicting parties have achieved nothing (this summary was written in 2010 – a flash of deja vu).
The fact is that birds of prey, particularly Hen Harriers which have large broods, will without persecution multiply and take the ‘surplus’ Red Grouse which the intensively managed grouse moor owners want for their shooting clients. Birds of prey and intensive grouse moors i.e. driven grouse moors can not co-exist. Non-intense i.e. walked up grouse shooting, especially with the aid of diversionary feeding, could but the grouse lobby are opposed to diversionary feeding. Their solution is to move Hen Harrier nests off the moors onto the lowlands. They don’t want any Hen Harriers on ‘their’ moors at all and the threat is implicit ‘let us move Hen Harriers off the moors or we will continue killing them’. This blackmail is working and is included in the hidden agenda of the government’s recently Hen Harrier Action Plan. That and introducing European Hen Harriers to the English lowlands even though we have a perfectly viable, although falling (due to persecution) population in Scotland which is constantly trying unsuccessfully to spread to England. How the Hen Harrier Action Plan is going to protect what remains of Peregrines, Goshawks, Red Kites, Golden Eagles and White-tailed Eagles in the uplands is ignored completely.
There is a multitude of evidence of the persecution on grouse moors. You only have to compare the Red Kite re-introduction scheme in the Chilterns with the one near the Black Isle. One is thriving and the other has not increased in numbers even though the breeding productivity of the Black Isle birds is high when they manage to breed.
The Black Isle is near driven grouse moors the Chilterns isn’t. It is the same in north-east England which is close to grouse shooting country and the population near Leeds/ Harrogate has had 10 Red Kites killed just this spring. The grouse moors in the Pennines and the North Yorkshire moors will not allow expansion. Presumably the same is happening with the introduced birds from Central Scotland, judging by these poisoning incidents here, here, here, here and here and those re-introduced in Dumfries and Galloway, judging by these poisoning incidents here, here and here.
Another proof is the Langholm experiment the most bizarre legally arranged experiment conducted. The object of the experiment was for gamekeepers on Langholm to stop killing raptors.
I still think I am Beelzebub’s grandson (or to be more contemporary, The Man Who Fell To Earth) when I even think about it but that is what happened and Hen Harrier numbers exploded.
Why ban driven grouse shooting, we have laws don’t we?
The criminals are almost impossible to catch as the killing and poisoning occurs in remote places and when the culprits are caught it is almost impossible to prosecute as the level of proof is extreme, e.g. video evidence can be deemed inadmissible. In Scotland the incident has to have been seen by two witnesses and even then a prosecution is not certain. If you have heard about the shooting of two Hen Harriers at Sandringham when a certain Mr. Windsor Jnr. was out shooting , you will see what I mean. It wasn’t even as though being a Windsor was any different to your average gamekeeper, it is almost impossible to get a prosecution. Behind every gamekeeper is a rich and powerful landowner. [Incidentally that Guardian article mentions Mr. Windsor’s shooting partner Van Cutsem. To peak down the rabbit hole search for that name and Glanusk estate in the search engine on Raptor Persecution UK or Mark Avery’s blog].
Even after a successful prosecution the penalties can be little more than a pat on the wrist (or may only result in warning), gamekeepers are unlikely to lose their jobs, whilst the real villains, the managers and landowners get off scot free (no pun).
Scotland is finding ways of hitting the negligent landowners in the purse by cutting the tax-payer funded subsidies and by new laws to prosecute the landowners where gamekeepers have been persecuted (Vicarious Liability) but even in Scotland the killing continues and for example Hen Harriers are in decline.

It can’t be all bad can it?
There are three arguments which the shooting lobby fall back on to justify driven grouse shooting.
1. Money and employment in the rural economy.
2. Grouse moors are good for other birds and even use the word biodiversity.
3. Grouse moors are a special habitat.
These might be valid points but, I would argue, need closer scrutiny.
1. The facts brandied around about the money involved and the employment generated are from the grouse lobby themselves and as far as I know there has been no independent research. I have never seen any research done to compare driven grouse shooting moors with other moors which have walked up grouse shooting which is far less intense or with moors which mix walked up shooting with genuine wildlife tourism or the tourism from moors managed purely for wildlife. The grouse lobby likes to think in binary, either-or without examining all the other possible forms of income from eco-tourism. The National Trust who own lots of moorland could set up an experimental moorland to demonstrate other alternatives.
I would like to see how much of the profit goes into the local community or even Scotland. One vicarious liability case could not be prosecuted because the owners were hidden in off-shore businesses. That wouldn’t be for tax purposes would it?
I would also like to know if those so called profits included all the costs to the tax-payer in the form of subsidies and lack of licensing of guns and shooting etc. I would also like to see the hidden costs to the public in the form of increase in carbon emissions from muirburn, increase in flooding, purification of water and the loss of re-introduced raptors and habitats. More important to me is not the monetary loss but the loss to ourselves, to which I can’t find a proper word. Spiritual comes as close as I can think of.
I am also not sure if the employment of gamekeepers, a certain percentage of whom are criminals, is high on my list of human rights priorities.
2. There has been good evidence that grouse moors are beneficial for certain wader species (Golden Plover and Lapwings) but it is by no means all waders. Again the grouse lobby is thinking or rather trying to get the public to think in binary. Their statistics compare keepered grouse moorland with non-keepered moorland. They have not taken into account moorland specially managed for wildlife, including waders, which would be the case on some moorland if shooting was banned. There is nothing to stop a non-grouse moor hiring a keeper. They haven’t taken into account the possibility of new legislation to protect waders. They have not taken into account the fact that Golden Plovers are actually a game bird and are shot. They have not considered all the other ways that waders can be protected. These birds are not exclusive to grouse moorland. Lapwings are mowed down during silage cutting in the valleys below the Forest of Bowland so excuse me, grouse lobby, if I don’t get too upset if a fox takes some on the moorland above.
Personally I would prefer to see Stoats, Foxes, Mountain Hares, Ravens, Hooded Crows and birds of prey flying freely on the uplands even if the population of waders and even Hen Harriers does have to find a new more natural balance rather than a sterile heather monoculture.
When the grouse lobby talk about biodiversity for some reason that does not include any predators and that is surely not going to include Lynx.
3. Grouse moors are not a special habitat. They are special for grouse, yes but this is not a natural habitat by any means. We spent 10 days walking from nut to hut on Hardangervidda, Norway, which was so beautiful it made me realise how brain-washed we are about our so called wilderness, I was ashamed of Scotland. True we did only see one brace of Willow Grouse but this was real nature not grouse farming…. and Norwegians are really very pro hunting.
The beauty of the moors is also used as a pro-shooting argument but since visiting similar habitats in Norway I realized there is very little beautiful or biodiverse about a driven grouse moor. If you look at photos of the patchwork of muirburn you will see what I mean. I have seen some beautiful spots of what appear to be un-burnt heather monoculture. I presume they still exist but I admit I don’t fully understand why some areas are like war zones and some have real charm. One of the places that used to be beautiful is on the north side of The Forest of Bowland but now I see there is a new tarmac road from Roeburndale right across to the west of the Forest of Bowland with car parks in the middle of the moor for shooters visiting the grouse butts. Then of course there are the grouse butts themselves, the new idea of hare-proof fences and ditches. No sorry definite beauty-fail on that one.
Another aspect which needs investigating is a comparison with other countries. The UK is one of the most lax (if not the most) country as regards licensing of hunting. No other country has our level of moorland game-keepering (if they have any at all) or monocultural moor management and our penalties are paltry and here compared with the Spanish deterrent.
All in all, the only thing unique about the UK moorlands is in their level of crime, lack of biodiversity, lack of effective law enforcement and complete mismanagement. Nothing to by proud of.


Some facts:
There has been a catastrophic decline of Hen Harriers on grouse-moors in north-east Scotland
There have been no breeding Hen Harriers on Angus Glens since 2006
In 2016 in England there are only 3 pairs of breeding Hen Harriers (none of which were on grouse moors) and which is on the brink of extinction there. Whereas in Wales, which has virtually no grouse shooting, the population is increasing and was, at the last survey, 57 pairs.
The path to extinction is shown in this graph from the government’s Natural England report The Hen Harrier in England
It is only the recruitment of Scottish Hen Harriers to the non grouse moors in England which is giving the ‘English’ Hen Harriers a very precarious life-line and, so far, preventing total extinction in England.

This study proved that ‘On average, 55-74 females were killed each year, 11-15% of the total population of breeding females in Scotland, excluding Orkney’ and that does not include males or immatures. According to this government report the population of Hen Harriers should be about 2,600 pairs, it is actually about 580. Even the grouse lobby in their own paper (Potts 1998) calculate ‘If all potential habitats were occupied, present numbers could more than double, to an estimated 1660 nesting females’.
There is no doubt that is loss is due to persecution and it is not just a few ‘bad apples’ perpetuating these crimes. Here is a list of estates where crimes have occurred.
https://raptorpersecutionscotland.wordpress.com/category/named-estates/
Maps of these crimes can be found on RSPB and PAWS Scottish crime reports.
This situation is the same with Golden Eagles and Peregrines.
This Scottish government SNH study on Golden Eagles states ‘A number of lines of evidence indicated that illegal persecution of eagles, principally associated with grouse moor management in the central and eastern Highlands, is the most severe constraint on Scottish golden eagles….Records of illegal persecution of golden eagles (including poisoning, trapping, shooting) were also more common in those regions where grouse moor management predominated…There was no consistent or strong evidence of associations between territory vacancies and constraints other than persecution in these regions’.
And for the most recent data on Peregrines ‘Illegal persecution continues to restrict numbers and productivity of breeding Peregrines in some regions, particularly where pigeon racing is practiced and where there is intensive management for red grouse shooting‘
and ‘Low occupancy of nesting ranges, with more singletons than pairs, was associated with intensive management for driven grouse shooting.’
and ‘The illegal killing of birds of prey is an important form of wildlife crime, which in the UK, is often associated with land managed for the recreational shooting of red grouse….Population models [of Peregrines] suggested source-sink dynamics, with populations on grouse moors unable to sustain themselves without immigration. Population data confirmed that growth rates were indeed lower on grouse moors than on non-grouse moor sites‘
Unbelievably, although the persecution of birds of prey has been illegal since 1954 and continues, the driven grouse moor owners and managers have found loopholes with which to persecute raptors within the law. So far the law hasn’t caught up with these methods and it is doubtful that they will in the near future given the amount of trust and self-regulation given to the grouse lobby. The only thing that can change this situation is public awareness.
Disturbing or preventing raptors from breeding is illegal. But if gamekeepers can prevent the birds from even attempting to breed it is very difficult to prove. The methods with which the driven grouse moors ‘legally’ persecute raptors includes a staggering array of weaponry.
1. Inflatable screaming and bowing scare-men
2. gas guns
3. delayed fire-crackers
4. What’s next?
If the illegal persecution is not enough there is also the damage to the ecosystem in the form of drainage, burning, lead poisoning, veterinary drugs, flood damage, the ‘self-regulated’ slaughter of mammalian predators and Mountain Hares. These are all subjects which go beyond a single e-mail and with more information daily, more can be found on Raptor Persecution UK, Mark Avery’s blog and the updated edition of Inglorious by Mark Avery.
References:
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.