Whatever it was that Defra published yesterday, it was not an action plan to save Hen Harriers. It was a hybrid between a Hen Harrier inaction plan and an action plan to postpone the demise of driven grouse shooting. In that regard it was generally a damp squib; a small victory for the grouse shooting industry and a small defeat for the RSPB and a rather larger defeat for the Hen Harrier.
Why do I say that?
Well, for starters, this so-called plan has no targets except to have a few Hen Harriers dotted around the English uplands at some stage in the future (see Success Criteria). For heaven’s sake! This is Defra – they have a responsibility to restore the SPAs designated, in part, for their Hen Harrier importance under the Birds Directive, to favourable conservation status. This is not even an aim of the plan. There isn’t even a milestone towards this spelled out in the plan. This legal responsibility is ignored in the plan. Why has the RSPB welcomed this plan without this very obvious objective?
Second, the RSPB has failed to get either vicarious liability or licensing of game shooting into this plan, even as something that government will look at. It seems to me that the RSPB often forgets what its own policies are.
Third, it is good to see satellite-tagging in this plan, but then, how could it not be? It is also good to see that the point made in this blog (here, here, here – but I’m sure elsewhere too), that this needs to be done on a wide geographic scale, and not just in England, in order to learn more about Hen Harrier biology and to catch more criminals, is recognised. There is no costing of this work and no analysis of whether current resources are adequate. There is no promise from Defra of a big increase in resources to make the most of this modern technology over the next few years. Why did the RSPB not insist on this as a part of the plan? And why are the Moorland Association, National Gamekeepers’ Organisation and others not identified as finding major resources for this aspect of the ‘joint plan’? Why aren’t landowners and keepers contributing hundreds of thousands of pounds to this work over the next five years? You work it out!
Fourth, I was interested to see that the cost of provisioning a brood of Hen Harriers is stated as being a mere £1,150/year. That’s amazing! In England, we are told that there should be 330 pairs of Hen Harrier in the uplands – although none of us can even imagine a time when that might be the case. But if we could, then they wouldn’t all be nesting on grouse moors (or feeding on them either). But let’s assume they would be (but they wouldn’t!), that would be a cost of c£350,000 a year for an industry that claims it spends £50,000,000/yr on management. A drop in the ocean! A pittance! Put your prices up a bit and the whole problem is sorted if that figure is correct. Indeed, Defra could even consider paying for diversionary feeding itself at those rates. I guess it would cost less than £100,000/yr in practice. Chicken feed to get the problem sorted. Why isn’t that even considered in this so-called plan?
Fifth, there is a hint of good news, in that the Defra plan says that the intelligence building aspect of combatting wildlife crime will continue and be part of the work of NWCU – rather difficult to abolish it then!
Sixth, although most attention has been and will be focussed on the mention of a southern reintroduction and a think about, and then a trial of methods of, brood meddling there is no indication that Defra will fund this work – and why should it? This is classic ‘kick it into the long grass’ behaviour and my prediction is that nothing will happen. And of course if it did, then neither of these actions would do much for the missing c330 pairs of Hen Harriers that we should see in the English uplands. Whatever the shooting industry might say, they know that nothing much will happen in these areas, but it is a small victory for them that the very idea of brood meddling hasn’t been ruled out completely.
And so we have a government department publishing, at long last, its plan for a threatened species which omits to have as its aim the restoration of that species to SPAs designated for it, and fails even to set an ambitious population target for recovery. Defra has forgotten what it is for – and it has also forgotten who it is for. It exists to save wildlife and further the public good, not to be nice to its mates in the grouse shooting industry.
We have a plan where the RSPB hasn’t really been able to get anything worthwhile in the plan. Defra isn’t going to do anything that it wasn’t doing already, the criminals have not been made to cough up money for satellite tags, there is no target with which to hold government or anyone else to account, and the policy objectives of stronger regulation are missing – yet the RSPB welcomes the plan. A bit strange and a bit disappointing.
Yesterday was one of those days when several things came together. We had this hopeless non-plan for inaction from a government department that has so lost its way that its support from the environmental community should be practically zero.We had the revelation on this blog that the shooting industry, at least the Buccleuch Estate part of it, can’t be bothered with any of this stuff and wants to be able to employ lethal control of raptors. And we had a popular movement, unaided by any major wildlife conservation organisation, reaching 30,000 signatures on an e-petition to ban driven grouse shooting.
The least significant of the three is this Defra plan for inaction, which we can see as a plan to postpone the demise of the grouse shooting industry.
The grouse shooting industry has no wish to occupy any middle ground. The RSPB has failed to influence Defra at all to do its proper job, but the general public is making it clear that they see an end to driven grouse shooting as the solution to the problems of the Hen Harrier and a whole range of other ecologically damaging consequences of this hobby for the rich.
Sign this e-petition to ban driven grouse shooting to help Defra get its head straight and to show the grouse shooting industry that there is a real plan out there to save the Hen Harrier.
43 Replies to “Defra’s plan”
“yet the RSPB welcomes the plan.”
It’s always hard to tell from the Guardian’s grammatical cheese-grater, but doesn’t the following sound odd?
“‘I welcome this plan – not because it is perfect, it isn’t – but because it reflects real potential for progress on one of the most deep-rooted conflicts in conservation. We needed action. The prize is that the landowners are now part of the conversation. The test will be if we succeed in getting the hen harrier flying again over upland England. This is progress,’ said Martin Harper, director of the RSPB.” (http://www.theguardian.com/environment/2016/jan/14/long-awaited-plan-to-save-englands-hen-harrier-gets-green-light)
‘It’s not perfect; it’s potential for progress. We needed action’ is, as Mark more succinctly puts it, inaction. If only those involved in the ‘plan’ had that clarity in communicating common sense.
I’d have been happier had the RSPB welcomed publication of the plan, for public deliberation and comment. What the RSPB actually appears to be doing is turning a blind eye to aspects of the plan – giving up, walking away. How can any credible conservation charity stand by and allow harriers to be removed to allow unfettered driven grouse shooting? Their stance is a sign of great weakness.
Cicely, I was wondering if Mark had shared a few other facts such as:
1. Wildlife conflict – Mark acknowledged in his autobiography (page 192) that prior to 1997 he, and the RSPB, were quite wrong to dismiss gamekeepers’ fears about hen harriers. After 1997 Mark, as conservation director at the RSPB, helped finance diversionary feeding – which failed to resolve the issue (see below) at Langholm. Vicarious liability and licensing has not been tested at Langholm and no one is suggesting it would help resolve the conflict – so clearly, if we wish to address the conflict, we need new ideas because…
2. Diversionary feeding – the most recent report from Langholm, signed by the RSPB, clarifies that diversionary feeding alone has not been shown to increase numbers of young grouse on the moor. Diversionary feeding may be a useful tool to further mitigate the impact of harriers on an individual moor but it has not been proven to improve grouse productivity. It would be odd for anyone, including the RSPB, to continue suggesting is a solution by itself. What else can be tested…
3. Brood management – has helped recover harrier numbers in France and is also being used by the RSPB for spoon-billed sandpipers. The GWCT sees this simple conservation measure as a ‘remedy’ that unlocks the impasse the conflict creates, in other words a precursor to allowing hen harrier numbers to recover. How to do it is known. It could be available, if required, to help with this breeding season.
4. The middle way – Defra have just embraced this. In Mark’s autobiography (page 194) he talks about how the middle way would appeal to the British love of compromise and that may be no bad thing – and that a ban should be held in reserve should the middle way fail. The middle way is now up and running – with a positive approach could be ready for this breeding season. It is not surprise that the RSPB might also think that is no bad thing.
5. Banning driven grouse shooting – Mark keeps suggesting this is the solution but as he knows, from his old job at the RSPB, he is conveniently ignoring the wider conservation, employment and economic benefits of moorland management for grouse. Secondly, Mark fails to address why there are so few hen harriers on the 50% of suitable habitat not managed for grouse shooting.
6. Action – the plan aims to increase harrier numbers – just like the plan to recover spoon-billed sandpipers (RSPB, WWT, Birds Russia and Moscow Zoo, BTO, BirdLife International, ArcCona and the Spoon-billed Sandpiper Task Force). The specifics in either plan are few but it’s not complicated – the focus is on reversing declines to secure favourable conservation status. If Defra embrace an approach to planning that is used by conservationists around the world – it would be bizarre for conservationist to then call this ‘inaction’.
You might now see the logic in Martin Harper’s comment?
Andrew – a totally bizarre post.
Andrew, as the representative of GWCT, I’m surprised to see you describe brood removal as a:
”….precursor to allowing hen harrier numbers to recover”
So, GWCT admits that driven grouse shooting estates and their game keepers will not ‘allow’ hen harriers to recover (survive) without brood removal – at least you’re now willing to express your threat explicitly.
And as a ‘precursor’ to allowing hen harriers to recover? In other words, if you don’t get brood removal this spring, the hen harrier slaughter will continue?
Actually, might I suggest that driven grouse moor owners and their game keepers allow the hen harrier population to recover to a pre-defined level, after which brood removal can be considered on a case by case basis, after other mitigation steps (diversionary feeding) have been attempted?
Messi, I feel you have illustrated my point. Diversionary feeding is in the plan but it does not address the conflict – brood management could help unlock that. Hence ‘allow’. No threats from me. Best. Andrew
Andrew, I agree with Mark that your contribution is more than slightly bizarre, and am tempted to respond to some of the comments you have made. You are obviously a highly intelligent man so it is difficult to patronise you, but as a lifelong naturalist who has specialised in studying Hen Harriers for much of the past twenty years, I can instantly gather from your comments above that you are surprisingly naïve concerning the natural history and biology of the species. I gather you think with the perspective of someone who is comfortable with the culture of killing wildlife for so-called ‘sporting’ purposes. Otherwise I do not know you or much about your background. But then I’m sure you’ve never heard of me either! I’ll try to be brief.
1. Prior to 1997, I wasn’t happy with RSPB’s approach to the perceived hen harrier problem. It seemed confused – on the one hand maintaining that harriers weren’t harmful to the grouse shooting industry, whilst on the other handing out quite bizarre land management advice on how to reduce harrier densities non-lethally. I explain this in a paper I am currently preparing.
2. Diversionary feeding. I strongly oppose this practice philosophically and ethically, and my position regarding its practical efficacy is closer to your opinion than that of RSPB or Mark Avery.
3. Brood management. It is irrational to equate the ecology of UK Hen Harriers with the French harrier population or the Spoon-billed Sandpiper. The French farmland breeding habitat is a world apart from the English countryside in terms of the former’s expansiveness of rich habitat with a suitable prey population. The only habitats in modern UK which are suitable are upland or semi-upland dwarf shrub heath (principally heather) habitats with large expanses of unimproved graminoid vegetation and mires. In England most of these are situated on grouse moors. It is not biodiversity per se which attracts the harriers, but biomass of small passerines (mainly meadow pipits) and small mammals (field voles).
4. The middle way. There is no middle way which could be realistically described as either sustainable or an ethical solution. This would involve unacceptable continuous damage to the peatland environments, moorland biodiversity and rare animals like the Hen Harrier. The outcome of the plan in England, even were persecution to be eradicated (seems unlikely), would result in only 70 breeding pairs when there is carrying habitat capacity for more than 300 pairs. It is impossible for one sector of society to continue to kill “our” wildlife for their entertainment, without causing considerable offence and anxiety to the remainder. In that sense it will always be unpopular and unacceptable to those who want to live in a peaceful and less cruel world. To put it bluntly, there’s no need for it, and those who participate in grouse shooting could survive quite happily without it. In my experience most British people wish to see nature flourishing unmolested, and their wishes should be respected and reflected in law.
5. Banning driven grouse shooting. I think I’ve made my views perfectly clear. To answer your question, it is simple to explain why there are so few harriers on 50% of suitable habitat which are not managed grouse moors. In one word, persecution. In more than one word, it is a result of the sink effect which draws harriers to breed on or near grouse moors, where gamekeepers shoot them. No-one as far as I know has ever denied that harriers are attracted to breed on managed grouse moors, but that is because most heather moorland, especially in England, is on land managed for that purpose. In that sense it is a poisoned chalice for harriers and predators generally.
6. Action. Your final paragraph, I’m sorry to have to say, is detached from reality and seems to me a desperately sad argument. Some plans are good, based on sound science, while others aren’t so good, based on hope and money-tossing. The Defra Hen Harrier Action Plan is worse that that; it’s cynical to an agonising degree, a shameless concoction of irrational and unscientific proposals, aimed purely at satisfying the urge of the greedy hunting community to exert even more control over nature doing what nature does. I do hope Mark’s efforts towards getting the guns off the moors is eventually successful.
It’s getting to final straw time for me regarding RSPB. Martin Harper hang your head in shame. Utterly useless and spineless.
I left the RSPB several years ago, after 35 years membership, when my eyes were opened as to the operational reality of the shooting season lists originally formed by the provisions of Edward VII’s Royal Charter. The RSPB needs to review its raison d’etre, not just despicable DEFRA!
Maybe it’s time to think about staging protests on the grouse moors where the CRoW Act would allow?
Though I think the CRoW Act would prevent a legal protest on shoot days.
I’m very much in agreement Andy. There will be ways around any restrictions I’m sure.
I’m not the least surprised by Defra, but I am incredibly disappointed with the RSPB, particularly Martin Harper who is someone I’ve always held in high regard.
This is nothing short of a complete cop-out, and after reading Martin Harper’s blog, I’ve come to the decision that I cannot in all good conscience continue to support the RSPB. I feel like there is nothing else I can do.
Roderick Leslie’s description of the ‘action plan’ as: ‘a dead cat and a putrid one at that’, sums up it perfectly.
Sadly for all bird lovers Martin Harpers latest waffle is just the usual stuff,almost five years into the important appointment of Conservation Director of the RSPB I doubt he has achieved very little and on two important cases of Hen Harriers and Farmland Birds he seems to have complete inaction.
What a disappointment for someone we should be able to rely on to fight the corner of birds either declining due to modern farming and in the other case deliberate persecution.
I believe HOT will be self funding a Hen Harrier brood management trial.
I am confused by this part of the plan which states
‘A trial scheme … would be open to driven grouse moors that had brood numbers in excess of the modelled densities and would run for a minimum of 5 years. An agreed threshold, based on independently derived, objective criteria, and agreed by main stakeholders, would be set for contiguous groups of estates. When harrier numbers within estates increased above the density determined by Elston et al, their eggs or broods could be moved to a rearing facility away from managed moorland.’
I am worried about the clause ‘agreed by main stakeholders’. Does that give them the right to ignore the main clause, that the threshold is given in the paper by Elston et al.
Is it one or the other or is is definitely dependent on the density above Elston figures?
Can someone help. I am deeply worried that they will do a ‘badgers’ and start the trial with no restrictions what so ever.
Raptor Persecution Scotland is convinced that the threshold will be 70+ Hen Harrier pairs on English grouse moors. I have my doubts, politicians like Merricks usually get there way especially these days. Could they be releasing 140 Hen Harriers in the lowlands and then saying ‘right there is your 70 pairs now we can get the rid of the vermin off our moors’ or just simply ignore the condition. Nothing is beyond these people.
Brood persecution ‘would be open to driven grouse moors that had brood numbers in excess of the modelled densities’ so as i read it, the ‘trial’ wouldn’t require 70+ pairs on grouse moorland but just high enough densities on a moor (with the added clause) ‘contiguous groups of estates’.
Elstons paper is here
I scanned the Elston paper. There isn’t really a given density as far as i can see only a discussion.
‘High Densities of harriers (above 0.1 nests km2) are clearly identified as a problem for grouse management… Yet at harrier densities of 0.025 km2 or less, impacts are predicted to be relatively low’. The latter would give 70 pairs in England and the paper goes on to say ‘Even the lowest hen harrier density considered here, 0.0125 km2 would be equivalent to 35 pairs of harriers breeding in England’.
As i understand it any moor with a higher density than 0.025 km2 (pessimistically 0.0125 km2) would be eligible for brood persecution.
Then all they do is shoot the remaining Hen Harriers, tagged or not, and claim they just ‘went missing’. Which mafia don wouldn’t sign up for that?
Just saw that Martin Harper has made a comment on Raptor Persecution Scotland.
He implies that the trial still needs to fulfil RSPB conditions.
I am no wiser.
And how might this “plan” be used in partial response to your petition Mark?
Sadly we all know the answer.
I am a long-standing RSPB member and don’t intend that to change in the foreseeable future yet how do I go about making my feelings of disappointment clear – a petition maybe?
I’ve posted my comments on Martin Harper’s blog. If we all express our displeasure there, maybe the RSPB will start to consider that it is out of step with its membership.
This action plan represents the common ground between all parties, i.e. there is none.
What is the emotional focus of the Inglorious campaign? It’s Henry the Hen Harrier, so grouse shootings’s strategy has to be to become Henry’s friend, and it will take years to prove that the plan isn’t working. The issue is about to kicked into the long grass.
The same strategy is being used on the lead ammunition campaign where the emotional focus is swans dying of lead poisoning on wetlands. Here the game shooters have proposed that Defra operates a bogus testing regime in an attempt to prove that the rules on lead ammo on wetlands are being observed. Again, more long grass, and more time bought before it’s proven that nothing has changed.
The real problem is that the government is firmly on the side of game shooting and will do all it can to ensure that these strategies succeed.
DEFRA website states they are:
“The UK government department responsible for safeguarding our natural environment, supporting our world-leading food and farming industry, and sustaining a thriving rural economy.”
Perhaps 1 out of 3 aint bad? It certainly supports the farming industry through supporting grouse shooting with massive injections of public (our) money, but is a grouse moor part of the food and farming industry? So maybe 0 out of 3.
While I’m absolutely convinced that RSPB staff, Trustees and volunteers are dedicated and committed people, their corporate bosses (as with so many other NGOs) have become conservative (small c) in order to grow their business. But at what cost?
Wow, congratulations Mark for a well thought out and well written reply to DEFRA’s rubbish. Its about time someone with common sense told DEFRA where to go. There is absolutely no point in releasing hen harriers in the south of England; if they are to be released it should be on the grouse moors where they belong. But there is a hitch isn’t there to this strategy? DEFRA already well aware these birds would be shot on sight, otherwise this would have been included in their action plan wouldn’t it?. The whole plan seems to me like putting the horse before the cart and a huge waste of money until the killing of hen harriers is brought to an end.
The plan talks of monitoring, I presume this includes potential monitoring of any nesting activity established on privately owned grouse moors? Another hitch, because anyone with a licence and who is in receipt of payment for the work they undertake, including RSPB staff, must obtain the prior approval of the landowner to enter onto a grouse moor. In my experience of monitoring birds of prey on grouse moors in the north of England since 1967, estates would not voluntarily provide such approval without a change in the law. Nor does it help when Natural England revoke the licenses
previously held by experienced raptor workers who have proven their ability to protect hen harriers on moorland where persecution continues to be widespread.
‘the landowners are now part of the conversation’. What planet is Martin Harper on ?
25 years ago the RSPB was a force – not always right, by any means – but a force nevertheless. It seems now just to be a glorified golf club, with membership conferring the usual comfortable privileges, but on reserves and cafes, rather than on courses and clubhouses. It has acquired the Labour Party disease – it’s purely managerial rather than radical and effective on the issues that matter.
Yes, about twenty-five years ago the RSPB was described by parliamentarians as a ‘devastating lobby’; today they’re perhaps better described as ‘devastatingly floppy’
Mark, I fully support your comments. My initial thoughts when I read the details of the plan were:
– how many years?
– how many people?
– how many meetings?
– FOR WHAT?
This is a sad and sorry excuse for an action plan, no licencing scheme, no vicarious liability, no ban – just business as usual for the Driven Grouse Shooting industry (it’s not a sport). Worse than that it actually includes brood meddling. What the plan does do is expose the RSPB as wearing “the Emporers new clothes”. It appears to have sacrificed what it has been telling us are it’s beliefs on this issue for nothing. In terms of this report it appears to play the role of a hapless dupe whose name is useful to DEFRA and the shooters to have appended to the plan. As an owner and manager of reserves the RSPB is brilliant, as a campaigning organisation it is hapless. Time for a total rethink of it’s structure, operations, purpose and leadership!. As a member I have no wish to leave because of the excellent work it does with Reserves and supporting organisations such as Birdlife with their work but as a UK campaigning organisation I have lost all confidence in it’s current management and abilities.
Lastly DEFRA and Natural England. Lived down to expectations yet again. Presumably the hopeless Liz Truss survives because nobody else wants the career ending role. If this is a national plan for survival and growth of one of our most threatened bird species it’s content and quality are shameful.
Alf, perhaps consider doing what Mark suggested in one of his New Year Resolution blog posts? Clearly you’ve reviewed and decided that they are still worth your cash but what’s to stop you writing to Martin Harper – the more folk, still members, who actually scribe and relay dissatisfaction then they may just start to take a bit more notice (we can live in hope)?
The rest of us should write to our MPs raising the omissions and expressing our disappointment (or stronger)? OK what is received back is unlikely to be worth the paper it’s written on, but that they’ve not managed to dull the campaign must irritate them somewhat?
Agree with all the above comments about RSPB and other large membership NGOs, but lest we forget that RSPB did at least take up the cudgel with Walshaw when NE dropped the case.
I like George Monbiot’s description of what DEFRA stands for; Do Everything Farmers’ Representatives Ask.
My take on DEFRA; Do Effall For Rare ‘Arriers.
I’ve already submitted comments to Raptor Persecution Scotland, and would recommend that anyone with an interest in harriers, and the Defra Action Plan, should look at that excellent blog site as complementary to Mark’s. Having studied the Plan in more detail, and read some of the supporting scientific documents, I’ve had to seriously pinch myself to be convinced this is reality!
Just about everything in the Action Plan is entire drivel. Sorry I can’t think of any more diplomatic way to summarise this, but anyone with even a modest understanding of harrier ecology or conservation ethics will know what I mean. It is truly astonishing, and extremely worrying in a wider context, that the RSPB seriously considers it to be a meaningful tool to further the cause of nature conservation in the UK, particularly the future of the Hen Harrier. To get bogged down in its almost infantile “solutions” to a non-existent problem is not a matter for serious scientists, civil servants or wildlife charities. The amount of human intellect, resources and public money being wasted on this exercise is an utter disgrace. The Plan as it stands is nothing more than a combined delaying tactic, and a cynical ploy to persecute harriers by the back door.
Is the RSPB really so stupid as to become involved with this? That is hard to believe, and is certainly not the opinion of most of its staff whom I know. Even setting aside the unethical and plainly ridiculous “brood management” element, to participate in discussing the other options is akin to Greenpeace cooperating with the Japanese whale “research” programme! I notice that RSPB chiefs frequently refer to the importance of scientific research, community involvement, partnership working and so on, but rarely seem to use the word “ethics.” A worrying trend which I have noted with increasing frequency in recent years is the phenomenon of corporation-friendly scientists, long familiar in the tobacco industry, but now spreading into other fields including environmental areas. For obvious reasons I can’t name names, but some of the those (one in particular) which crop up as authors of supportive papers to the Defra plan are individuals I have come up against in a number of cases concerning planning applications and appeals. We need to be aware of this added complication.
The Langholm studies have a lot to answer for. I realise there is some degree of disagreement over interpretation of results between RSPB and the game shooting industry, but why do we keep hearing almost exclusively one and not the other? Why does the RSPB seem to have so little impact or clout, even with its one million members? To my mind the main issue is a fundamental intellectual error, in that the whole “problem” is founded on a false premise based largely upon the Langholm studies apparently confirming a widely held belief that Hen Harriers seriously deplete surplus Red Grouse numbers available for shooting. Quite simply, that is not proven, as would be the verdict in a Scottish court of law. The science is flawed.
How can we arrive at a definitive conclusion based upon one study at one site? Other studies which are by comparison low profile have actually shown that harriers need not rely on Red Grouse chicks to feed their young. For example, CCTV camera data collected at five Hen Harrier nests in the Clyde Muirshiel Regional Park (on grouse moors) between 2003 and 2007 revealed that of 1,285 prey items delivered to the nests, 93% were Meadow Pipits, 2% were unidentified small passerines, and 5% were Field Voles. Not a single Red Grouse, chick or adult. Observations from other harrier nests by raptor workers, in southwest Scotland, show similar non-existent low predation levels of Red Grouse. My own intensive watching of harriers over a period of seventeen breeding seasons resulted in only one record of a harrier killing a Red Grouse, and that was an adult. How often do we see photographic images of harriers carrying prey which isn’t a pipit or a vole, or occasionally a wader chick? I would suggest very rarely, and hardly ever a grouse chick, for one main reason; harriers do not prey preferentially on grouse. I suggest that an analysis of habitat subtypes and prey availability at Langholm would reveal the reason why on occasion large numbers of grouse chicks may be taken there. The question certainly requires further research.
If, as seems highly likely, Langholm is atypical, then the belief that harriers significantly reduce grouse stocks is blown out of the water, and the draft Hen Harrier Action Plan can be consigned to the dustbin.
Jack Snipe – thank you very much for your comment.
I don’t agree with you about the impacts of Hen Harriers on grouse (read Chapter 3 of inglorious) but you make a lot of good points, thank you.
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