Peter Clark on why Scotland’s effective General Licence system needs targeted practical updates rather than an overly bureaucratic overhaul, and what BASC has put to NatureScot
General licensing does a simple job well. It lets a keeper deal with a magpie raiding a nest, or a farmer with geese in a barley field, there and then, rather than waiting for paperwork while the damage carries on. That’s why, when NatureScot’s consultation on Scotland’s General Licences closed on 31 August, our response was clearly stated. The system works well in principle, so improve it, don’t replace it.
We say that because General Licences let gamekeepers, farmers, shoot managers, pest controllers and other land managers respond quickly where the legal tests are met, rather than waiting for a bespoke licence for every routine case. Move that work on to individual licences instead and the result will be lost crops, increased disease risk, avoidable impacts on livestock or missed opportunities to protect nesting birds when intervention is most needed.
For BASC members, the three licences that matter most are GL01, GL02 and GL03, covering the conservation of wild birds, the prevention of serious damage and the protection of public health and safety. These issues arise regularly across farms, shoots, fisheries, holdings and rural businesses, which is borne out in what our members say.
A survey we ran over the past couple of months to inform our response to NatureScot backs this up. Of 150 members who answered a question on the essential requirements of General Licences, 91% pointed to being able to proactively prevent serious problems caused by wild birds, 89% to population control of problem species, 86% to conservation and 85% to being able to react quickly to damage as it happens.
One of the sharper questions in the consultation asked whether every General Licence should carry a mandatory condition to report what’s been done under it each year. Our answer is no. Reporting as a blanket condition would create an administrative burden without necessarily producing reliable or meaningful data.
We’re not rejecting monitoring outright, and we appreciate that reliable information can help demonstrate that licences remain justified and targeted. But any reporting condition needs to earn its place. It should be necessary, risk-based, proportionate and demonstrably able to improve decision-making. Our preferred route is a well-designed voluntary or sample-based system for specific licences, not a universal requirement applied across the board.
We’ve also pushed for a handful of practical improvements. Top of the list is extending the licence period from one year to two, in line with NatureScot’s own multiyear goose schemes and the two-year licences Defra issues in England. In addition we have flagged the need for clarity on why designated sites carry a 500m buffer, guidance on what to do if a protected species turns up unexpectedly in a trap, and confirmation that operators won’t be marked as being non-compliant just for being unable to recite a licence from memory, so long as its conditions are genuinely being met. We have also proposed widening GL01 to cover several gull species, ravens and ring-necked parakeets for conservation purposes. Those are just some of the main points we put to NatureScot.
None of this is about defending the status quo for its own sake. It’s about recognising that a system built around timely, local decision-making helps the farmers and land managers who rely on it, just as much as it supports the conservation outcomes it’s designed to protect. Get the detail right on returns, licence length and species, and general licensing can keep doing that job for years to come. That’s the case BASC has put to NatureScot – and we’ll keep making it.
Peter Clark is BASC’s director of Scotland. He can be contacted at peter.clark@basc.org.uk.
They are the three General Licences that matter most to BASC members: GL01 covers the conservation of wild birds, GL02 the prevention of serious damage, and GL03 the protection of public health and safety. They let a land manager act at once where the legal tests are met, rather than applying for an individual licence each time.
To extend the licence period from one year to two, to explain why designated sites carry a 500m buffer, to give guidance on a protected species found unexpectedly in a trap, to confirm that not reciting a licence from memory is not non-compliance, and to widen GL01 to several gull species, ravens and ring-necked parakeets for conservation purposes.
That was one of the consultation questions. BASC’s answer is no as a blanket condition, on the grounds that it would create an administrative burden without necessarily producing reliable data. Its preferred route is a voluntary or sample-based system for specific licences instead.
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