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Written submission from the Game and Wildlife Conservation Trust
Section 6: ENTRY IN VALUATION ROLL OF SHOOTINGS AND DEER FORESTS
As a conservation organisation, GWCT is primarily concerned with the environmental
implications, both positive and negative, that the Land Reform Bill could have on
Scotland’s biodiversity. Over 20% (~15,700km2) of Scotland’s land area is primarily
managed for sport, with agriculture being the most prominent land use along with
forestry46. GWCT understands that Scottish Government’s intention in proposing the
reintroduction of sporting rates is to ensure that sporting enterprises are in line with
other rural businesses in terms of taxation. Although we note that other land
management businesses such as farming and forestry are not subject to taxation,
our primary concern is that this policy change could negatively impact on
conservation management within the wider countryside.
Why is this the case?
We suggest that there is a risk that increasing costs and regulatory burdens on
currently motivated individuals will dis-incentivise those who provide benefits to
biodiversity, soils and local culture and economies through their skilled use of a suite
of conservation tools and approaches.
Those who are motivated by the enlightened self-interest of wishing to sustainably
shoot wild game contribute substantially to enhancing Scotland’s habitats and wildlife
by actively managing the rural landscape. A dedicated and concentrated effort to
enhance habitats, monitor species, manage disease and common predators are all
tools which are currently delivered across our countryside by gamekeepers, wildlife
rangers and farmers.
What could replace lost incentive?
The GWCT is not convinced that the public purse or local communities are ready to
shoulder the burden of continuing to provide the public benefits that flow directly from
game conservation management.
If private investment in our countryside were to be reduced or withdrawn, as the
incentives to continue were unbalanced against the increasing cost of carrying out
management, it is likely that wildlife management would be left to two groups. The
first are those who are paid to undertake such management at a considerable cost to
the public purse. The current cost of managing 1km 2 of NNR is in the region of
£4,872 47; there are 15,700km2 of farmland, woodland and moorland primarily
managed for sporting purposes 46.
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The second are communities who will likely have fewer skills and less of the
motivation needed to deliver consistent and professional conservation effort which is
so desperately needed if Scotland is to achieve its 2020 Biodiversity targets.
Game management and public benefits
GWCT research, and our experience of game management indicates that many
public services accrue from shooting and that it is incorrect to state that they make
no contribution1.
Scotland’s moors, farmland and woodlands are man-made habitats, celebrated
around the globe2. They are home to specialist flora and fauna and deliver a range of
other public goods and services such as drinking water, carbon storage and
recreation. They are no longer “wilderness” having been subject to centuries of
human influence either direct or indirect2. The key to their future is to ensure that
they are managed ‘sustainably’, in such a way as to meet a full range of demands
without the ecosystem becoming permanently depleted or damaged. The GWCT
believes that maintaining the economic incentive to produce enough grouse (or
pheasants and partridges in the lowlands) for driven shooting is one of the best ways
to sustain the investment that allows people to live and work in the countryside and
enhance the natural environment.
Across moorland, farmland and woodland game management produces a number of
public benefits, including:
1.
Cost-effective
statutory
conservation
Game management provides a framework for the conservation of habitats and
wildlife, supporting the statutory targets for dry heaths 3, black grouse4 and, on
farmland and woodland, songbirds and grey partridge 5. Across all habitats the
sporting management of red and roe deer makes the greatest contribution to
protecting healthy habitats and deer populations6. Without this private investment in
our rural environment we believe that there would be greater financial pressures on
Government bodies and charities to maintain habitats and to deliver population
recovery of our wildlife at a landscape scale.
2.
Retention
and
restoration
of
habitat
Woodland management and planting, outwith commercial forestry, in many
instances has been driven by game conservation interests. Studies have shown that
land managers are three times more likely to undertake woodland planting where
pheasant releasing is practiced7. The management of woodland for game, which
includes the creation of rides, skylights and maintenance of shrubs, provides a
number of benefits to declining species butterflies8 and birds9.
Heather is a globally important habitat - 75% of the world’s heather habitat is found
in Britain10 - which is utilised by red grouse and other species. Grouse moor
management promotes the retention and restoration of heather habitat through
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sensitive grazing by sheep and rotational patchwork burning (muirburn). Red grouse
shooting has been a disincentive to overgrazing and the planting of conifer forests on
these protected habitats. In Scotland grouse shooting interests are widely accepted
as having protected 953km2 of Scottish heather moorland from conversion into
grassland and forestry in the last 50 years11. Heather moorland is of cultural and
aesthetic value to local communities12 and the thousands of tourists who visit our
iconic purple clad hills every year, whilst being an internationally important resource
that is of high conservation priority13.
Graph- An analysis of aerial photographs
from the National Countryside Monitoring
Scheme in Scotland. A random sample of
sites photographed in 1940 showed that
49% were being managed as grouse
moors. Of these, 57 sites remain as
active grouse moors and 46 had given up
grouse management by the 1980s. Over
this 40-year period the grouse moors lost
24% of their heather cover, whereas
where the grouse shooting was lost, the
heather cover had been reduced by 41%.
From a study by Robertson, Park &
14
Barton
3.
Support
for
the
conservation
of
ground-dwelling
species
Many of our most iconic and yet threatened species such as grey partridge, hen
harrier, capercaillie, curlew, lapwing, golden plover and black grouse nest on the
ground and are susceptible to predation. GWCT research has shown that predation
management as undertaken by game keepers can protect increasingly rare and
threatened ground-nesting species by improving their chances of fledging young15 16.
In addition, in the lowlands, brown hare’s are strongly associated with game
management, with predator control a significant determinant of population change 17.
Similarly, Mountain hare presence is strongly associated with upland sporting
management, with 80% of mountain hares found on moors managed for grouse 18.
Graph- Numbers of breeding waders found
on grouse moors compared with moorland
not managed for grouse. Golden plovers
and lapwings were over five times as
common on grouse moors compared with
other moorland, and curlews twice as
common. RSPB and GWCT joint-authored
19
research .
4. Contributes to the delivery of clean water and carbon storage policy objectives
In the low ground, habitats created by farm shoots and managed for game such as
planted field margins, grass strips, hedgerows and beetle banks all contribute to the
Water Framework Directive through reducing diffuse pollution and soil and water runoff20 21.
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Moorland is a key component in the delivery of drinking water and downstream flood
protection. It also supports our ability to meet climate change targets through carbon
capture22. Best practice grouse moor management contributes to these aims by
maintaining heather and peat cover, reducing the risk of wildfires through sensitive
burning regimes44 and filling in historically subsidised drainage ditches (grip
blocking)23. However, further research is needed on improving carbon lock-up in
peat, understanding both the carbon cycles on managed moorland and the
restoration of Sphagnum mosses, and refining burning practices to maximise carbon
storage.
5.
Provides
jobs
in
economically
vulnerable
areas
Rural Scotland is an economically vulnerable area with limited opportunities for local
communities to develop sustainable and year round income. It has been estimated
that shooting contributes £200 million per year (GVA) to Scotland’s economy24 both
directly and indirectly through local services such as hotels and garages 12. In
2011/12 it was estimated that grouse shooting accounted for 2640 FTE jobs and
£30m of wages per annum25. There are also financial benefits to extensive hill
farming, which is increasingly under pressure, through improved habitat
management and payment for treating sheep. Sporting income is important in
ensuring the sustainability of remote rural communities and their supporting
services26.
6. Contributes to our cultural heritage
Game management contributes to the conservation of a number of flagship species
and habitats that are part of our cultural heritage and underpin aspects of Scottish
tourism. SNH calculated that “wildlife tourism” contributes £127 million and “touring
and enjoying Scotland’s landscapes and scenery” £420 million per annum. Also of
benefit to tourists is the active tick control that occurs on many upland moors as part
of best practice grouse moor management 27.
GWCT concerns with the reintroduction of sporting rates
There is little research into the motivations and incentives which shape cost-benefit
judgements as regards sporting management. But if the additional investment
threshold is too great we believe that the reintroduction of sporting rates could have
significant unintended consequences for conservation management and in turn the
amount of public services provided by the managed landscape. Through an increase
in bureaucracy and additional costs sporting rates may result in the withdrawal of
game management over large areas of the countryside (56% of Scotland is
influenced by shooting28). This in turn would have an impact on a number of aspects
of conservation management and Scotland’s ability to deliver adequate species
recovery in order to meet its 2020 biodiversity targets outwith designated sites.
A report for the Scottish Government’s Rural Land Use Strategy46 identified key
actions to maintaining sustainable use of Scotland’s countryside which include:
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


keeping transaction costs of policy delivery low;
creating incentive systems for community engagement;
maximising the scope for voluntary measures by a wide range of rural
stakeholders.
GWCT is of the view that the reintroduction of sporting rates could result in changes
in voluntary investment in three key aspects of conservation management:
1. Landscape restoration and habitat fragmentation
Conservation of Scotland’s species is largely delivered by private ownership and
investment. This includes large areas of land owned by private individuals and
charities such as RSPB, NTS and JMT. Land use amongst these groups is focused
on wildlife/landscape tourism, conservation (nature reserves), agriculture and
sporting (shooting, fishing and stalking).
Evidence from the GWCT’s Grey Partridge Count Scheme (a voluntary programme
of recording numbers of this red listed species in the UK), has shown that
participating land owners undertake more management that supports partridge
recovery and delivers wider biodiversity benefit than non-members. Further analysis
has shown that long-term members tend to be larger estates or farms which in turn
require a higher density of keepers dedicated to active land and species
management. This evidence would suggest that larger units have the ability and
resources to deliver measurable biodiversity benefit in Scotland.
Game management is a significant motivation for investment, often at uneconomic
levels, in habitat management justified by the desire to maintain or improve capital
value. Currently 47% of shoots pay for habitat improvements themselves, with a
further 69% of shoots entering into agri-environment agreements29. If the driver for
management was removed through the actual or perceived additional costs of
sporting rates, other single objective economic land uses such as woodland
expansion, food production and wind farms, all of which are supported by publiclyfunded policy incentives, are likely to prevail. This would reduce and fragment
biodiversity habitats such as heather moorland with consequent impacts on
associated flora and fauna and ultimately the visitor experience. Given that heather
moorland in Britain is considered to be internationally important and its retention is a
high conservation priority there is a risk of contravening our EU obligations 30.
Protection of heather moorland without its associated management is not the
answer. Unmanaged heather will increase the risk of wildfire and changes in the
sward composition such as bracken encroachment will impact on important upland
ground nesting species, affect its grazing value and change a culturally valued
landscape. Cessation of grazing, burning and predator management (grouse moor
management) will affect the breeding success of vulnerable ground nesting species 31
including hen harrier as seen at Langholm Moor in South West Scotland 32 and in the
Berwyn SPA in Wales33 . The economic output from moorland areas (hill farming and
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sporting) would also be significantly reduced. If conservation management were to
replace grouse moor management then this would need public funding and may
have negative socio-economic consequences for upland communities34.
Habitat fragmentation will not be restricted to the uplands and a number of low
ground habitats may also be effected by a change in the level of management. Areas
such as small scale woodland (64% of shoots have planted new woodlands in the
last 10 years29) which contribute to Scotland’s woodland expansion programme and
benefit a number of woodland species such as the red squirrel. Conservation crops
and hedges which are often planted for game may also become less desired
landscape features if sporting management is reduced or withdrawn.
2. Reduction in legal predator control
GWCT’s research has demonstrated the benefits of controlling predators (foxes,
corvids and mustelids) for a number of game and wildlife species including priority
action species such as black grouse, capercaillie35 and brown hare36.
For some species habitat improvement alone will not support population recovery.
Our multi-year, peer-reviewed experiments at Salisbury Plain37, 38 and Otterburn 39
have highlighted that predation not only has a meaningful impact on many species,
but that predator control is necessary to sustain numbers in favourable conservation
status as required by the EU Bird and Habitat Directives.
This effect was well demonstrated at the GWCT Allerton Project where hares
reached autumn densities that were exceptional for the UK when both habitat and
predation control were in place. When predation control was stopped, hare densities
fell, even where habitat improvements remained. This analysis demonstrates that
even when farmland habitat is greatly improved, uncontrolled predation prevents
hares making full use of its carrying capacity36.
Predator control when done well is both expensive and time consuming. Any
increased financial pressures placed on smaller shoots could see the removal of
such management, thereby having a negative impact on biodiversity. We believe
Scottish Government would struggle to deliver adequate species recovery for a
number of declining species if the incentive (sporting) to manage predators was
removed.
3. Reduction in over winter feeding
Farmers plant wild bird seed mixes in small patches across their farm or distribute
grain from feed hoppers to provide food for birds and other wildlife over the winter
when natural resources are critically low. These areas are of particular importance
due to the efficiency of harvest machinery and herbicides which have reduced the
availability of food for wildlife in the arable landscape40.
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The primary incentive for many land managers to provide food during the winter
months is to support game birds for sporting purposes. However, there is clear
evidence of the additional benefits to wider farmland birds 41, 42 such as yellow
hammer, tree sparrow, linnet and song thrush all of which are red listed as species of
conservation concern45 from the provision of winter feeding (Game management).
This management is currently funded in two ways:
1. Private investment
2. Public sector subsidies (SRDP).
We believe the actual (or perceived) financial and bureaucratic impacts of sporting
rates could reduce the incentive to maintain levels of private investment in the
provision of food during the winter months with land managers choosing not to invest
in additional habitat management.
For those that receive financial support through subsidies, any additional burden
(taxation) is likely to de-incentivise entering these agreements. This is because even
the payments received currently do not cover the full cost of such management (i.e.
are not ‘profit foregone’), and this management is in addition to already compulsory
greening requirements.
Discussion
Game management contributes to the provision of public services and conservation
objectives.
We are concerned that the economic impact of sporting rates could disincentivise
enough land managers to reduce the management of key habitats and species,
removing support for their recovery alongside legitimate economic and social
activities. Given the severely constrained environmental budgets, particularly under
SRDP, we believe there would be little, if any capacity for Scottish Government to fill
any deficit created. Currently conservation funding is targeted at designated sites
which cover 18% of Scotland43. As identified in the Scottish Biodiversity Strategy,
habitat fragmentation caused by changes in land use is one of the biggest drivers of
environmental degradation. We wish to ensure that new policies introduced by the
Land Reform Bill do not unintentionally result in land abandonment or the
intensification of economic activity to the detriment of biodiversity. An increase in
regulation and costs is not, in the GWCT’s experience, likely to stimulate
management for wildlife or encourage the wildlife revival we urgently need.
We recognise that Scottish Government feels that it has not seen compelling
evidence against the reintroduction of sporting rates in respect to potential job losses
and the reduction in species and habitat management. However we would suggest
that it has not provided evidence to the contrary, and that a full economic and
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environmental assessment would be beneficial and necessary before parliament
reaches a decision on sporting rates.
Mitigation
We believe that there are ways to reduce any negative impacts on biodiversity which
may occur with the introduction of sporting rates. We believe there are two ways
which could ensure that conservation management continues:
1. Exempting smaller shoots from sporting rates, similar to the small business rate
relief. This would encourage shoots who make a valuable contribution to biodiversity
but are economically more vulnerable, making little or no income, to continue to
positively manage the rural landscape.
2. We also see merit in exempting sporting enterprises that are able to clearly
demonstrate a net biodiversity gain from their management. We suggest that an
accreditation scheme which independently assesses sporting businesses would
warrant further consideration by Scottish Government. Thus farms under existing
schemes such as the GWCT Partridge Count Scheme or LEAF farm accreditation, or
properties that have satisfied the stringent tests of the Wildlife Estates Scotland
accreditation scheme, may be considered suitable for exemption.
Furthermore, we would also recommend that the money raised through the
reintroduction of sporting rates should be used to benefit conservation management
to ensure that Scotland has the best possible chance of meeting its 2020 biodiversity
targets.
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