SNH announces consultation on General Licences

Scottish Natural Heritage (SNH) has announced it is to launch a public consultation on the General Licences later this summer.

[The use of traps like this one are ‘regulated’ under the General Licences but that ‘regulation’ is rarely enforced]

Here’s the SNH press release:

SNH to launch General Licence Consultation

A 12-week consultation about General Licences will take place later this year, Scottish Natural Heritage (SNH) announced today.

A General Licence is a type of species licence that allows users to control wild birds or destroy their nests, for reasons such as preventing serious damage to crops, protecting public health, and guarding air safety when flocks of birds are liable to get in flight paths.

Robbie Kernahan, SNH’s Head of National Operations, said: “We want to ensure that General Licences in Scotland are clear, proportionate and fit-for-purpose. In light of the complicated situation in England with General Licences right now, we have decided to bring forward our consultation which had been scheduled for 2020.

Our General Licences cover relatively common situations – such as preventing agricultural damage and protecting public health and safety – when there’s unlikely to be any conservation impact on a species. They avoid the need for people to apply for individual licences for these specific situations. As with any licence, we need to ensure that General Licences strike the appropriate balance between species conservation and a range of other legitimate interests.

We would like to reassure those who are currently operating under General Licences in Scotland that these remain in place, allowing those who comply with the conditions to continue to use them.”

The consultation will ask stakeholders for their views about how General Licences work in practice, what they should cover, and how they are worded.


This proposed review and public consultation of the General Licences is no surprise given the recent situation with similar General Licences in England which Natural England has had to admit are unlawful, after a legal challenge by Wild Justice.

And whilst the proposed SNH review and consultation is to be welcomed, long-term blog readers will know we’ve been here many times before (e.g. see herehereherehere, here and here) and although SNH has responded to some criticisms in the past by making some minor amendments, most of the requests for reform have fallen on deaf ears.

General Licences are still considered to be a light-touch form of regulation for the killing of wild birds and there are MANY areas of improvement still needed, not only to address the principle that lethal control of birds should be a last resort, but also to close the loopholes being routinely exploited by raptor-killing criminals. If calls for reform are ignored again, without justification, SNH may well find itself facing another legal challenge.

We look forward to the launch of the consultation later in the year and we’ll be encouraging as many people as possible to submit a response.

UPDATE 5pm: RSPB Scotland has issued a strong statement welcoming the review in light of some of the current General Licences being “not fit for purpose”. Spot on.

8 Responses to “SNH announces consultation on General Licences”

  1. May 21, 2019 at 2:53 pm

    I had wondered if Wild Justice would be looking more closely at SNH licences. The huge difference between England and Scotland in the licences and legislation is remarkable. I hope that the consultation will be open to members of the public rather than just stake (and shotgun) holders. Having read the licences it does seem that some of the issues in England are replicated. As a science based organisation, the appearance on the general licence of some species and SNH assertion that they see no other satisfactory solution does seem strange. SNH should be praised for not having Jay on the 2019 lists, however. I would admit that the situation is different (and already better) in Scotland, which has kept the legislation and licences under review.

    • May 21, 2019 at 4:52 pm

      Hi Alex,

      To be honest, although there are differences between the English and Scottish General Licences, I’d argue that those differences are not “huge” – they’re minor.

      And for the record, SNH General Licence GL 01/19 does have Jay listed.

      I don’t understand your last sentence. General Licences in England and Scotland are all subject to review and have been since implementation. It’s the robustness of the review that is questionable, in both countries.

  2. 3 Simon Tucker
    May 21, 2019 at 3:00 pm

    The whole idea that someone can kill an unlimited number of anything, whatever the justification, and not have to account for each kill, not to account for the non-lethal methods tried and failed, not to be held to account for unnecessary pain and suffering caused, not held to account for non-target species killed and maimed is anathema to me.

    The whole system needs scrapping and starting again: and the people that want to do the killing should have to pay for it. It is astonishing that the ordinary taxpayer picks up the bill for administering a system that most abhor. The fact that the licences to own the means of destruction, particularly shotgun licences, is a monstrous waste of taxpayer money is just plain wrong: subsidies for the rich. If the cost of licensing a shotgun is £2k, as I seem to remember reading elsewhere, as estimated by the police, then that is what it should cost each individual to licence their shotgun.

  3. 4 Les Wallace
    May 21, 2019 at 4:24 pm

    This wouldn’t have happened without Wild Justice. Well done!!

    • May 21, 2019 at 4:46 pm

      Hi Les,

      That’s not quite accurate. SNH (and Natural England for that matter) routinely undertake ‘reviews’ of the General Licences and less routinely undertake consultations on their application.

      What might be different this time is that SNH takes more care of its review and might take more consideration of legitimate criticisms. Let’s see.

  4. 6 Big Eck
    May 21, 2019 at 7:40 pm

    I hope this doesn’t mean they’ll go in really hard in the meantime, fearing their licences may end in the future, Didn’t this happen when word went out that permission for hill tracks would be required?

  5. 7 George M
    May 21, 2019 at 9:41 pm

    I’m not enthused by either the content or the tone of Robbie Kernahan’s statement.
    It appears to me that he is simply trying to test the water to find out how it will be received and draw out any potential criticisms so they will be ready to address them when the review reveals, that I have little doubt it will, that not much will change other than how the regulations are framed.
    Indeed it might well be prescient that this is the day that Theresa May presented her revamped position on Brexit, only to reveal that nothing will fundamentally alter in either case.
    Walk with caution.

  6. May 22, 2019 at 7:02 am

    SNH are not a safe pair of hands, it would be better if there was an independent lead on this exercise.

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