RSPB Scotland has expressed concern at Scottish Natural Heritage's response to their recent consultation on the 'general licences' that permit the killing of some species of protected birds under certain circumstances. We do not believe that this approach will contribute to wider and helpful Scottish Government efforts to tackle wildlife crimes against birds of prey.
General licences are issued annually to allow land managers (and certain others) to kill a range of protected species such as some species of gulls, magpies and crows in situations where they are causing serious damage to crops or livestock; are a threat to public health or safety; or to the conservation of wild birds. These licences effectively allow unrestricted and un-monitored killing of listed species.
Although the licences permit some actions that are justified and necessary, RSPB Scotland has demonstrated over many years that this system can be used as 'cover' for the criminal destruction of birds of prey, particularly through the abuse of cage traps. Over a long period of time we have suggested that the use of cage traps should be restricted seasonally to target the right species, and that these traps should not be placed in woodland or on the open hill where the risk of bird of prey by-catch is highest. We have submitted detailed evidence to SNH to support this advice.
There are many flaws with the newly proposed licences but several provisions cause us real concern.
One decision has made the illegal killing of birds of prey even easier. A few years ago the, the use of meat baits in certain cage traps was banned because this encouraged birds of prey to enter the traps. SNH then commissioned research (i) that clearly confirmed this. Despite this, SNH have now said they will allow meat baits again, presumably in the full knowledge that birds of prey will certainly become trapped.
RSPB Scotland's Head of Investigations, Ian Thomson, said: "The SNH proposals are very poor and represent yet another missed opportunity to tighten up the regulation of bird trapping in Scotland. While we recognise that legal control of some bird species such as crows can have positive conservation benefits for wading birds, red grouse and some other ground nesting birds, the suite of licences that SNH propose to publish for 2017 provides no framework for improved monitoring or enforcement, and simply maintains a system that is mostly unaccountable.
"Despite SNH's own field trials demonstrating increased likelihood of catching protected birds of prey when using meat baits, these are now to be permitted again. These licences also have, as yet, no improved mechanism for registration of trap operators, and provide no idea about how much trapping is going on, or its impact."
RSPB Scotland is also concerned that far too wide a range of bird species are allowed to be trapped without any evidential justification. There is, for instance, no published evidence that rooks pose a threat to the conservation status of other wild birds. Despite this, they remain on the licence for bird conservation even though their own population in Scotland has been in long term decline (ii).
Ian Thomson said, "It is inexcusable that a rational review by SNH of species that can be killed has not occurred, meaning that a species like the rook, which can actually benefit farmers through eating pest insect species, and has undergone a significant population decline, is still allowed to be routinely killed" .
"Also, given that a significant proportion of trapping and killing of crows is undertaken on land managed intensively for game shooting, the suspicion remains that the general licence is used not for wild bird conservation, but in order to produce unnaturally high densities of gamebirds for shooting. This would be an illegal use of the general licence but we have seen no evidence that SNH wish to investigate this issue."
i SNH Commissioned Report 931: Assessing the nature and use of corvid cage traps in Scotland: Part 1 of 4 - Questionnaire survey of corvid trap users in Scotland - see http://www.snh.gov.uk/publications-data-and-research/publications/search-the-catalogue/publication-detail/?id=2436
ii Information on the population trend for rooks can be found on the BTO's website here: https://www.bto.org/volunteer-surveys/bbs/latest-results/trend-graphs#rook
Notes to editors:
1. RSPB Scotland has compiled a video on the abuse and misuse of crow traps in Scotland which can be seen here: https://vimeo.com/196554563