SLE rejects annual returns plan in general licence review

Scottish Land & Estates (SLE) has told NatureScot that mandatory annual returns for every general licence user would add unnecessary administrative burden for rural businesses, as the first phase of the regulator’s review of Scotland’s general licences closed on Monday (31 August). The organisation’s consultation response defends the existing framework as proportionate and challenges the basis on which restrictions are imposed on individual landholdings.

What is SLE objecting to?

For the first time, NatureScot proposes making annual information returns a condition of using all general licences, which permit wildlife management for purposes including preventing serious damage to livestock or crops, preserving public health or safety and conserving wild birds.

Nadia Flaherty, policy adviser for wildlife management at SLE, said: “NatureScot has not demonstrated a clear regulatory need for annual data returns. This requirement would create a significant additional burden for rural businesses, farms and estates, undermining what has always been a simple and proportionate scheme enabling lawful activities to be undertaken. Pest and predator control is an inherently reactive exercise, and we do not believe the proposal to submit returns is practical or reasonable.” SLE adds that mandatory returns could increase the risk of data being misused.

The restriction question

The response also questions NatureScot’s approach to restricting general licence use on particular land. “NatureScot’s ability to restrict the use of General Licences appears to rest on a flawed assumption – namely that location equals causation,” Ms Flaherty said. “In other words, there is no requirement to link evidence found on a particular site to a relevant person or persons. We do not believe such an approach is consistent with the principles of good regulation. NatureScot should ensure that consideration of evidence that an alleged crime was carried out by the owners or managers of that land is compulsory, rather than optional.”

NatureScot used those powers last month, restricting general licences on land in Angus and Perthshire following police evidence of raptor persecution.

Why do general licences matter on shoots?

Legal corvid control under the general licences protects vulnerable species including ground-nesting birds, SLE says, alongside its role in protecting crops and livestock. “The existing regulations are proportionate and are delivering important outcomes for rural Scotland,” said Ms Flaherty. “Land managers already navigate a wide range of complex licensing and regulatory requirements linked to rural business activities, so significant changes to the General Licence framework would create additional and unnecessary administrative pressure.” Five reviews and public consultations on the scheme have already been carried out since 2011, in 2011, 2012, 2013, 2016 and 2019.

How does BASC’s response compare?

BASC has published its own submission to the review, backing the continuation of the general licensing system but opposing mandatory reporting as a blanket condition, which it says would add administrative burden without producing reliable data. The association recommends extending licence validity from one year to two and retaining every species currently listed on the licences.

It also wants species added: herring, great black-backed, lesser black-backed and black-headed gulls, raven and ring-necked parakeet to the conservation licence GL01; barnacle goose, red-breasted merganser, goosander, cormorant, raven and ring-necked parakeet to the serious-damage licence GL02; and jackdaw, herring gull, lesser black-backed gull and common gull to the public health and safety licence GL03.

What happens next?

The first-phase consultation on the 16 general licences proposed for 2027 closed on 31 August. NatureScot will now analyse responses, with the British Association for Shooting and Conservation (BASC) and the Scottish Countryside Alliance among the other organisations to have submitted, before settling the licences to take effect in 2027. SLE’s full response is available from the organisation.