Our response to the Wildlife Management Bill

In response to the questions laid out in the recent Wildlife Management & Muirburn (Scotland) Bill consultation, we have submitted the following responses and recommendations. We have inserted headings to demarcate particular topics discussed:

GLUE TRAPS

Q1. Do you agree with the proposed ban on the use and purchase of glue traps (sections 1-3)?

 We welcome the inclusion of a prohibition on the use and sale of glue traps in Scotland. Glue traps are an indiscriminate form of trap which cause an unusually cruel slow and painful death over days as a result of asphyxiation, starvation, exhaustion, or vulnerability to predation. This form of entrapment causes extreme panic which exacerbates the cruelty of this form of trap. Animals will often tear their flesh, feathers or fur trying to escape, adding to their already significant suffering. We are pleased the Scottish Government shares this view and urge Members to approve.

The sole amendment we would seek in the first three sections is in Section 2 Subsection (2) where sale (or acquisition) of glue traps is permissible for use outside Scotland or for delivery outside Scotland. At a time when Scotland and the UK are re-assessing the behaviour of citizens abroad in relation to e.g. trophy hunting and the ethics of our citizens footprint abroad in terms of animal welfare, we see no justification for this clause other than to protect commercial interests. Moreover, if sale or acquisition is permissible for any reason, it heightens the likelihood of illegal use domestically and would therefore urge the committee to remove 2(2), sections (a) and (b).

WILDLIFE TRAPS

Q2. Do you agree there is a need for additional regulation of the use of certain wildlife traps? 

Yes.

Q3. Do you agree with the proposed licensing system for the use of certain wildlife traps (sections 4-5)? 

 We fully support the introduction of licensing for the use of traps particularly where they may be lethal. It should be of great concern that at present there is little oversight or regulation in relation to the use wildlife traps and the introduction of a licensing system should not be viewed as a layer of bureaucracy rather an overdue layer of animal welfare protections.

The Bill in its current form includes extensive criteria against which the licensing of certain traps would be adjudged against. Whilst we do not object to these criteria in principle, we would remind Members of the principles of ethical wildlife management which if encoded in law would provide for a more rigorous framework. The internationally agreed principles ask questions the Bill does not appear to such as, are there alternatives. We strongly urge the committee to consider this an opportunity to encode the ethical principles in law and afford it due discussion.

Our focus in terms of Q.3 is in relation to the use of snares. This Bill provides the Scottish Parliament with an opportunity to explicitly prohibit their sale and use in Scotland. We would draw the committee’s attention to the rationale behind prohibiting the use of glue traps and suggest most if not all the arguments the Scottish Government has deployed for illegalisation apply equally to snaring. These include their indiscriminate nature and prolonged suffering before expiration.

Lastly, Members will be aware that by finally prohibiting the use of snares Scotland would be falling in line with the work of the Senedd in Wales and most European countries.

LICENSING SCHEME FOR LAND USED TO SHOOT RED GROUSE

Q4. Do you agree there is a need for additional regulation of land to be used to shoot red grouse? 

As an animal welfare charity we make the overarching point at this juncture that we oppose breeding and/or killing animals for ‘sport’ which is how we characterise grouse shooting. Moreover, we strongly object to further animals being killed under the auspices of ‘land management’ to safeguard more economically valuable animals, including game birds, such as red grouse. Animal Concern opposes grouse shooting in principle.

Q5. Do you agree with the proposed licensing system for land to be used to shoot red grouse (sections 6-7)?

We reiterate our response to Q4 that shooting for sport should have had its time. If shooting for sport is to continue, we would support a licensing scheme as a minimum. We ask that the licensing scheme adopts the approach that all is prohibited except that which is specifically and explicitly permissible rather than being open ended. Additionally we would ask that the cost of a genuine application process, rather than an administrative exercise, is borne by applicants.

ADDITIONAL POWERS TO INVESTIGATE WILDLIFE CRIME

 Q6. Do you agree with the proposal to give the Scottish SPCA additional powers to investigate wildlife crime (section 8)? 

 We fully support proposals to give additional powers to investigate wildlife crime to the SSPCA in respect of wildlife crime. We would suggest should additional resourcing be deemed a prerequisite to fulfil additional statutory duties that Members urge Ministers to ensure they accompany any extended powers. We would also remind Members that where an animal, grouse or otherwise, is found dead the SSPCA cannot investigate even where circumstances provide prima facie evidence of a crime. This section of the Bill provides a clear opportunity to address this oversight.

LICENSING SCHEME FOR MUIRBURN

Q7. Do you agree there is a need for additional regulation for muirburn?

 We refer Members to the response from the REVIVE coalition.

Q8. Do you agree with the proposed licensing system for muirburn (sections 9-19)? 

We refer Member to the response from the REVIVE coalition.

We will be keeping our members and supporters in the know about how they can follow the progress of this Bill and at what point they can call on their MSP to support our proposed amendments.