Questions for Defra

I submitted this request for information to Defra on 12 September. I am looking forward to receiving their full response on or before 12 October so that I can refer to it in my oral evidence to the inquiry into grouse shooting.

 

 

This email is a request for information ahead of an evidence session of the House of Commons Petitions Committee on e-petition 125003 ‘Ban driven grouse shooting’ which has received more than 121,000 signatures on the date when I write to you and will therefore be debated by MPs in Westminster Hall at a date which is yet to be set later this autumn. As the petitioner, I have been called to give evidence to the Petitions Committee in an evidence session which has been set for 18 October (although the date is not public knowledge at the time of writing to you).

I require you to provide answers to the following questions to assist me in giving evidence to that evidence session. I need your responses by midnight on 12 October to give me, an ordinary member of the public, lacking the resources of government departments, time to assimilate and review your responses. Your response may be used by me in whole or in part as written evidence before or after the evidence session and to inform my oral evidence to the committee. Failure to provide answers to these questions in a timely manner could be construed as lack of cooperation with a parliamentary enquiry. Failure to provide full and truthful answers could be regarded as a serious matter by parliament.

Below I reproduce the full government response to my e-petition which can still be seen on the petitions website, and then below that I ask a series of general questions and then specific questions about the contents of each paragraph of the government response.

 

The government response:

‘Defra is working with key interested parties to ensure the sustainable management of uplands, balancing environmental and economic benefits, which includes the role of sustainable grouse shooting.

When carried out according to the law, grouse shooting 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 any lawful activities. However, all those involved are encouraged to follow best practice.

A report by the UK shooting community (Public & Corporate Economic Consultants report 2014: The Value of Shooting) concludes that the overall environmental and economic impact of game bird shooting is positive, and industry has estimated that £250 million per year is spent on management activities substantially benefiting conservation. For grouse shooting in particular, according to the Moorland Association, estates in England and Wales spend £52.5 million each year on managing 175 grouse moors. The industry also supports 1,520 full time equivalent jobs and is worth £67.7 million in England and Wales.

Grouse shooting takes place in upland areas, which 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. The Government is committed to helping create a more sustainable future for the English uplands, including by protecting peatlands through measures such as the Peatland Code.

With regard to predator control, we welcome the proactive approach taken by game keeping organisations to ensure a sustainable, mutually beneficial relationship between shooting and conservation, for example through the BASC green shoots initiative. Control of grouse predators such as foxes and stoats on shooting estates has a role to play in the recovery of rare or declining species, particularly ground nesting birds. Mountain hares and other tick carrying species such as deer are controlled to reduce disease mortality in infected red grouse chicks. We also recognize that controlling mountain hares and deer is a legitimate practice in other circumstances: for example, to protect young trees and vegetation or as quarry species.

The Wildlife and Countryside Act 1981 affords protection to all wild birds; despite this, incidents of illegal killing of birds of prey continue, so we have identified raptor persecution as a national wildlife crime priority. Each wildlife crime priority has a delivery group to consider what action should be taken, and develop a plan to prevent crime, gather intelligence on offences and enforce against it. The raptor persecution group, led by a senior police officer, focuses on the golden eagle, goshawk, hen harrier, peregrine, red kite and white tailed eagle and is led by a senior police officer.

The National Wildlife Crime Unit, which is part-funded by Defra, monitors and gathers intelligence on illegal activities affecting birds of prey and assists 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 regard to hen harriers, in January 2016 the Defra led Upland Stakeholder Forum hen harrier sub-group published the Joint action plan to increase the English hen harrier population. This sets out six complementary actions to increase hen harrier populations in England. These actions are individually beneficial, and when combined have the potential to deliver stronger outcomes and contribute to the recovery of the hen harrier population in England. These are:

1: Monitoring of populations in England and UK

2: Diversionary feeding

3: Work with Raptor Persecution Priority Delivery Group (RPPDG) to analyse monitoring information and build intelligence picture

4: Nest and winter roost protection

5: Southern reintroduction

6: Trialling a Brood Management Scheme

The Action Plan sets out who leads on each action and the timescale and benefits of each. The plan was developed with senior representatives from organisations best placed to take action, including Natural England, the Moorland Association, the National Gamekeepers’ Organisation, the Game & Wildlife Conservation Trust, National Parks England and the RSPB. These organisations will now take the plan forward led by Natural England. They will monitor all the activities carried out and report annually on progress to the Defra Uplands Stakeholder Forum and the UK Tasking and Co-ordinating group for Wildlife Crime.

Department for Environment, Food and Rural Affairs’

 

My questions:

Q1: Was this government response signed off by a Defra minister?

Q2: Was this government response signed off by Rory Stewart MP?

Q3: Given the passage of time since this government response was produced, would Defra respond in precisely the same manner today and are there any gaps or errors which Defra would, today, like to rectify? Or does Defra stand by this response as a full and accurate response to the e-petition.

 

‘Defra is working with key interested parties to ensure the sustainable management of uplands, balancing environmental and economic benefits, which includes the role of sustainable grouse shooting.’

Q4: What does Defra understand by ‘the sustainable management of uplands’?

Q5: How would Defra and the general public recognise ‘sustainable grouse shooting’ if they saw it?

Q6: Does Defra regard the current state of grouse moor management in England as representing a good example of ‘sustainable upland management’? Please explain and justify your view.

Q7: Does Defra accept, because in its response it did not say, that working towards ‘sustainable management of uplands’ requires an assessment of environmental and economic costs as well as benefits?

Q8: My reading of the government response is that it enumerates some economic and environmental benefits, rather uncritically in my opinion, but fails to mention many of the economic and environmental costs of the system. Would Defra agree that its response was extremely partial in setting out what is in effect the grouse shooting industry’s side of the case?

‘When carried out according to the law, grouse shooting 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 any lawful activities. However, all those involved are encouraged to follow best practice.’

Q9: Does Defra believe that if all illegal bird of prey persecution ceased then driven grouse shooting would be able to continue at current levels in the English uplands? Your response to this question will need to take fully into account the results of the Langholm study (Redpath, S. M. and Thirgood, S. J. 1997. Birds of Prey and Red Grouse. Centre for Ecology and Hydrology, London.). If Langholm is a more or less representative grouse moor which shows the impact of illegal persecution on protected birds of prey, and the impacts of birds of prey on grouse populations (very small) and grouse shooting (very large) then if the results from Langholm were played out across the English uplands it is my contention that driven grouse shooting would be economically unviable in most of the English uplands. Another way of putting this is that driven grouse shooting is an industry which depends on wildlife crime and cannot exist in its current form if raptor persecution ceased.

‘A report by the UK shooting community (Public & Corporate Economic Consultants report 2014: The Value of Shooting) concludes that the overall environmental and economic impact of game bird shooting is positive, and industry has estimated that £250 million per year is spent on management activities substantially benefiting conservation. For grouse shooting in particular, according to the Moorland Association, estates in England and Wales spend £52.5 million each year on managing 175 grouse moors. The industry also supports 1,520 full time equivalent jobs and is worth £67.7 million in England and Wales. ‘

Q10: Defra quotes a report by the game shooting industry on the overall impact of that industry but this e-petition is solely about driven grouse shooting – does Defra believe that the overall environmental and economic impact of driven grouse shooting is positive? If yes, what is the evidence for that? If not, why did Defra quote this report in this misleading way? And if not, what is the overall environmental and economic cost of driven grouse shooting?

Q11: Does Defra employ a team of economists?

Q12: Were Defra economists asked to evaluate the game shooting industry’s PACEC report (PACEC (2014) The Value of Shooting. The economic, environmental and social benefits of shooting sports in the UK. PACEC, Cambridge, UK.)? If not, why not?

Q13: Is Defra aware of the criticisms by academic economists that have been levelled at the specific industry report that Defra quotes in its response (Cormack & Rotherham (2014) A review of the PACEC reports (2006 & 2014) estimating net economic benefits from shooting sports in the UK.)? If yes, why were these criticisms apparently ignored in Defra’s response? If not, why not? And would Defra like to clarify its view (not the industry’s view) on economic impacts of driven grouse shooting?

Q14: Would Defra agree that a full economic assessment of driven grouse shooting would need to take account of costs to society as well as benefits to individuals?

Q15: Would Defra agree that a proper economic evaluation of driven grouse shooting would include the loss of wildlife experiences for the public, the loss of commercial value to the tourism industry of that wildlife value, any increased risk of flooding due to moorland management, any loss of or damage to protected habitats caused by inappropriate moorland management, any increased water treatment costs caused by moorland management, any increase in greenhouse gas emissions caused by moorland management, any loss of fish stocks caused by moorland management and probably a range of other costs?

Q16: Has Defra evaluated the tourism benefit to English National Parks if Golden Eagles, Hen Harriers and other raptors were present in natural numbers? The RSPB has some pretty impressive data on this matter for the Loch Garten Ospreys, White-tailed Eagles on Mull etc etc.

‘Grouse shooting takes place in upland areas, which 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. The Government is committed to helping create a more sustainable future for the English uplands, including by protecting peatlands through measures such as the Peatland Code.‘

Q17: I’m glad that Defra is aware of the ecosystem services approach but this paragraph ignores, rather spectacularly, the evidence from studies which show that the management of moorland for driven grouse shooting imposes costs in these areas on society as a whole. Does Defra agree that these costs must be taken into account to undertake a proper assessment of the economic contribution of driven grouse shooting to society as a whole and to arrive at a nett value?

Q18: Is Defra aware of the EMBER study (Brown L.E., Holden J. and Palmer S.M. (2014) Effects of moorland burning on the ecohydrology of river basins. Key findings from the EMBER project. University of Leeds.)?

Q19: Is Defra aware of this follow up to the EMBER report (Holden, J., S. M. Palmer, K. Johnston, C. Wearing, B. Irvine, and L. E. Brown (2015), Impact of prescribed burning on blanket peat hydrology, Water Resour. Res., 51, 6472–6484, doi:10.1002/2014WR016782.)?

Q20: Is Defra aware of the 2015 report by the Committee on Climate Change which stated ‘The damaging practice of burning peat to increase grouse yields continues, including on internationally protected sites’. https://www.theccc.org.uk/wp-content/uploads/2015/06/6.738_CCC_ExecSummary_2015_FINAL_WEB_250615.pdf

Q21: Is Defra aware of this scientific paper which documents the increasing intensity of moorland management for driven grouse shooting (David J.T. Douglas, Graeme M. Buchanan, Patrick Thompson, Arjun Amar, Debbie A. Fielding, Steve M. Redpath and Jeremy D. Wilson (in press) Vegetation burning for game management in the UK uplands is increasing and overlaps spatially with soil carbon and protected areas. Biological Conservation, 191, 243-250.)?

Q22: Is Defra aware of this report which documents the increasing intensity of moorland management for driven grouse shooting (Burning in the English Uplands – A Review, Reconciliation and Comparison of Results of Natural England’s Burn Monitoring: 2005 – 2014 www.gov.uk/government/publications/improvement-programme-for-englands-natura-2000-sites-ipens )?

Q23: Has Defra taken into account any estimates of increased flood risk, increased flood damage, increased home insurance costs, increased water treatment costs, increased greenhouse gas emissions, damage to protected habitats, loss of popular and iconic wildlife, reduced aquatic biodiversity and reduced fish stocks to evaluate the nett economic contribution of driven grouse shooting to society?

Q24: Does Defra believe, and can it prove, that there is a nett economic benefit of the activity of driven grouse shooting to society as a whole once the benefits are properly enumerated and the externalities and costs are fully taken into account?

Q25: Does Defra have an estimate of the economic cost or benefit of driven grouse shooting to the economy? If so, what is it?

Q26: Would Defra accept that if driven grouse shooting depends on wildlife crime then it is not justifiable, whatever any economic benefits might be?

‘With regard to predator control, we welcome the proactive approach taken by game keeping organisations to ensure a sustainable, mutually beneficial relationship between shooting and conservation, for example through the BASC green shoots initiative. Control of grouse predators such as foxes and stoats on shooting estates has a role to play in the recovery of rare or declining species, particularly ground nesting birds. Mountain hares and other tick carrying species such as deer are controlled to reduce disease mortality in infected red grouse chicks. We also recognize that controlling mountain hares and deer is a legitimate practice in other circumstances: for example, to protect young trees and vegetation or as quarry species.’

Q27: Does Defra accept that legal predator control is a management practice carried out in a targeted rather than a blanket way by organisations such as the National Trust, the Wildlife Trusts, the RSPB and others, and can, and is, carried out without other aspects of intensive moorland management that accompany driven grouse shooting?

‘The Wildlife and Countryside Act 1981 affords protection to all wild birds; despite this, incidents of illegal killing of birds of prey continue, so we have identified raptor persecution as a national wildlife crime priority. Each wildlife crime priority has a delivery group to consider what action should be taken, and develop a plan to prevent crime, gather intelligence on offences and enforce against it. The raptor persecution group, led by a senior police officer, focuses on the golden eagle, goshawk, hen harrier, peregrine, red kite and white tailed eagle and is led by a senior police officer.

The National Wildlife Crime Unit, which is part-funded by Defra, monitors and gathers intelligence on illegal activities affecting birds of prey and assists 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.’

Q28: How would Defra describe the overall picture on wildlife crime directed at birds of prey in the uplands of England?

Q29: Is Defra aware of the Hen Harrier Conservation Framework report which sets out the status and potential status of the Hen Harrier in different parts of the UK (JNCC Report No: 441 A Conservation Framework for Hen Harriers in the United Kingdom. Alan Fielding, Paul Haworth, Phil Whitfield, David McLeod and Helen Riley. February 2011)?

Q30: Does Defra accept that statutory agency peer-reviewed report as being more or less correct?

Q31: Given that that report predicts that there is sufficient suitable habitat to support over 300 pairs of Hen Harrier nesting in England does Defra regard this year’s 3 pairs as satisfactory?

Q32: Which English SPAs had nesting Hen Harriers as part of their reason for qualifying for notification as SPAs? What were their Hen Harrier populations in those years? What are their nesting Hen Harrier populations now?

Q33: Is Defra aware of the scientific paper which documents high rates of nest failure and absence from traditional sites of Peregrine Falcons in upland areas of England, many of them National Parks, associated with driven grouse moors (Amar, A., Court, I. R., Davison, M. et al. 2012. Linking nest histories, remotely sensed land use data and wildlife crime records to explore the impact of grouse moor management on peregrine falcon populations. Biological Conservation 145, 86–94.)?

Q34: Is Defra aware of the failure of the Peak District Bird of Prey initiative to meet its targets for recovery of bird of prey populations in the moorland areas of the Peak District National Park?

Q35: Is Defra aware of the numerous cases of Red Kites being poisoned or shot in upland areas of northern England this year?

Q36: Is Defra aware of the case on the Mossdale Estate near Hawes in Yorkshire this spring when three illegal pole traps were set by a gamekeeper who was an employee of the estate?

Q37: Is Defra confident that the current enforcement approach will dramatically reduce wildlife crime directed against birds of prey in the uplands of England in the next five years? And if so, why hasn’t the same approach done so in the last five years?

‘With regard to hen harriers, in January 2016 the Defra led Upland Stakeholder Forum hen harrier sub-group published the Joint action plan to increase the English hen harrier population. This sets out six complementary actions to increase hen harrier populations in England. These actions are individually beneficial, and when combined have the potential to deliver stronger outcomes and contribute to the recovery of the hen harrier population in England. These are:

1: Monitoring of populations in England and UK

2: Diversionary feeding

3: Work with Raptor Persecution Priority Delivery Group (RPPDG) to analyse monitoring information and build intelligence picture

4: Nest and winter roost protection

5: Southern reintroduction

6: Trialling a Brood Management Scheme

The Action Plan sets out who leads on each action and the timescale and benefits of each. The plan was developed with senior representatives from organisations best placed to take action, including Natural England, the Moorland Association, the National Gamekeepers’ Organisation, the Game & Wildlife Conservation Trust, National Parks England and the RSPB. These organisations will now take the plan forward led by Natural England. They will monitor all the activities carried out and report annually on progress to the Defra Uplands Stakeholder Forum and the UK Tasking and Co-ordinating group for Wildlife Crime.’

Q38: the Hen Harrier plan is supposed to be a plan for Hen Harriers – what impact would the successful implementation of this plan have on other birds of prey which are illegally killed in the English uplands such as Peregrine Falcons, Red Kites, Goshawks, Buzzards and Short-eared Owls? Does Defra have a plan for those species?

Q39: How much extra money has Defra allocated to each of the 6 action points in the plan since its publication?

Q40: How many pairs of Hen Harrier in England have been fed through diversionary feeding in the last 20 years since this technique was trialled at Langholm – please give the numbers for driven grouse moors and other areas separately?

Q41: What size of population of nesting Hen Harriers (in England) would represent favourable conservation status?

Q42: What level of Hen Harrier breeding success (in England) would represent favourable conservation status?

Q43: In what year, if the Defra plan is fully implemented, would Defra expect the English nesting Hen Harrier population to reach favourable conservation status?

Q44: Does Defra have any estimate of the number of illegal pole traps and/or poisoned baits which are set in the English uplands each year? Does Defra have any useful estimate of the scale of the problem that law enforcement agencies are trying to tackle? Does Defra have any estimate of how much resource would be necessary to tackle the scale of this illegal activity? Does Defra have any confidence that the resources being deployed are sufficient to tackle the issue of bird of prey persecution?

 

 

Q45: Is Defra considering introducing vicarious liability for wildlife crimes into English law?

Q46: Is Defra considering introducing licensing of upland game shooting estates in England?

Q47: Is Defra considering providing any extra resources and taking any new approaches to dealing with wildlife crime and unsustainable management of driven grouse moors?

Q48: Has Defra considered the possibility of banning driven grouse shooting in England as a result of over 120,000 citizens (most of them apparently from rural areas, many of which are grouse shooting areas) asking for that to happen?

 

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