To Rory Stewart, Defra
The government response to the e-petition to ban driven grouse shooting is simply awful. It is partial and inaccurate. I have previously asked Defra whether responses of this sort are seen and signed off by ministers and have never received a response. Did you sign off this response? Did one of your ministerial colleagues? And do you take responsibility for it?
Given that you have had, as requested, a copy of my book Inglorious on this very subject, I would have thought that the government response might have been a bit more carefully written. Have you read Inglorious yet, by the way?
Here is a first pass at the government response. There some things that really ought not to be in this response – if only IPSO covered matters of this sort then I feel sure that we could press Defra to make a corrections and apologise. And that is what the department should do anyway.
Defra is working with key stakeholders to ensure the sustainable management of uplands, balancing environmental and economic benefits,
Balancing environmental and economic benefits – you do realise that many of the environmental benefits of the uplands are statutory and legal requirements, don’t you? There is no question of balancing the environmental goods such as favourable condition of protected sites and protected species with economic activity. It is Defra’s job to ensure that Natura 2000 sites are in favourable conservation status and that Hen Harriers and other protected species have favourable status too. Would you agree? This response is not suggesting, or is it, that this government is relaxed about trading off legal environmental requirements for short-term economic gain?
…which includes the role of sustainable grouse shooting.
Sustainable grouse shooting – how does Defra define that? I think this is a phrase that you have just invented. Would you not agree that sustainable grouse shooting, if it could be defined, would be grouse shooting that did not damage the environment? Or do you have another definition? Given that the UK is currently dealing with a complaint to the EU over damage to protected blanket bogs right across northern England due to grouse moor management (did you see Martin Harper’s blog today?) and that English Hen Harrier breeding populations are more than 300 pairs below their potential level (according to a statutory agency report) and that protected Peregrine Falcon populations are routinely persecuted on English grouse moors and that rivers whose catchments are dominated by driven grouse shooting have reduced aquatic biodiversity and are more polluted and are more prone to flooding, and that the Committee of Climate Change has just recently criticised the management underpinning driven grouse shooting thus ‘The damaging practice of burning peat to increase grouse yields continues, including on internationally protected sites.’ I suggest that we are far away from sustainable grouse shooting and are getting further away from it with every year that passes. How does Defra define sustainable grouse shooting, and how prevalent is it in the real world? It doesn’t seem that you have got to the end of Chapter 5 of Inglorious yet?
When carried out in accordance with the law, grouse shooting for sport is a legitimate activity…
When carried out accordance with the law, grouse shooting…is a legitimate activity – come on Minister, you wouldn’t have got away with this when you were at Eton, let alone when you got to Balliol, would you?
…and in addition to its significant economic contribution, providing jobs and investment in some of our most remote areas, it can offer important benefits for wildlife and habitat conservation.
Grouse shooting can offer important benefits for wildlife and habitat conservation – it could, but does it? In particular, does it deliver nett benefits or does it just offer some benefits that are vastly outweighed by the disbenefits? What is your position on this – and is it the position of the foxes, stoats, blanket bogs, mountain hares, raptors and native woodland? This statement is in the same category as ‘Hitler wasn’t all bad’ – it might be true but it isn’t important.
The Government’s position is that people should be free to undertake lawful activities should they wish to do so.
The Government’s position is that people should be free to undertake lawful activities should they wish to do so – that’s big of the government! Gee! Thanks!
However, we encourage all shoot managers, owners and their staff to follow best practice to reduce the chances of a conflict of interest with birds of prey.
What form does this encouragement take please? Of what, precisely, does this practice comprise? The conflict of interest between driven commercial grouse shooting and birds of prey is a biological inevitability – the birds of prey eat the grouse the killing of which grouse managers want to sell to clients. Defra must surely be aware of the Langholm study? If not, you will find an account of it in Chapter 3 of Inglorious.
The overall environmental and economic impact of game bird shooting is a positive one…
The overall environmental and economic impact of bird shooting is a positive one – you are in trouble here Defra. You used this phrase in your response to John Armitage’s e-petition calling for licensing of shoots and I pointed out that it was not backed up by evidence then. In reply to a letter from my then (and excellent) MP, Andy Sawford, asking for the evidence on ecological costs and benefits of releasing pheasant and red-legged partridges into the countryside Defra replied they didn’t have any evidence and had no plans to collect any. So why have you resurrected this phrase for this response? It’s probably because you aren’t really trying to base your response on evidence and that you, for some reason I can only guess at, are taking the side of the shooting industry rather than looking at this matter objectively. You should correct your response. If IPSO had jurisdiction here, I bet they’d make you!
…and it has been estimated by the industry that £250 million per year is spent on management activities that provide substantial benefits for conservation.
Estimated by the industry… – and you as government take that as true do you? Why? As you know, those industry estimates have been taken apart by economists (funded by Animal Aid, instead of funded by the shooting industry) on the grounds that they are overestimated by a factor of around fourfold and that they include public money (taxpayer money) that would be spent elsewhere and perhaps to greater benefit, if not in this way. Why does a government department simply regurgitate industry figures without checking them? You are the Daily Telegraph of government departments it seems – failed to check figures given to you by a single source which happens to be the shooting industry. Defra should correct this bit of its response. You may find Inglorious (pp 229-30 and references at the back) of value here.
For grouse shooting in particular, according to the Moorland Association (http://www.moorlandassociation.org/economics3.asp) estates in England and Wales spent £52.5m on managing 149 grouse moors for shooting in 2010; Scottish landowners manage a further 150 moors for shooting grouse. The industry also supports 1,520 Full Time Equivalent jobs and is worth £67.7 million in England and Wales. In Scotland grouse moor management is estimated to be worth £30 million per year.
You are here again taking the industry figures as true and accurate. Why? Have you checked them? But, in any case, these figures do not take into account the externalities of economic costs and loss of value of natural capital, do they? (No they don’t!). The external costs include increased greenhouse gases (as referred to by the Committee on Climate Change above), increased flood risk (and house insurance costs), increased particulate matter and acidification of catchments (and increased water bills for the consumer), damaged landscapes which are burned in unsightly geometric shapes and loss of wildlife which is part of our natural heritage. How much do these add up to? What is the nett effect? Do you have any idea? At any conservative estimate the externalities far outweigh the economic activity of grouse shooting. And moreover, Minister, the money spent on grouse shooting would not disappear from the economy if not spent on blasting birds out of the sky – rich shooters will spend their money in some other way, perhaps not in the same geographic localities, but the money will not be lost to the economy if grouse shooting disappeared tomorrow. Would it? There’s quite a lot about all this in Inglorious Chapters 4 and 5 – have you got that far Minister?
Grouse shooting takes place in upland areas and the Government is committed to helping create a more sustainable future for the English uplands. They are endowed with natural assets that are important for delivering a range of valuable “ecosystem services”, including food and fibre, water regulation, carbon storage, biodiversity, and recreational opportunities for health and wellbeing.
With regards to carbon storage in particular, the Government recognises the significance of peat as a natural carbon store and acknowledges that historic land use and management has caused degradation of UK peatland and resulted in the loss of stored carbon. The last decade has seen increasing numbers of conservation initiatives (such as Nature Improvement Areas and Sites of Special Scientific Interest) which have halted the loss of and re-established areas of peatland in UK and therefore reduced the loss of peat stored carbon.
The Government is also taking measures to protect peat including the pilot Peatland Code. The pilot Peatland Code was launched in September 2013 with the aim of promoting the restoration of UK peatland through business investment. It is hoped the Code will assure restoration delivers tangible benefits for climate change alongside other benefits such as restoring habitats for protected species and improving water quality.
In response to the three paragraphs above – yes, but banning driven grouse shooting would solve many of these problems at source and at a stroke. You aren’t making much progress on these issues, because you are far too wedded to market solutions. The economic ‘benefits’ of grouse shooting accrue to a small number of land owners – the costs accrue to a large number of taxpayers and the public in general. This is a classic case where government needs to intervene to prevent the selfish interests of a minority overriding the public good. Defra is not doing its job and the suspicion has to be that this is partly because those few beneficiaries of the current unsustainable system are supporters of the present government.
Defra will also be investing over £3 billion in agri-environment schemes (Environmental Stewardship and the new Countryside Stewardship scheme) in the next Rural Development Programme 2014-2020.
You will, will you? Just remember that is my money, and the money of all taxpayers, and it should be spent for public good not private profit. And actually, that sum is surely for England as a whole – a very small proportion will be spent in the uplands, and an even smaller proportion spent on the issues under discussion here.
Addressing loss of biodiversity will be a priority for the new scheme. In addition, and as a core element of the approach to securing synergies across a wide range of rural habitats, funding will look to maximise opportunities to deliver biodiversity, water quality and flooding benefits together.
In response to the issue of illegal killing of protected wildlife, the Wildlife and Countryside Act 1981 affords protection to all wild birds and certain other species. Despite the protection afforded to birds of prey, such as the hen harrier, incidences of illegal killing of birds of prey continue to occur. To address this, senior Government and enforcement officers in the UK identified raptor persecution as a national wildlife crime priority. The National Wildlife Crime Unit, which is part-funded by Defra, monitors and gathers intelligence on illegal activities affecting birds of prey and provides assistance to police forces when required. Despite instances of poisoning and killing of birds of prey, populations of many species, such as the peregrine, red kite and buzzard have increased.
The level of illegal persecution is still unacceptably high – wouldn’t you agree? What level of wildlife crime would be acceptable to Defra? The human population is increasing but trapping, poisoning and shooting are still regarded as crimes across the world – aren’t they? What level of Hen Harrier and Peregrine population is Defra aiming to achieve?
With regards to hen harriers, it is encouraging to learn that there were six successful hen harrier nests this breeding season, fledging 18 chicks, figures which show it is on track to be the most successful year since 2010.
It is, isn’t it? What a shame then that so many males have disappeared under suspicious circumstances this year. Given that the statutory agencies estimate that the English uplands could have 330 pairs of Hen Harrier if these birds were not illegally killed, how many pairs of Hen Harrier would Defra like to see in England? How many pairs of Hen Harrier would Defra wish to see in the SPAs that were designated with Hen Harrier as part of their biological interest – to remind you there should be at least 13 pairs of Hen Harrier in the Forest of Bowland SPA (and they shouldn’t be mysteriously disappearing) and this year there were six nests (and several males did disappear). We should celebrate some movement in the right direction – but Defra should not look and sound so complacent and should be taking greater steps to rectify the Hen Harrier deficit in England. Inglorious covers this in Chapter 1 (and elsewhere) – you must, surely Minister, have got to Chapter 1?
The Uplands Stakeholder Forum Hen Harrier Sub-group was set up in 2012 with senior representatives from organisations best placed to take action to address the decline in Hen Harriers. These include Natural England, the Moorland Association, the National Gamekeepers’ Organisation, the Game & Wildlife Conservation Trust, National Parks England and the RSPB. Defra welcomes the involvement of all parties.
The Sub-group has developed a draft Joint Action Plan containing a suite of complementary actions intended to contribute to the recovery of the hen harrier population in England. We are working with Sub-group members to finalise the Plan. Does the plan include a massive increase in the number of satellite-tagged Hen Harriers in order to deter illegal killing and aid detection of crime and criminals?
I ask you again Minister – did you sign off this response? Because it is a poor response. It is partial and inaccurate. It looks as though Defra is a rather poor public relations machine for the shooting industry.
We, the taxpayers and voters will remember this and we are watching your future action. Please remember you work for all of us, not for the shooting industry.
In the meantime, please watch the number of signatures continue to rise as the public demands that you ban driven grouse shooting.