NatureScot response to RSPB on the Strathbraan licence
RSPB Scottish Headquarters
03 May 2018
Raven Research Licence, Strathbraan
Thank you for your letter dated 23 April 2018 regarding the discharge of our licencing duties at Strathbraan.
You note in your letter that there has been significant public outrage following the issue of licence to the Strathbraan Community Collaboration for Waders. I personally have received some serious and malicious communications, and this continues. I have also received a number of supportive communications from individuals and groups who expect NatureScot to do its utmost to support a species in decline. I appreciate you, and your supporters, care passionately about these matters, and this has been shown in the volume of correspondence we have received. But so do our staff.
I want to build consensus in what is the ultimate goal - to do all we can to address the on-going threat to our wading bird population. You may have seen the offer from one of the Strathbraan licensees in the media for a discussion with the RSPB on how we can all work collaboratively to improve the chances of ground nesting waders. Therefore, I would like to offer to facilitate this. I hope you will see this as a positive step in trying to find common ground.
In reference to the points in your letter, as you will be aware, the Scottish Government has delegated authority for species licencing in Scotland to NatureScot. As such we are duty bound to assess any licence application on its merits. In doing so we must consider the potential benefits of any proposal against the impacts. In this instance we have a very small impact on a species that is faring very well (on the Green list) and the opportunity to better understand some of the possible factors that are affecting species that are doing badly (on the Red list).
Curlew and lapwing populations in the UK are collapsing – populations of both have more than fallen by over 50% since the 1990s. The Strathbraan licence is for the control of 69 ravens this year from a strong population that has grown by over 40% in the same period. You will be aware that licences have been granted for many years to control ravens in Scotland to prevent serious damage to livestock and there is no indication that this is having any impact on the population of the species.
Predator control is familiar territory for your organisation. Along with a number of other public, private and community based organisations you practice predator control and in particular have published useful material which concludes that this sort of intervention can provide a valuable additional tool for conservation efforts. The assertion by RSPB in recent press coverage that possible impacts of ravens are not supported by any evidence is incorrect and misleading. There are of course multiple factors affecting populations of these species. This proposal helps us explore this issue in an adaptive and community-led way, without detriment to the wider raven population.
Our licencing team also ensure that on a case-by-case basis, this experience is incorporated into our licencing decisions, along with evidence and knowledge from other land managers. As with all other licences issued, there are strict conditions attached. This includes the means by which birds are controlled and in this instance also ensuring that all of the appropriate monitoring is taking place. NatureScot reserves the right to withdraw a licence at any time if these conditions are not met.
We have worked closely with the Strathbraan Community Collaboration for Waders and the Game and Wildlife Conservation Trust, to ensure that the aims of the licence (to maintain and/or increase existing populations of waders, to safeguard the conservation status of the raven and to gather data to enable further learning and adaptation) are delivered. It is important that we, and all stakeholders who care for the future of our ground nesting waders, are able to learn from this practical trial.
You have expressed concerns that in this case there could have been greater partnership working, showing more inclusivity and collaboration. I hope that the Working for Waders initiative will help us all to facilitate this, and move us forward in terms of action for wader conservation. This will be true on a range of fronts in future, and the data generated from this practical trial will assist in that regard. To be clear though, this application came to NatureScot almost a year in advance of Working for Waders coming into being.
We are clear that further investigation is merited. The licence application, rationale and methodologies were developed with support from GWCT scientists. It is not a traditional academic study but is designed in such a way to ensure that we can learn from the proposal. If necessary, we can then adapt our approach to maximise that learning about these species that are in such rapid decline, whilst ensuring that the wider conservation status of ravens will not be affected.
We have asked our Scientific Advisory Committee to consider how this particular case fits with the wider work on adaptive action to save waders, including the extensive review provided by Understanding Predation. We hope that this will provide additional reassurance about the contribution this project will make to the wider work in terms of the methods and monitoring proposed.
I trust that this helps to clarify our licencing functions and provide further background to this particular case. It is our assessment that these actions will have no impact on the overall population success of ravens in Scotland and they will, along with RSPB’s own respected and valued contributions to conservation, contribute to our understanding and ultimate recovery of our precious wading bird populations. I have enclosed a copy of the conditions of licence for additional information. Given the wide interest in this matter, I intend to make this letter publicly available to supplement our statement of last week.
Conditions of licence
- All activities must be carried out in accordance with those set out in the licence application and supporting document(s) and any subsequent correspondence agreed in writing with the NatureScot Licensing Team, but subject to any modifications or amendments imposed by this licence.
- While engaged in work authorised by this licence, the licence holder and agents must each be able to produce a copy of this licence to any Police Officer, authorised person, or official of NatureScot on demand.
- Multi-catch cage-traps may be used to trap ravens under this licence. Traps must be used in accordance with the methods and conditions required by NatureScot General Licence 01/2018.
- Ravens can only be shot from groups of three or more birds, and not within 500m of known nest sites. Ravens may not be shot at roost sites.
- All persons shooting or trapping ravens under this licence must report the number of birds they have killed and by what means to the licence-holder on at least a weekly basis. It is the responsibility of the licence-holder to ensure that the bag limit of this licence is not breached.
- This licence permits the use of sound recordings as a lure and of semi-automatic weapons but does not permit the use of any other firearm prohibited by section 5 of the Wildlife and Countryside Act 1981 (see note 8).
- Some shot birds may be found to bear leg-rings or other unique marks. Details of any such markings and the date and place of shooting must be reported to the British Trust for Ornithology. Instructions for doing this may be found at the British Trust for Ornithology.
- Monitoring must be carried out in accordance with the methods in the licence application and supporting information. This includes; annual coordinated non-breeding raven counts, raven breeding pair estimates (nest counts), counts from a minimum of 8 sets of wader transects and 6 Vantage Point counts for waders.
- No later than one month after the date on which this licence expires, the licence holder must provide NatureScot Licensing Team with a licence return, detailing all actions carried out under this licence. The return must include details of numbers of ravens controlled and method of control used as well as the wader and raven monitoring results.
- This licence is granted subject to compliance with the conditions as specified. Anything done otherwise than in accordance with the terms of the licence may constitute an offence.
- Agents may work independently of the licence holder. It is the responsibility of the licence holder to ensure that agents have the appropriate training and experience and that they understand the terms and conditions of this licence.
- Nothing in this licence shall confer any right of entry on to land or property.
- This licence may be modified or revoked at any time by NatureScot.
- This licence only exempts any legal provision contained in the Wildlife and Countryside Act 1981 (as amended).
- 'Multi-catch cage-trap' means a trap defined as such in NatureScot General Licences 1-3 2018.
- Methods of killing prohibited under section 5 of the Wildlife and Countryside Act 1981 include; automatic weapons and shot-guns with a barrel that has an internal diameter at the muzzle of more than one and three-quarter inches.