On Dec 5th we blogged about the changes being brought in by SNH to the 2013 General Licences following a period of public consultation (see here).
We suggested that it looked like SNH had listened to the recommendations made by the game-shooting lobby and had ignored those made by the pro-raptor groups. This was pure speculation because at that time SNH hadn’t actually published the responses they’d received during the consultation. We (and many of you) asked for them to be published. They did so on 21st December. Click here to read them.
Having now had the chance to review all these responses in detail, we believe that SNH has indeed favoured the recommendations made to them by the game-shooting lobby and ignored the recommendations made by the pro-raptor groups. But on a much more serious level, we now also believe that SNH’s decision to approve the use of clam traps in the 2013 General Licences before conducting an independent assessment of their suitability is based on a flawed interpretation of the responses.
In the letter sent by SNH to the consultees, dated 4th December (see here), SNH wrote this:
“On the basis of the feedback received we have made a number of decisions for changes for 2013”.
One of these changes was this:
“Traps permitted under General Licences 1-4 will be clarified, including authorisation to use ‘clam’-type traps”.
Later in the same letter they further explained this change:
“In the consultation we asked whether there was a need to clarify the traps that are permitted for use under the General Licences. Our proposal was to provide further clarification and to specifically permit the use of ‘clam’-type traps. These traps have been available and used for a number of years but whether or not their use is covered by the General Licences has been debated due to unclear trap definitions in the General Licences to date.
Whilst the majority of consultees supported the proposed amendments, concerns were expressed by a number of respondents over potential welfare implications of these traps and how they could be used to trap non-target species”.
So, in this letter, SNH told us that the “majority of consultees supported the proposed amendments” [to explicitly authorise the use of clam-type traps before conducting an independent assessment of their suitability] and that SNH’s decision to authorise their use was based on “the feedback received”. According to our analyses of the responses, this is blatantly untrue on both counts.
We divided the respondents into four groups:
(1) Those who explicitly supported the use of clam-type traps prior to an independent assessment of their suitability;
(2) Those who didn’t expressly mention clam-type traps in their response;
(3) Those who did specifically mention clam-type traps but were unclear about whether they supported use prior to independent assessment; and
(4) Those who explicitly did not support the use of clam-type traps prior to an independent assessment of their suitability.
In group (1) –
Scottish Countryside Alliance, Scottish Association for Country Sports, Scottish Gamekeepers’ Association, Scottish Land & Estates Moorland Group, Game & Wildlife Conservation Trust, British Association for Shooting and Conservation.
TOTAL: 6
In group (2) –
National Farmers Union Scotland, Scotland for Animals, Animal Concern Advice Line, Scottish Tree Trust, Individual B, Grampian Wildlife Crime Unit, Grampian Police, Glasgow City Council, Individual C, University of Stirling.
TOTAL: 10
In group (3) –
National Wildlife Crime Unit
TOTAL: 1
In group (4) –
OneKind, RSPB, Scottish Raptor Study Groups, SSPCA, Against Corvid Traps, Kindrogan Field Centre (Field Studies Council), Individual A, Individual D, Individual E, Individual F, Individual G, Individual H, Individual I.
TOTAL: 13
For the purposes of this analysis, groups (2) and (3) can be discounted. That leaves us with groups (1) and (4).
It is clear that the number of respondents in group (4), i.e. those opposing the use of clam-type traps prior to independent testing, is more than double those in group (1). Thirteen respondents were against the use of clam-type traps; only six were supportive.
So how on earth can SNH justify their decision, “based on feedback received”, to authorise the use of these traps prior to independent testing? At best this appears to be incompetence; at worst, corruption.
This is a serious issue. Has SNH intentionally misled the public to believe that the majority of respondents supported the use of clam traps prior to independent testing? Why hasn’t SNH heeded the majority of the responses, which clearly stated their opposition to the use of clam-type traps prior to independent assessment?
We demand an immediate review of this consultation process and we urge you to seek the same. In the first instance, we suggest you contact SNH Chief Executive Dr Ian Jardine: ian.jardine@snh.gov.uk
If you don’t know how to phrase your complaint, you could simply cut and paste from this blog or provide a URL to this posting.
SNH have a duty to respond to emails within 20 working days. If Dr Jardine’s response is unsatisfactory, then we have the right to ask the Scottish Public Services Ombudsman to investigate the complaint.
Raptor Persecution UK 
I would say it’s very unlikely it was due to incompetence, more like a deliberately planned act of corruption at the highest levels. DEFRA, NE and SNH are not fit for purpose and should be shown up for what they really are, highly paid lackies for the shooting estates and the government, (or is that one and the same thing ?).
SNH are not independant, they are a mouthpeice of government. They are doing what ministers want them to do and are applying slimy political spin to make it look credible. Jardine will respond with spin. We need some campaigning MSP’s who are willing to ask the correct questions in Holyrood.
Dr Jardine may well reply with spin, but he may not. Either way, we should allow SNH the opportunity to respond before any further steps are taken.
As you’re aware, there have already been some (very good) questions asked in Parliament about the use of clam traps: https://raptorpersecutionscotland.wordpress.com/2012/12/12/parliamentary-questions-asked-about-snhs-decision-on-clam-traps/
However, the point we’re trying to make here is not the use of clam traps per se (although we strongly oppose their use prior to independent testing), but rather the process that was used during this particular consultation.
We believe that SNH has missed out a key stage of this consultation: that is, a detailed analysis of the responses received during the consultation. A good consultation should respond to each and every point raised by each respondee. These should be summarised and then used to formulate a decision. Looking at SNH’s decision to authorise clam traps prior to independent testing, and comparing this decision to the responses they received during the consultation, we would argue that their decision is unjustified.
Of course, we may have misinterpreted the process used, hence why we’re asking SNH to conduct a formal review.
Dear Raptor Scotland
Thanks for your post; it is increasingly clear that SNH has no interest in conservation; I’ve come up against them on a local, highly-dubious scheme to eradicate roe deer and turn a biodiverse meadow into a forest (except the soil and other factors mean the trees won’t grow, something they already knew).
I’ll be writing a round-up of SNH blunders and dodgy dealings. I’ve satirical column out today pointing out some of SNH’s Aberdeen city and shire failures; if it is of any passing interest it can be found at http://aberdeenvoice.com/2013/01/old-susannah-no-107-natural-heritage-101/ , where there is also an article on the Forestry Commission and Ash disease.
I will look at your website for any past SNH articles. If there are any items critical of the SNH you can point out to me, I would be most grateful, whether these are related to raptors or other factors, whether on your website or not.
Yours sincerely
Suzanne Kelly
How can you simply add up the number of responses to the consultation and do a simple comparison of the numbers for and against use of clam traps? Clearly more weight should be given to a response from an organisation than to a response from an individual? And organisations vary in the numbers of individuals that they can claim to represent.
Would you mind awfully recalculating using the number of individuals represented by each response? Let’s see if the total represented by Scottish Countryside Alliance, Scottish Association for Country Sports, Scottish Gamekeepers’ Association, Scottish Land & Estates Moorland Group, Game & Wildlife Conservation Trust, British Association for Shooting and Conservation ‘beats’ the number represented by OneKind, RSPB, Scottish Raptor Study Groups, SSPCA, Against Corvid Traps, Kindrogan Field Centre (Field Studies Council), Individual A, Individual D, Individual E, Individual F, Individual G, Individual H, Individual I.
Hang on – perhaps better not do that…. it’s a bit one sided? RSPB’s weight alone? Perhaps your simple approach is fairer to SNH afterall.
An alternative method could be for more weight to be given to respondees who wear tweed. Oh, hang on…
Now, I knew SNH were a bit dodgy at times, but this is really taking the piss. I’ve mentioned their pathetic calculations on avian species on a local SSSI (40 or so species short of the actual figure), which is evident that their desk studies are woefully inadequate. They also (deliberately?) miscalculated the breeding, passage and wintering species for this site. Or was the SNH subterfuge a deliberate attempt to rid the Portencross Coast SSSI of its status, thereby enabling the Scottish government to push through their plans for a coal-fired power station?
Perhaps it was the same team that carried out the calculations for this consultation.
And again, was this the Scottish government and the court system pandering to the rich and wealthy, rather than listening to the majority of ordinary citizens?
I await a reply to my email to Dr Jardine.
Has anyone read the 2013 General Licence? ,oh I forgot you dont need to. Condition 1 no longer requires a person to have read the licence!!
Not only have SNH approved the Larson mate or clam trap but they have also included another trap ..the Larson pod. Where did this trap appear from?
Is there a need for TWO new traps, I have heard no evidence that the Larson trap has become less effective. Why are SNH permitting the use of two new traps against the backdrop of raptor persecution?
SNH may claim that if these traps are used properly (as per the general licence) that they will present no risk to raptors and this may well be the case however it is when a person chooses to use them for an illegal purpose in particular trapping raptors that presents a serious problem. If the operator claims his intentions are to catch crows then it will extremely unlikely that this can be disproved.
Even if the operator was filmed catching and killing raptors in these traps it is very likely that this evidence would not be used and deemed to be inadmissible.
Traps will be undoubtedly be used 365 days of the year and not at key times when crows cause damage to the eggs of ground nesting birds, traps will be located where they don’t catch crows but are likely to catch raptors, traps wont be checked and nothing can be done by any of the authorities.
Lets not forget the Larson trap was trialled over FIVE years before approval.
Sadly we are left with a situation where these traps now being legal and will undoubtedly be used to seriously effect raptor population levels in particular goshawk.
SNH have shown their true colours and I fear that now they are responsible for the general licence things will only get worse.
It really is an astoninshing deceision given the appalling levels of illegal raptor persecution across Scotland. The recent outcry over the incident involving the trapped Golden Eagle left to die in agony with its legs broken by a similiar trap obviously escaped the attention of these people. A disgusting state of affairs that should in my opinion be brought to the attention of the EU authorities as it clearly makes a mockery of the Birds directive.I would also like to know the neccessity for such traps given the effectivness of existing Larson and Ladder traps for the control of magpie and crows.
Quote:
“I would also like to know the neccessity for such traps given the effectivness of existing Larson and Ladder traps for the control of magpie and crows.”
Clam traps are easier to set and bait and more efficient at catching Raptors than larson traps.