Archive for August, 2013


SNH put positive spin on worrying golden eagle news

eagle-poisoned2There’s a very curious news item doing the rounds this morning that seems to have originated from an SNH press release. The news is that two immature female golden eagles have attempted to breed in two different locations and that this is somehow an indication of a potential ‘upturn’ in the fortunes of the Scottish golden eagle population.

To the unassuming general public, the news that golden eagles are breeding at an earlier age than normal (3 years old instead of the usual 4-6 years) may well sound like a positive story. On a superficial level this is probably true – breeding golden eagles, at whatever age, has got to be good news, right?


According to several scientific studies, the occurrence of breeding subadult eagles should actually be used as an early-warning of potential population decline. The reason these Scottish golden eagles are attempting to breed at three years of age is because there is little or no competition for that vacant territory. Why is there little or no competition? Because one or both of the territorial adults have been killed and there are very few non-breeding adults (known as ‘floaters’) around to challenge for the territory. If the population was healthy, it would be these breeding-age floaters that would move in to the territory, not an immature three-year old bird.

An excellent study (Whitfield et al. 2004 – see below) has also demonstrated that subadult and mixed-age breeding golden eagle pairs in Scotland have lower breeding success than adult pairs – a result of inexperience and persecution, seeing as most golden eagle territories in Scotland with subadult breeders are in areas associated with illegal persecution.

Des Thompson from SNH does mention the link to persecution in this press release but he kind of glosses over this and instead suggests that these young breeders are good news. They are good news as long as they are not bumped off, and the chances of them being bumped off is quite high because, as mentioned above, these territories with immature breeders are only available because the adults have already been persecuted.

Instead of spinning this as a ‘good news story’ and ignoring the known warning signs of a population in decline, SNH should be telling us how they are going to beef up their conservation efforts at these sites and get the Scottish golden eagle population back to a favourable conservation status – as it is, it is far from that.

The news story has been reported here, here and here.

Here is a PDF of the scientific study mentioned above, entitled The Effects of Persecution on Age of Breeding and Territory Occupation in Golden Eagles in Scotland:  Effects of persecution on age GE


Not just any red grouse…part 2

m7sLast week we blogged about the news that Marks & Spencer was planning on selling red grouse at two of its flagship stores in London (see here). Naturally, given our interest in the management of grouse moors and the widespread illegal persecution of raptors that is associated with a lot of them, we wanted to know if M&S could reassure their customers that they were sourcing their red grouse from  suppliers who didn’t illegally kill wildlife to increase their grouse stock. This seemed a perfectly reasonable question, especially as we learned that the grouse moors in question included some in Yorkshire, a county with one of the worst records for raptor persecution in the whole country.

We (and many of you, thank you!) emailed Executive Director of Food at M&S, Steve Rowe, to ask him some questions.

It turned out that Mr Rowe was away until 27th August, but a response was received from Mike Rogers from the Executive Office. Here’s what he said:

Thank you for emailing Steve Rowe to share your concerns about the introduction of grouse into some of our stores. As a member of his personal team, I’m replying on his behalf.

We have the highest standards of animal welfare and only source from suppliers we know and trust. Our game range is sourced from well-managed estates across the UK stretching from Nottinghamshire to the Scottish borders, with the majority of product coming from Yorkshire and Northumberland.

Game is one of the most animal welfare friendly meats you can eat as it is totally free range – the birds live totally in the wild and in their natural habitats. It is also a very sustainable option and good estate management and conservation intended for game shooting actually stops deforestation, and encourages the protection of the countryside.

There are no breeding pairs of hen harriers on the grouse moors we take from and there are severe penalties for anyone that interferes with Hen Harriers – this is actively enforced not just for Hen Harriers but all species of raptors.

I appreciate you taking the time to get in touch with us to raise your concerns about the sale of grouse in our stores. I hope my email has helped to reassure you of how seriously we take our commitments to the environment and ethical sourcing.

Kind regards

Mike Rogers

Executive Office

Your M&S Customer Service

Clearly Mr Rogers didn’t have a scoobies what he was talking about and was just regurgitating some inaccurate and frankly absurd propaganda probably fed to him by someone with a vested interest in selling red grouse.

We wrote back to Mr Rogers, pointed out the flaws in his statement and asked again if he would please name the actual grouse moors from where the M&S red grouse were being sourced. A very reasonable question, you’d think, given M&S’s stated policies on ethical food sourcing, including their ‘Named Farmer’ scheme, designed to provide traceability to secure consumer confidence.

m&s_0This is the message that came back, this time from Stephen Duxbury in the Executive Office:

Thank you for your email. I hope you don’t mind me responding on Mike’s behalf.

I’d like to reiterate that we are working with only the most sustainable and well-managed estates, and do not work with any suppliers that interfere with Hen Harriers. We take issues regarding animal welfare very seriously, as evidenced in our Plan A programme. You can read more about our Plan A at

I’m afraid I am unable to give you specific details of our suppliers, as this is commercially sensitive information.

We are unable to comment further on this matter at this time, but I hope you will not interpret this for a lack of interest from M&S. We are closely monitoring this matter and will continue to review the situation. This will enable us to guarantee our suppliers are meeting our exacting ethical standards.

Thank you again for your email.

Kind regards
Stephen Duxbury
Executive Office

So, M&S are apparently ‘not working with any suppliers that interefere with hen harriers’. How can they be so sure? Did they have a conversation with their suppliers? Did it go something like this? –

M&S: Are you involved in the illegal persecution of hen harriers on your grouse moor?

Red grouse supplier: No.

Genius. Of course nobody in their right mind is going to admit to any involvement in any criminal activity. Did M&S do anything else to ensure that their suppliers are not engaged in the criminal persecution of wildlife? We think their customers have a right to know. We would also like to know why M&S think revealing the name of the grouse moors is too ‘commercially sensitive’ and yet with other meat products they’re prepared to name the actual farmer!

There are plenty of other questions to ask them, too. Mark Avery has a cracking blog on the M&S scandal today, with further questions about legal predator control and lead poisoning (see here).

M&S have done their best to shut down this conversation (see the last paragraph in the above letter) but that just ain’t going to happen. Steve Rowe (or his colleagues) have one last chance to answer our questions (namely, from which grouse moors are they sourcing their red grouse and what assessment have they used to determine whether the illegal persecution of raptors is carried out on those moors?) before we take the next step.

What will be the next step? The Trading Standards Office. We think the TSO will be very interested in the claims M&S are making about this product, particularly under the terms of the Trade Descriptions Act. It wouldn’t be the first time that M&S have found themselves under investigation by the TSO – in 2005 they were fined £10,000 + costs for making misleading claims about some of their products (see here). And just today, Tesco has been fined a whopping £300,000 + costs for misleading its customers over strawberries (see here).

Please join us in emailing Steve Rowe today and give him (or his colleagues) 7 days to answer these questions fully or else they can do their explaining to Trading Standards. Email:


East Scotland sea eagles raise chick in secrecy

wte east coastThe news of the first successful sea eagle breeding attempt in East Scotland in over a century has finally been announced today.

The breeding pair, both four years old, have managed to raise a single male chick on their first attempt, which is quite an achievement. It’s not unusual for young pairs to fail at their first attempt – a combination of inexperience and immaturity. The successful nest was in a secret location on Forestry Commission ground.

The pair were reintroduced to East Scotland in 2009 as part of a six-year reintroduction project (2007-2012) which saw 85 young eagles, donated by Norway, released into the wild from a secret location in Fife. At least 24 of those birds didn’t survive (cause of death included poisoning, shot, accidentally electrocuted and hit by trains). The East Coast reintroduction was the third phase of a national reintroduction project that started back in 1975 on the west coast of Scotland, after the species was extirpated from Britain thanks to persecution in the late 1800s and early 1900s.

This first successful breeding attempt marks an historic milestone in the project and hopefully is the beginning of a new and vibrant population in the east, mirroring the successful population growth in the west.

claire rhianAlthough many people and organisations have been involved with this project (notably RSPB Scotland, SNH and Forestry Commission Scotland), massive congratulations are due to two key individuals who have been at the very heart of the work – soundbites from their boss might be what we read in the media but it’s the efforts of these two that really should be recognised here: take a bow Project Officer Claire Smith and her successor Rhian Evans. Really well done. If you want to learn about the challenges they’ve had to endure throughout the project, check out the East Scotland Sea Eagle Project blog here.

The news of this chick is superb – far more interesting and important to some of us than the Royal baby hype –  but the story is marred by the secrecy that has surrounded it. This breeding attempt has been kept tightly under wraps for months, and the news has only been released now that the chick has safely fledged. It’s incredibly sad that the general public has not been allowed to follow this pair’s breeding attempt, sharing the drama as the season unfolded and feeling connected to the story, just as the public have been able to do with the first successful breeding attempt of reintroduced sea eagles in Mountshannon, Ireland this year. The interest is there, of that there’s no doubt, judging by the huge number of people who religiously log in every day to watch various nest cameras up and down the country, as well as those who make the long trek to Mull just for the chance of spotting the resident celebrity sea eagle pair from the purpose-built viewing hide. Not being able to share in that is a bit like being told Andy Murray has won Wimbledon, three months after he did it. It’s great news but not quite the same as watching and getting involved and feeling all those emotions.

Why has the breeding attempt been kept secret? Well that should be obvious – the threat to these birds is still incredibly high, as seen in January this year when ‘somebody’ took a chainsaw to a sea eagle nest tree on Invermark Estate in the Angus Glens and felled it (see here). Needless to say, Police Scotland are still ‘investigating’, 7 months on. If somebody can act so brazenly to go as far as felling a nest tree, then obviously the sea eagle project staff are going to do all they can to keep the news of a breeding pair under wraps until it’s safe to release it, no matter how much the public want to know.

Will it be like that next year? And the year after that? When will it be considered safe to tell us at the beginning of the breeding attempt rather than at the end? Probably not for a long, long time yet, thanks to illegal egg collectors, illegal poisoners, illegal shooters, illegal trappers and illegal tree-fellers. God this is a backward country.

Here’s hoping this year’s pioneering young male manages to stay alive (keep away from grouse moors) for long enough to raise his own family – the next big milestone for the East Coast Project will be Scottish-born sea eagles rearing their own young. Good luck kid.


Not just any red grouse…

MSAn article in the Daily Mail today reveals that Marks & Spencer has become the first high street retailer to sell whole red grouse (see here).

Initially, only two London stores will sell it, as a bit of a trial run –  Kensington High Street and Marble Arch – with the possibility of extending to other stores if sales are favourable.

Interestingly, the grouse are being sourced from grouse moors in Yorkshire and Northumberland. Why is this interesting? Well, M&S claims to have a strong policy on food sourcing, including a ‘named farmer’ scheme and a farm assurance scheme ‘which guarantees high quality food production’ (see here) and high specifications for animal welfare (see here). Now, North Yorkshire (full of grouse moors) just happens to be one of the worst raptor persecution hotspots in the whole of the UK (see here).

So, how will Marks and Spencer assure their customers that their red grouse have been responsibly sourced from grouse moors that are not poisoning, shooting and trapping protected species such as hen harriers, red kites, buzzards, peregrines, goshawks etc?

The Executive Director of food at M&S is Steve Rowe. Let’s ask him from where, exactly, are the red grouse sourced (name of grouse moor) and how, exactly, can he assure customers that the moors are not involved in wildlife crime? Here is his email address:


Natural England claims release of buzzard licence info ‘not in public interest’

buzzard 3Today, Natural England announced that they’d won a ‘Customer Service Excellence Standard Accreditation’ (see here). The independent assessors apparently spoke with NE staff as well as ‘a range of Natural England’s key customers and stakeholders’ and decided that NE was ‘excellent’ at providing ‘delivery’ and ‘information’ to their customers, amongst other things.

That’s not been our experience.

On 23rd May, an article in the Guardian revealed that Natural England had licensed the secret destruction of buzzard nests and eggs in order to protect a pheasant shoot. The licences in question had been issued to an un-named gamekeeper, whose licence application had been supported by the National Gamekeepers Organisation. We blogged about it here. There was widespread public condemnation, as expected.

On 30th May, we blogged about whether the licence applicant had a previous criminal conviction for wildlife crime (because we had good reason to ask – see here) and we wrote to Natural England to ask them about it (see here). Incidentally, we also asked the National Gamekeepers Organisation whether the gamekeeper they were supporting had a criminal conviction for wildlife crime and if so, had he ever been expelled from their membership, as per their club rules about not tolerating wildlife crime – they still haven’t answered!

On June 3rd, Natural England responded to our request for information (a very quick response, to give them due credit) by issuing a refusal notice. In other words, they refused to either confirm or deny that they held any details about previous convictions because, they claimed, this was ‘personal information’ as defined in the Data Protection Act. We strongly disagreed and wrote a second letter to NE (see here), asking for an internal review of their decision. We argued that the information requested could not be defined as ‘personal information’ because the information would not lead to the identification of the buzzard licence applicant; what we were asking was whether the applicant had a wildlife crime conviction, which could have been answered with a simple ‘yes’ or ‘no’.

On 29th July, Natural England responded to our request for an internal review by issuing a second refusal notice. Once again, they claimed the information we had asked for was ‘personal information’ and they also claimed the release of that information was ‘not in the public interest’. Here is a copy of the generic letter they sent out to quite a number of blog readers: RFI 2020 Int_Review Response_RD

Next stop? The Information Commissioner, to ask for a review of Natural England’s decisions. Watch this space…

On a related subject, Alan Tilmouth has written a(nother) good blog this evening, this time about the GWCT’s position on buzzard licensing – see here.


Peregrine shot, barn owl chick stolen, hen harriers remembered

It’s been quite a day. The so-called ‘Glorious 12th’ has been taken back by the conservationists and re-named Hen Harrier Day, in an inspired move by Alan Tilmouth (read his blog entry here).

Although he only came up with the idea yesterday, Twitter has been alive today with hundreds of people using the #henharrier tag to celebrate these spectacular birds and to express their anger at the virtual extermination of the species on grouse moors across England. Unsurprisingly, the game-shooting organisations were conspicuously absent.

Mark Avery also came up with a plan to help hen harriers. He’s called it BanGS – see here.

Meanwhile, news came through that police in Bolton are appealing for information after an injured and distressed peregrine was found by the side of a road. It had been shot. Full details here.

Elsewhere, the Suffolk Wildlife Trust is appealing for information after a barn owl chick was stolen from the Carlton Marshes Nature Reserve last night. Information here.

In other news, we’ve been having a look at some VERY interesting literature – a copy of the Leadhills Estate gamebook (don’t ask how we got hold of it!!) – which very helpfully documents annual counts of killed ‘vermin’ over a considerable number of decades. ‘Vermin’ in Leadhills-speak includes hawks, badgers, otters, cats and ravens amongst others. It’s fascinating. We’ll be writing more on this in due course…

Leadhills game book vermin lists


‘Project Raptor’ – new website launched

PR2-new-cmykA new website focusing on the illegal persecution of raptors in Scotland has just been launched by the ‘Project Raptor’ team – see here.

Definitely one to watch!


Hen harriers in England are fucked

HH by Gordon LangsburyRSPB press release here

If you’re offended by the title of this post then you really shouldn’t be here. Try getting offended by the news that there wasn’t one single successful hen harrier nest in England this year. Now THAT’s worthy of your outrage.

Here is some more media coverage from this morning:

BBC News here and good interview with RSPB’s Jeff Knott on BBC here.

The Guardian here, where the Moorland Association blames ‘the long cold winter’ for breeding failure!

The RSPB’s Skydancer blog here, where a fieldworker tells the story of one of the failed nests.

And then there’s a classic statement from the National Gamekeepers’ Organisation here, who accuse the RSPB of timing their press release to coincide with the start of the grouse-shooting season. Er, did they miss all the propaganda put out by the game-shooting industry this week about how good grouse-shooting is for conservation?? See here. They also suggest that hen harriers are doing well in the grouse moor stronghold [stranglehold] of Scotland! 505 territorial pairs in a country that has the capacity to support 1467-1790 pairs isn’t a very good example to show how great grouse moors are for hen harriers, especially when HHs are absent from large swathes of grouse moor in the Eastern Highlands and Southern Uplands!


Grouse-shooting propaganda rises as the 12th approaches

HH by Gordon LangsburyYou don’t need to look at your calendar to know that the 12th August is approaching; the rise in grouse-shooting propaganda tells you that the opening of the grouse-shooting season is almost here.

There have been several comical articles in recent days, including this one (titled ‘Grouse shooting praised for environmental work’), this one (titled ‘Benefits of managing Scotland’s natural assets’) and this one (titled ‘Grouse shooting season to be the most glorious for years’).

Each of these articles talks about how great grouse moors are for ‘rare wildlife’ and uses waders as the reference point. This isn’t rocket science – of course ground-nesting birds will benefit if their predators are systematically eradicated. Unsurprisingly, none of the articles mention the other ‘rare wildlife’ that certainly doesn’t thrive on intensively driven grouse moors – birds of prey.

There is though, one exception. A press release put out by the GWCT yesterday (see here) actually acknowledges that illegal persecution on grouse moors has had an impact on the hen harrier. They’re not kidding! Breeding hen harriers have been virtually driven to extinction in England. Last year there was one solitary breeding pair. This year….well, we don’t know yet. We haven’t heard of any breeding pairs in England although that’s not to say there haven’t been any – it’s possible that there may have been one or two and the nests have been kept top secret to protect them. No doubt we’ll hear more later in the year. But one thing’s for sure – there certainly haven’t been 300+ breeding pairs – this is the estimated population size that could be supported in England if the illegal persecution on grouse moors was stopped.

As for Scotland, well, hen harriers are doing better here than they are in England, but then that’s not difficult. A total of 505 territorial pairs were recorded during the last census (2010), more than a 20% decline from the previous survey done in 2004. Scientific studies suggest there is the potential for between 1467 – 1790 pairs if they were just left alone. They are absent from large swathes of, er, grouse moors, in eastern and southern Scotland.

It’s good to see GWCT publicly acknowledge the occurrence and extent of illegal persecution on grouse moors – it’s the first step in addressing the issue. Incredibly, a lot of their mates in the grouse-shooting world still refuse to admit it. As long as that denial continues, there is no hope for turning around the fortunes of this severely threatened bird.

Photo: hen harrier by Gordon Langsbury


Environment Minister responds to our questions about his ‘further measures’ to tackle raptor persecution

WheelhouseOn July 1st, Environment Minister Paul Wheelhouse laid out his ‘further measures’ to tackle the on-going problem of raptor persecution (here).

Whilst we welcomed his intentions, we wanted further clarification about these ‘further measures’ as well as some updates on previously-promised measures, so on July 2nd we posed five clear questions to him (see here).

This week, one of our blog readers received the following response from Wheelhouse’s wildlife crime policy officer:

Question 1:

Please can you clarify whether the Lord Advocate has instructed COPFS to accept covert video footage as admissible evidence in prosecutions for alleged raptor persecution incidents?


The Lord Advocate has instructed the specialist prosecutors in the Wildlife and Environmental Crime Unit to work with Police Scotland to ensure that law enforcement utilises all investigative tools at their disposal in the fight against wildlife crime including tools such as video surveillance equipment where justified and appropriate.

Before instituting any prosecution, the Procurator Fiscal must be satisfied that there is sufficient admissible evidence to justify doing so. Established rules of evidence determine whether a court can take into account certain types of evidence including third party video evidence. If evidence does not comply with these rules, it is inadmissible and the court may not take it into account. In considering any case for prosecution, the Procurator Fiscal will assess, having regard to the particular facts and circumstances of any evidence and the manner in which it was obtained, whether the court will allow it to be considered. For example, the court may refuse to take account of evidence that has been obtained improperly, irregularly or unlawfully.

Our assessment:

It’s hard to know if the Lord Advocate’s instruction will make a blind bit of difference. Covert video evidence is routinely accepted as admissible evidence in England. It has, also, been previously accepted in Scotland, albeit rarely. More often than not, COPFS rejects it and we’re never provided with a transparent answer about why it was rejected. We’ve struggled to understand the legal reasoning behind these repeat rejections, especially when, as we understand it, the decision to accept or reject evidence should be made by the court (the Sheriff), not COPFS. We’ll just have to wait and see how covert video surveillance is treated in any future cases….and it’s quite likely we won’t have long to wait.

Question 2:

Please can you clarify the timescale for SNH’s review for introducing potential restrictions on the use of General Licences in areas where they have good reason to believe crimes against wild birds have been committed? In other words, when can we expect the review to be completed? Also, will their review be made publicly available?


Officials are currently discussing with Scottish Natural Heritage how they will carry out the work to examine how and in what circumstances they can restrict the use of General Licences to trap and shoot wild birds on land where they have good reason to believe that crimes against wild birds have taken place. Timescales for completing the work are still to be concluded, but we would expect any new arrangements to be in place for next year and will ensure that we keep stakeholders in PAW Scotland informed of progress. SNH will be clear to all users of General Licences when and in what circumstances their use will be restricted or prohibited.

Our assessment:

This seems a perfectly reasonable explanation. We look forward to watching the developments.

Question 3:

Please can you advise whether there will be a prosecution under the new vicarious liability legislation following the recent conviction of gamekeeper Peter Bell, found guilty of poisoning offences on the Glasserton and Physgill Estates? If you don’t know the answer (which would be surprising, given that you said in March 2013 that you would be “keeping an eye on this particular area [i.e. vicarious liability] with interest”, please can you provide the contact details of someone who can answer the question?


It would be inappropriate to comment further on this case as police enquiries have not yet concluded.

Our assessment:

Not very impressed, but as this case is probably the first of its kind to be considered under the new vicarious liability legislation, we don’t have any benchmark to be able to compare the timescales involved. It’s been 8 months since the crimes were committed (December 2012). Is it reasonable to expect Police Scotland to still be conducting enquiries or is this another fob-off to delay telling us that no charges will be brought under VL legislation? If they are still making enquiries, let’s hope they’re making a better job on this case than they did on this one! We’ll keep asking questions about this case every so often so it can’t just be swept quietly under the carpet.

Question 4:

Please can you tell us the status of the Scottish Government’s first annual report (2012) into wildlife crime? As you know, under the Wildlife and Natural Environment (Scotland) Act 2011, there is now a requirement (under section 26B) that ‘Scottish Ministers must, after the end of each calendar year, lay before the Scottish Parliament a report on offences relating to wildlife’. You mentioned in March 2013 that your policy officials ‘are currently working on’ this report. When can we expect this report to be available?


Section 26B of the Wildlife and Countryside Act 1981 requires Scottish Ministers, after the end of each calendar year, to lay before the Scottish Parliament an annual report on wildlife crime. We will of course comply with that requirement and it is in preparation. Details about the laying of the report, including the timing, will be given to the Parliament in the first instance in accordance with established parliamentary protocol. We will, of course, ensure that the report publication is communicated to stakeholders and Parliament.

Our assessment:

It’s taking a very long time for this report to be published. We’ll keep asking about it.

Question 5:

Please can you tell us when, exactly, will you open the consultation regarding the increase of SSPCA powers to broaden the range of their work investigating wildlife crime? As you know, this consultation was first suggested by former MSP Peter Peacock as an amendment during the WANE Act debates, way back in February 2011. The then Environment Minister Roseanna Cunningham rejected it as an amendment but suggested a consultation was in order. Seven months later in September 2011, MSP Elaine Murray lodged a motion that further powers for the SSPCA should be considered. In November 2011, Elaine Murray MSP formalised the question in a P&Q session and the next Environment Minister, Stewart Stevenson, then promised that the consultation would happen in the first half of 2012. Nothing happened so in September 2012 we asked you, as the new Environment Minister, when the consultation would take place. In response to one of our blog readers in October 2012 your policy officer said: “The consultation has been delayed by resource pressures but will be brought forward in the near future”. Nine months later and we’re in July 2013 – almost 2.5 years after Scottish Ministers committed to undertaking the consultation. Where is it?


We regret that resource pressures did further delay the public consultation on the extension of SSPCA powers. However, I can confirm that the consultation document will be published later this year.

Our assessment:

As far as we’re concerned, this consultation, if it does actually appear this year, could be a game-changer. Forget bringing in new legislation to tackle raptor persecution – we don’t need it. The legislation is all there – it just needs to be enforced. The enforcement process begins with a criminal investigation. Do we have complete confidence in Police Scotland to effectively and efficiently undertake these investigations? Based on their past performance, that has to be a resounding NO, with just a handful of exceptions. Do we have confidence in the SSPCA to undertake these investigations? If we judge them on their track record for successful prosecutions under animal welfare legislation, then YES, we do. We also know that certain organisations associated with the game-shooting industry do not support these extended powers for the SSPCA – they argue that criminal investigations should be carried out by the police. Funny that, because they support extended powers for water bailiffs – is that because the water bailiffs are often acting in the interests of landowners and gamekeepers (e.g. when tackling poachers)? Do they not support extended powers for the SSPCA because they know that with an extra 75+ highly-trained officers on the ground then the chances of raptor persecution crimes being uncovered become greater? You’d think, given that the game-shooting industry claims to be all for stamping out raptor crime, that they’d welcome the SSPCA with open arms.  We’ll be watching closely for this consultation to finally emerge and you can expect a great deal of blogging about it when it is published.


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