Written evidence from Keith Miller (GRO0339)

 

 

Executive Summary

 

 

Written Submission

 

  1. I am a UK citizen.  I was brought up in the countryside of NW England, and have lived & worked in the uplands of the UK throughout my entire adult life.  For the last 14 years I have lived in an area in which driven grouse shooting takes place.  As a result I am very familiar with upland habitats, wildlife, land management & its practices and rural life. 

 

  1. I am submitting evidence as I signed the UK Government petition to Ban Driven Grouse Shooting (https://petition.parliament.uk/petitions/125003) – I do not consider that this hobby has a place in the 21st century.

 

 

  1. Scientific evidence clearly demonstrates several significant negative environmental impacts of driven grouse shooting and its management, and implicates it in others.

 

 

  1. The management of our uplands should benefit the whole of society and not just a few individuals. 

 

 

  1. The proven major negative environmental impacts greatly outweigh any claimed benefits.

 

 

  1. Therefore, I believe the law on driven grouse shooting should be changed as soon as possible so that the activity is completely illegal.

 

 

 

Impacts of Driven Grouse Shooting on the Environment and Wildlife

 

Deliberate (prescribed) burning of vegetation

 

  1. Deliberate (prescribed) burning of vegetation is one of the main elements of management to increase the number of Red Grouse available to be shot.

 

  1. Scientific research (including the EMBER project at the University of Leeds; Brown, LE, Holden, J and Palmer, SM (2014) Effects of moorland burning on the ecohydrology of river basins. Key findings from the EMBER project. University of Leeds. http://www.wateratleeds.org/ember/) has demonstrated significant detrimental environment impacts of the practice.  These include:

 

 

  1. Peatland is a key carbon sink, storing around 40% of the UK’s soil carbon (http://uknea.unep-wcmc.org/Resources/tabid/82/Default.aspx). Burning reduces in the ability of peatlands to store carbon and so increases the release of carbon dioxide (CO2) into the atmosphere and contributes to human-exacerbated climate change (being a ‘greenhouse gas’).  A key finding of the EMBER project (http://www.wateratleeds.org/ember/) was: “Water-table depth is very important in peatlands for maintaining their stability and function as a carbon store. Water tables were found to be significantly deeper for burned catchments than for unburned ones. Deeper water tables would suggest a greater scope for degradation of the peat and loss of carbon to the atmosphere.”

 

 

  1. “Sphagnum mosses are keystone species for providing a range of ecosystem services. Sphagnum mosses are the main peat forming species, thereby contributing to carbon sequestration and storage. Furthermore, Sphagnum-dominated peatlands do not release as much methane as those dominated by vascular plants.” (Burning and Peatbogs (IUCN 2011): http://www.iucn-uk-peatlandprogramme.org/sites/www.iucn-uk-peatlandprogramme.org/files/Burning%20and%20Peatbogs,%20June%202011.pdf)

 

 

  1. Burning of peatlands reduces the ability of Sphagnum to grow there. A key finding of the EMBER project (http://www.wateratleeds.org/ember/) was: “Sphagnum is an important peat-forming species. Changes in the hydrological properties of the peat after fire make the peat less conducive to Sphagnum moss growth.”

 

 

  1. Burning reduces water quality by increasing organic material and sediment in water courses.  A key finding of the EMBER project (http://www.wateratleeds.org/ember/) was: “Particulate organic matter (predominantly peat) deposits were increased up to four-fold in the bed sediments of burned rivers.” This increases costs for water companies which need to clean-up the water before providing it to their customers.  These customers then pay extra in their water bills to cover these clean-up costs. The polluter is clearly not paying for their pollution in this situation.

 

 

  1. The Environmental Audit Committee inquiry into soil health received a written submission from the Committee on Climate Change (https://documents.theccc.org.uk/wp-content/uploads/2016/01/CCC-Written-Submission-to-Environmental-Audit-Committee-Inquiry-into-Soil-Health.pdf.  This noted that:

 

 

  1. “14. The English uplands are dominated by blanket bog and heathland habitats, which tend to have highly organic and peaty soils. When in good condition, peat bogs actively soak up carbon, accumulating between 3 and 7 tonnes per hectare per year. Peatlands also play a vital role in the provision of drinking water to millions of people, as they form the headwaters for some of England’s major water supply catchments.”

 

 

  1. “16. The area of burned moorland has increased significantly in recent decades across much of northern England. A comparison of aerial photography from the 1970s and 2000 of over 200 km2 of the English uplands found that the extent of new burns had doubled (from 15% to 30%) over this period. A recent study found that the annual number of burns between 2001 and 2011 increased by 11% per year, with an accelerating trend in more recent years.”

 

 

  1. “17. There is increasingly strong evidence that managed burning reduces peat accumulation, causes declines in carbon storage, and increases dissolved organic carbon (DOC) levels in watercourses.11 Levels of DOC in UK upland water bodies have doubled over the last 30 years. Some of this observed increase in DOC is likely to be due to reductions in sulphur deposition (more commonly known as acid rain) since the 1990s. However, there is evidence that managed burning is the primary cause of DOC export in parts of the English uplands.”

 

 

  1. Evidence is accumulating that burning of moorland & peatland vegetation increases downstream peak flow (for example https://www.scribd.com/document/325491420/Odoni-Modelling-Study-and-Supplement). This has major implications for downstream human settlements that suffer flooding with water originating on moorland managed for driven grouse shooting. 

 

 

  1. Burning favours fire-tolerant species, one of which is heather (Calluna vulgaris) which is why it is carried out.  Obviously, however, other species and especially fire-intolerant ones suffer.  Areas subject to (rotational) deliberate burning therefore have impoverished vegetation (for example they lack trees & shrubs) and thus an impoverished associated fauna. Habitat, plant and wildlife diversity are thus all strongly depressed in these areas. 

 

 

  1. Burning prevents the establishment and growth of trees and shrubs which can slow the flow of water from upland areas.  Slowing the flow of water has been proven to reduce peak flood events downstream.  Thus burning, and the management of land associated with driven grouse shooting, prevent actions that can reduce or prevent flooding of people’s homes and businesses downstream, and all the human misery that goes along with this flooding.

 

 

  1. It is clearly time that the Government legislates to make the deliberate burning of vegetation undertaken for the hobby of driven grouse shooting illegal.

 

 

Drainage

 

  1. Drainage of moorlands is another frequent management action and a very significant proportion of the English uplands managed for driven grouse shooting have suffered from the digging of drainage ditches.

 

  1. Drainage of moorlands clearly alters the hydrology of the area and has several similar detrimental impacts on the environmental.  These include:

 

 

  1. Drainage of moorlands reduces the capacity of the soils and vegetation to absorb and hold water, and speeds up water flow off the higher ground.  This is implicated in increasing the risk of flooding of downstream human settlements.

 

Birds of prey

 

  1. Driven grouse shooting is underpinned by the illegal persecution and killing of several species of birds of prey, including Hen Harrier (Circus cyaneus), Peregrine (Falco peregrinus) and Golden Eagle (Aquila chrysaetos). 

 

  1. Breeding populations and productivity of these species are significantly lower on land managed for driven grouse shooting than on land not managed for driven grouse shooting.

 

 

  1. In 2008 Natural England published A future for the Hen Harrier in England? (http://publications.naturalengland.org.uk/file/81030).  Its summary states:

 

 

  1. However, since that report was published the situation has deteriorated further.  In England, between 2010 and 2016 there were no more than 6 successful Hen Harrier nests in any one yea; in 2012 only 1, in 2013 none, in 2016 only 3 with none on grouse moors.

 

  1. This report also notes (page 18) that “Potts (1998) estimated that in the absence of persecution the English uplands would support 232 territorial females.”

 

 

  1. In 2011 the Joint Nature Conservation Committee (JNCC) published its report A Conservation Framework for Hen Harriers in the United Kingdom (http://jncc.defra.gov.uk/pdf/jncc441.pdf). Amongst much data and analysis this authoritative report notes that:

 

 

  1. Peregrines also fair extremely badly on grouse moors.  Their breeding distribution is strongly skewed away from grouse moors despite suitable habitat, food and nesting sites.  In fact there are more pairs of Peregrines breeding in England’s cities than on all of England’s grouse moors.

 

  1. The impacts of grouse moor management on populations of Peregrines has been researched, notably by Amar et al (2012) Linking nest histories, remotely sensed land use data and wildlife crime records to explore the impact of grouse moor management on peregrine falcon populations     (http://www.sciencedirect.com/science/article/pii/S0006320711003831).

 

 

  1. So in England we have virtually no breeding Hen Harriers (when there should be 232-340 pairs in the uplands) and a significantly reduced breeding population of Peregrines on grouse moors, with evidence clearly implicating illegal persecution associated with driven grouse moor management. And both species have had full legal protection for over 60 years.  This is a problem of illegality, nothing else, and is totally unacceptable. Urgent Government action is clearly required. 

 

 

Impacts on other wildlife

 

  1. In order to maximise the number of Red Grouse (Lagopus lagopus) available to be shot land management favours heather (Calluna vulgaris) above other vegetation as this is the principle food of Red Grouse.  Management for driven grouse shooting clearly reduces the diversity of upland habitats and upland wildlife is restricted to those animals that can live in these impoverished habitats. 

 

  1. In order to maximise the number of Red Grouse available to be shot large numbers of animals perceived to be potential predators of Red Grouse (such as Weasels, Stoats, Foxes, Carrion Crows) are trapped and killed.  Although, if done correctly, this trapping and killing is legal there are instances of non-target species being caught and suffering in traps. 

 

 

  1. Furthermore, why should society allow these species to be killed just to provide larger numbers of Red Grouse that are then shot as part of what is simply a hobby.  This mass killing does not have a place in the 21st century. 

 

 

Roads and ATV tracking

 

  1. Many, many, miles of private surfaced roads have been constructed or established across England’s uplands just to service the hobby of driven grouse shooting.

 

  1. These surfaced roads are scars on the upland landscape and significantly detract from people’s enjoyment of these areas.  

 

 

  1. These surfaced roads damage and destroy vegetation and habitats.

 

 

  1. These surfaced roads require drainage and so alter the hydrology of areas across which they are established. Therefore, they contribute to the negative environmental impacts associated with land drainage (paragraphs 20, 21 and 22 above).

 

 

  1. Additionally the use of all-terrain vehicles (ATVs) damages, and when used frequently can destroy, the vegetation across which they travel.

 

 

  1. Convenience should not be a justification for damaging or destroying upland vegetation and habitats.

 

 

Lead deposition into the environment

 

  1. An unknown, but undoubtedly considerable, quantity of lead is deposited into the upland environment through the use of lead shot in cartridges used to shoot Red Grouse.  Lead has been legally banned from use in paint, water pipes, petrol and elsewhere for many years due to its known toxicity to humans and proven very significant health hazards. 

 

Economy

 

  1. Costs to society and the economy include:

.

  1. Claimed figures of the economic benefits attributable to driven grouse shooting are unverifiable and have been strongly criticised for flawed methodologies, lack of transparency and over-estimation of claimed benefits (http://www.league.org.uk/~/media/Files/LACS/Publications/Cormack—Rotherham-2014-Review—of-the-PACEC-2006-and-2014-reports-on-sport-shooting-impacts-MAIN-REPORT.pdf).

 

  1. Driven grouse shooting is a rich person’s hobby that benefits already rich people and impoverishes the English uplands and everyone else.

 

 

  1. Whatever the actual benefits, if there are any, from driven grouse moor management actually are to society they are clearly significantly outweighed by its costs to society.

 

 

Recommendations for action by the Government

 

  1. The Government should ban driven grouse shooting as soon as possible. The mismanagement of the English uplands solely to produce large numbers of Red Grouse for a few people to shoot is unambiguously proven.

 

 

October 2016