Negative impacts of grouse moor management: 86 respondents or 40% of all respondents made
comments about the negative impacts of grouse moor management. These included the intensity of heather burning and the alleged persecution of birds of prey.
Focus on statutory purposes: 60 respondents or 28% of all respondents made comments about
focusing on statutory purposes. These comments generally made reference to the first statutory
purpose to conserve and enhance natural beauty, wildlife and cultural heritage. The emphasis was towards landscapes and wildlife with reference to this taking precedence over other initiatives where there was conflict between them.
Promote a more natural landscape: 33 respondents or 15% of all respondents mentioned things
like high nature value farming, rewilding, species re-introduction, enabling natural succession
and native woodland afforestation. These comments generally aspired to a less intensively management landscape with greater emphasis on nature conservation.
Wildlife crime: 29 respondents or 13% of all respondents made comments about greater focus on tackling wildlife crime.
Here is another passage:
‘Poor condition of special quality 2, internationally important and locally distinctive habitats and species: The description of this special quality in particular was identified as being aspirational rather than accurate. The descriptive prose regarding the potential to see a hen harrier was challenged as these birds have only bred twice in the Peak District National Park since 2006.
Respondents who commented on this theme also alleged wildlife crime was rife within the National Park with birds of prey and mountain hares in particular sighted [and presumably ‘cited’!] as falling victim to management activities undertaken on grouse moors. Going further one respondent suggested; “One of the problems with designated upland landscapes…..is that hills and mountains are “pretty”because of their shape alone, but their beauty is at best skin deep……Impoverished wildlife and damaged soils are the most striking characteristic of tens of thousands of hectares of the PDNP landscape.”
Other comments questioned the ecological integrity of the National Park and suggested that there is an opportunity, when discussing the special qualities, to stress the connectedness between beautiful views, biodiversity, tranquillity and wildness. As one respondent noted:
“Landscape is not just about the view but the habitats and species that make it up. A superficially attractive view of green fields can be a relative desert for wildlife”.’
‘Focus on implementing the statutory purposes of National Parks:Both those who agreed and disagreed with this area of impact stressed that it should be viewed through the context of the Environment Act 1995 which clearly states that if there is any conflict between the two statutory purposes of national parks then greater weight shall be given to preserving their natural beauty, wildlife and cultural heritage.’
‘Anti-grouse moor management: Of concern to many were the alleged activities that take place on moors managed for driven grouse shooting. These included alleged persecution of raptors and mountain hares, the use of medicated grit and the use of snares to control predators. It was stated that knowledge of these activities taking place within the Peak District National Park created a mental barrier which prevented people from visiting. Some responses commented that grouse moor management is not compatible with achieving a national park for everyone as it is focussed on providing sporting opportunities for an elite few. It was also suggested that this type of land management was not sustainable as it contributed to downstream flooding, poor biodiversity and prevented access during the shooting season. It was suggested that abandoning this type of land management in favour of enabling more natural processes to take place would do more to create a national park for everyone and be more consistent with working towards the National Park’s statutory purposes. It should be noted that pro-grouse moor comments were put forward but not within this area of impact.’
‘Is the word “balance” appropriate? : Some respondents questioned the use of the word balance as they believed this suggested that at times there may need to be a compromise taken between delivering the two statutory purposes of National Parks even though legislation dictates that purpose one always takes priority where there is conflict.’
‘Grouse moor management contributions to climate change: Contradictory submissions were received in relation to the contribution grouse moor management makes to climate change. Practises such as burning heather, track cutting and over grazing were all cited as ones that contributed to climate change through releasing of carbon and increasing run-off. On the other hand it was suggested rapidly growing young heather following a prescribed burn sequesters more carbon than that lost during the burning and more than is sequestered by older heather.
Promote more tree planting: Pro-afforestation comments were common in this section. A number of benefits were cited that could be gained by adopting such a policy. These included; greater biodiversity, contribution to natural flood management, carbon sequestration, increased wildlife corridors and as a positive change to current land management practises that leave the landscape “bare”.’
And yet another:
‘Grouse moor management and delivery of public goods: Closely linked to the above theme was the concern that grouse moor management objectives are not consistent with the ambitions of this Area of Impact. Burning of heather and illegal persecution of wildlife were cited as unsustainable land management practises within this topic. A small number of organisations responded that the delivery of ecosystem services provided by grouse moor management should be better communicated to the public. There was a clear divide within this topic and in some cases contradictory evidence was cited. Many felt that this subject should be addressed within the NPMP and that it was deliberately overlooked to avoid controversy. For example, one respondent wrote: “Your suggested options are not really much in your gift. And the elephant stomping around your room is ‘which land management do we want in the PDNP?’ You may have picked up from my comments by now that I would like to see an end to intensive grouse moor management in the PDNP. Your consultation avoids this issue and appears happy with the status quo – I believe this is a big mistake and represents a failure to address properly your major responsibility to ‘to conserve and enhance the natural beauty, wildlife and cultural heritage’.” ‘
‘The impact of controlled burning: There was a concern by a number of respondents that controlled burning of grouse moors had a negative impact on wildlife and ecosystem services provided by the moorlands. It was felt more needed to be done to address this issue.’
And the antepenultimate:
‘Rewilding: There was a high level of support for a range of rewilding approaches including High Nature Value Farming, increasing woodland cover, species reintroduction and passive land management, especially of the moorlands. Many questioned the viability of encouraging upland management and suggested that alternative ideas should be explored further.’
And the penultimate:
‘Clear measurement of conservation objectives required: Many felt that there was a need to create clear monitoring framework that reports honestly on the status of the biodiversity of the Peak District. A number of respondents referred to the need to build on the work carried out on the State of Nature Report in 2016.
Targets not met by Birds of Prey Initiative: Linked to the above point was the fact that the Birds of Prey Initiative did not achieve its targets in restoring raptor populations. Wildlife crime was again a key theme that emerged from comments in this section.It was felt that the NPMP should play an important role in holding this initiative to account for its targets on numbers of birds of prey and more needed to be done to address wildlife crime.’
‘Better enforcement of wildlife protection legislation: During the consultation period a video and report was released by the Hunt Investigation Team (HIT) which was alleged to show the methods used to control pests on a local estate as part of their grouse moor management practises. The report and footage showed distressing scenes of snared animals and highlighted that of those animals caught within them only 29% were target species. These reported activities were referenced by many respondents who called for better enforcement of existing wildlife and environmental protection legislation. In particular respondents wanted better protection for birds of prey and mountain hares, species that should be synonymous with moorland habitats but are currently heavily under represented. Respondents making these comments firmly believed that management practises on grouse moors are contributing to this under representation.
Representative organisations of grouse moor owners in their responses condemned any illegal persecution of protected species, promoted the management of grouse moors in line with best practise guidelines and confirmed their willingness to work towards increasing bird of prey numbers.
Benefits of grouse moor management: One respondent noted that approximately 26% of the Peak District National Park is managed heather moorland for the purpose of driven grouse shooting with 75% of that land being designated as SSSI, SAC or SPA. It was further noted that the park itself was designated in 1951 because of: “the historic land management (driven grouse shooting and agriculture) and land managers should be encouraged, recognised and supported by the (Peak District National) Park Authority for maintaining this.” Respondents noted that today’s grouse moors make valuable contributions to conservation through habitat management and predator control, to peatland restoration through grip and gully blocking, to local economies through expenditure with local business and creating employment.’
Dr Coffey, your department is the sponsoring department for National Parks and you could probably take these comments as being indicative of the responses that would come from similar exercises if they were carried out in other National Parks, most notably the Yorkshire Dales and North York Moors and AONBs, most notably Nidderdale, Forest of Bowland and North Pennines.
There is a conflict in the uplands which is most sharply focussed in National Parks and AONBs between what some stakeholders (aka vested interests) want and what the public and local residents want. Defra, so far, has sided firmly with the vested interests of intensive grouse shooting which looks very much like keeping in with your mates in the shooting industry. By appearing completely deaf to the concerns of the electorate and ‘ordinary’ people you are simply stoking up trouble in the future. That’s what your ministerial predecessors have done and why the focus is now so clearly on you and your response to Gavin Gamble’s e-petition.
The PDNP is to be congratulated on carrying out a consultation that elicited such a strong, well-argued and cogent overall response. Responding to these concerns falls as much at Defra’s, and your feet Dr Coffey, as it does to the National Park. You’ve been keeping Gavin Gamble waiting for almost three weeks – and almost each day that passes provides more reason for you to move against wildlife crime and unsustainable grouse moor management. In the new green Defra of Michael Gove you should feel blessed that this opportunity to move the government’s position forward into this century falls to you. We’re waiting to see whether or not you take it.
be published within 2 weeks of Gavin Gamble’s e-petition reaching 10,000 signatures – FAIL
announce that vicarious liability for wildlife crimes will be introduced in England because of the unacceptably high levels of wildlife crime
announce that Defra will ask the RSPB to come forward with proposals for licensing of shooting estates within a month and that Defra will respond to them by Christmas
acknowledge the level of concern about driven grouse shooting which led to 123,077 signatures being gained last year for an absolute ban on this hobby (I’m not expecting Dr Coffey to say anything nicer than that about a ban)
confirm that Defra is looking at removal of farming subsidies from grouse moors in its post-Brexit agricultural strategy
confirm that the evidence for wider environmental damage of heather burning has increased recently and that this is an issue that government will address and that this will require widespread changes to grouse moor management (burning and draining)
mention where the government is with dealing with the RSPB complaint to the EU over unsustainable moorland management due to grouse shooting practices
acknowledge that the plight of the Hen Harrier has not improved in two breeding seasons since the Defra Hen Harrier plan was launched and that the grouse shooting industry has not cleaned up its act and is on a last warning
announce that the details of the 15-year Natural England Hen Harrier study will be published by Christmas 2017 in a government report with further recommendations for Hen Harrier conservation
acknowledge that wildlife crime applies to many other protected species other than the Hen Harrier
announce that the National Capital Committee has been asked to compile a report on ecosystem services and grouse moor management
announce a review of the economic costs and benefits of intensive grouse moor management will be carried out by independent academics and published by Christmas 2018.
The government response should not:
say that funding of the NWCU is a sufficient response to combatting bird of prey persecution in the uplands (because nobody who knows has ever suggested such a thing)
say or suggest that grouse shooting provides a nett economic benefit to the nation (because there are no such figures)
suggest that the current Hen Harrier Action Plan is remotely fit for purpose
conflate benefits of all shooting (economic or environmental) with benefits of grouse shooting (because it makes the government department and/or its ministers look either stupid or biased)
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