You ought to be thinking of replying to our latest e-petition calling for a ban on driven grouse shooting – we have now been waiting for over three weeks for a response. In that period, though, the e-petition has gained another 17,000+ signatures. You should be aware that the campaign to end driven grouse shooting is gaining momentum all the time and so you should expect your response to this e-petition to be scrutinised carefully.
Because of that, maybe you would like to make sure that the Defra response is more accurate than last time (and the time before) and does not just look like something that the Moorland Association told you to write.
I’ll take you through the awful response that your department produced last time, but before that I would be interested to know whether you do in fact sign off these responses yourself? You are, of course, responsible for them anyway as they cover your remit, but do you actually look at them? I have asked this question several times before without an answer and I’ll call the Defra press office later this morning to ask them. I can’t see any reason why we taxpayers should not know whether you have personally signed off the nonsense coming from your department; can you?
Also, just to remind you as you draft or authorise your department response to this e-petition, remember that two important things have happened since your last awful response: you have published your plan for grouse moor managers (which you called a Hen Harrier plan) and the north of England experienced heavy floods over the Christmas period, and as you must be becoming aware, these floods are made worse by upland land management of which intensive management for driven grouse shooting is one aspect (see here, here, here).
I’ll now take you through the nonsense you allowed your department to put out as a ‘response’ to this e-petition’s predecessor last year on 17 September.
I’ve structured your response in a different way from the way it appeared but it’s all here and it appears here in a nice Conservative blue colour.
First, Hen Harriers; Defra wrote:
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.
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.
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.
And now you have published your Grouse Moor Managers’ plan masquerading as a conservation plan for Hen Harriers but this hasn’t fooled any of us (except, it seems, the RSPB). Yes, we’ll have to see what happens this year but your plan does not have any targets for Hen Harriers (or Peregrines, Red Kites, Goshawks, Golden Eagles or anything else) does it? You won’t be off the hook on this one until all the SPAs return to favourable condition, including to the number of successfully nesting Hen Harriers which formed part of the reason for their designation, will you? You haven’t made any commitments on that subject at all. Your plan is a non-plan – but I guess you will trot it out in your response. I’ll tell you now, that is only likely to accelerate the rate at which people flock to the campaign to ban driven grouse shooting, because you have a non-plan and everyone can see that.
However, if you have read the copy of Inglorious that I sent you (and for which you have never thanked me – not very polite of you) then you might recall that I think that the Hen Harrier issue is only a part, perhaps even a relatively small part, of why we should ban driven grouse shooting.
Let’s move on to your department’s opening defence of driven grouse shooting, for it cannot be taken as anything other than a stout, but utterly flawed, attempt to tell us all that driven grouse shooting is a good thing. Why did Defra do that?
When carried out in accordance with the law, grouse shooting for sport is a legitimate activity 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. The Government’s position is that people should be free to undertake lawful activities should they wish to do so. 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.
The first sentence (and indeed the second) is very embarrassing – which is why I wondered whether you really did sign off this nonsense. They say, ‘when done legally, grouse shooting is legal’ which is hardly a response to an e-petition calling for it to be made illegal is it? What did they teach you at Eton, minister?
We’ll come back to the economics of grouse shooting a bit later.
You state that grouse shooting can offer important benefits for wildlife and habitat conservation without saying what they are. What are they? I know what some of them are but the problem you have is in showing that this land management system delivers nett conservation benefits, ie when you add up the benefits and the costs what is the balance? Has Defra ever done this rather difficult analysis? Where is it published? Is it a peer-reviewed paper or just something you picked up from the Moorland Association?
In any case, you will, I am sure, agree that it isn’t the shooting that delivers any benefits, but the management – and you would have to concede that the management does not have to be followed by shooting, don’t you? So, if we wished, we could manage the moors in a similar way, not shoot the grouse, and still have the conservation benefits couldn’t we? In fact, we wouldn’t have to manage the moors at anything like the intensity they are managed now in order to maintain open habitats (if we wished to do so) and to maintain the range and distribution of all moorland species – don’t you agree minister? In other words, it’s a fiction that we need grouse shooting, or even that we need the management that underpins driven grouse shooting to maintain conservation interest, particularly given that there is a long list of conservation disbenefits that are derived from the management underpinning driven grouse shooting. And all of that assumes, wrongly, that we want the uplands to stay more or less as they are – which we don’t.
You have probably noticed that the National Trust are moving away (very slowly – they are a bit hopeless) from management for driven grouse shooting for ecological and conservation reasons and that the Wildlife Trusts and RSPB don’t shoot grouse, or carry out intensive moorland burning on their nature reserves. So, on what basis is Defra saying that we shouldn’t ban driven grouse shooting on conservation grounds? Perhaps you could be much clearer on this matter next time around.
And your department doesn’t seem very certain of its ground anyway (how wise!) because your response only said that grouse shooting ‘can’ offer conservation benefits, not that it ‘does’. Well, does it?
So, if you want to look as though you have bothered to address the wildlife conservation case you should tell us why banning driven grouse shooting would necessarily lead to a nett loss of wildlife interest. Could you do that please?
I should point out to you that according to the Langholm study (see Chapter 3 of Inglorious which you have had for 8 months but show no sign of having read) then it is necessary for birds of prey to be killed for driven grouse shooting to be feasible. There is strong evidence that driven grouse shooting can only exist because of persistent, widespread and unremitting illegal persecution of birds of prey such as the ones mentioned earlier above (and the one pictured below). It is your job to conserve these species under English, UK and EU legislation – you aren’t doing your job, minister. Can you look this wonderful Hen Harrier in the eye minister?
Shall we move on to the economics, minister? This was your previous attempt at the subject:
The overall environmental and economic impact of game bird shooting is a positive one and it has been estimated by the industry that £250 million per year is spent on management activities that provide substantial benefits for conservation. For grouse shooting in particular, according to the Moorland Association (http://www.moorlandassociation.org/grouse-2/) 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.
First, you state that the overall environmental impact of game bird shooting is a positive one. This e-petition is about driven grouse shooting and you haven’t backed up your statement with any evidence. Poor show – the tens of thousands of people who support a ban on driven grouse shooting have quite possibly, thought about this rather more than you minister. You ought to give them some evidence rather than such a contentious, unjustified statement.
But you also state that the economic impact of game bird shooting is a positive one. For grouse shooting you rely on a rather duff survey of the people who carry out grouse shooting to estimate the value of grouse shooting – can you see the snag in that minister? According to your figures grouse shooting is worth a paltry £100m to the UK economy each year. You know this isn’t true, don’t you minister. This figure, which is not very accurate anyway, does not take into account the externalities (as economists call them). Defra has a large team of economists so I’m surprised that you spouted this nonsense when they could have told you that it is nonsense. According to the GOV.UK website ‘Defra economists provide analysis, appraisal and evaluation for all aspects of Defra policy, to ensure policy decisions are informed by high quality and robust evidence in order to meet Defra’s strategic objectives.’. Have you passed your previous response to my e-petition by the eyes of your team of economists, minister?
If not, then maybe you should this time. They will/should tell you that management for driven grouse shooting has been criticised for the impact it has on UK carbon emissions by none other than the Committee on Climate Change and that carbon emissions have costs that should be taken into account in any economic appraisal of driven grouse shooting. They may also tell you that the EMBER study showed that water treatment costs are higher for watercourses leaving catchments dominated by driven grouse shooting and that these extra energy and economic costs should also be taken into account. Then they will tell you that another aspect of the EMBER report, backed up by further study, is that the management of moorlands for driven grouse shooting increases flood risk. This is a subject that you should know something about by now minister, and you will have heard a lot of evidence requiring better management of the uplands so that they hold more water for longer in times of downpour. Driven grouse moors are not very good at providing this ecosystem service and those costs should be allocated to them too. You would have to admit that part of the additional costs for flood re are because of intensive grouse moor management – and that these costs are spread across the population and should be taken into account in a proper economic analysis too. And EMBER also shows that aquatic biodiversity is reduced in grouse moor catchments, probably leading to lower fish stocks for anglers and others, and that this is a further external cost that must be taken into account. And whilst we are at it, the lack of sightings of birds like the Hen Harrier above are also ‘economic’ costs that can be estimated and laid at the door of driven grouse shooting.
I think driven grouse shooting is simply a silly hobby, but if you are going to try to justify it on the grounds of its overall economic impact being positive, then you must, you really must, do a half decent job on a thorough economic analysis. I have no doubt that that analysis would demonstrate that driven grouse shooting is costing us all money. Please don’t trot out this nonsense again unless you are wishing to send the signal that you really don’t give a monkey’s about the facts nor about public opinion.
Your previous response clearly recognised the subject of ecosystem services (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.) even though you chose to ignore all these factors in your flawed economic analysis.
Your remaining point was this:
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. 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.
The main point coming out of this is that it isn’t Defra, it is the taxpayers and the voters, who are paying all that money to the uplands. We deserve a much better deal for our money, and, minister, let’s be clear, we expect you to pull your finger out and deliver it. It is not your job to put the case of the Moorland Association to us, the public, as though the government is entirely signed up to it, unless you really are. Are you? Can you possibly believe this guff?
Well, I guess we’ll see when you sign off the next Defra response to the ever-growing e-petition on banning driven grouse shooting.
All 27,000+ of us look forward to a much better response this time around.