Scottish Natural Heritage (SNH) has announced the start of its consultation for General Licences 2014. The consultation, which closes on 18 November, proposes certain changes, some of which have caused concern among gamekeepers.

One of the most significant points in the consultation document is the question of General Licences and raptor persecution, which states: “In July this year, Paul Wheelhouse, minister for environment and climate change, directed SNH as the licensing authority,‘to examine how and in what circumstances they can restrict the use of general Licences to trap and shoot wild birds on land where they have good reason to believe that crimes against wild birds have taken place.’ Presently, we are examining how we might take forward this direction for 2014 with input from the police and Scottish Government.”

Shooting Times spoke to the Scottish Gamekeepers Association (SGA), which said that it had met with representatives of SNH at Battleby, near Perth, on Tuesday, 22 October. The SGA told Shooting Times that the principal concern of the organisation remains the potential restriction of a General Licence where there is “good reason to believe that crimes against wild birds have taken place”.

The potential change announced by Paul Wheelhouse MSP in July is a further bid to tackle persecution of birds of prey, despite poisoning now standing at its lowest recorded level in Scotland.

SGA chairman Alex Hogg told Shooting Times: “We have made it clear to both the minister and to SNH that we feel ‘good reason to believe’ something is happening, or not, is not in any way a legally sufficient basis upon which to make such a major decision, such as withdrawing or withholding a General Licence from someone.

“We have seen only recently how investigations can be imperilled by those who may have a particular agenda. For someone’s livelihood, and potentially their ability to look after their families, to be taken away on a suspicion does not stand up to scrutiny. Wildlife will also suffer because it will restrict legal predator control and the important habitat work which has been scientifically proven to benefit threatened groundnesting birds and other fragile species, such as red squirrels.

“Unless the standard of proof required is appropriately robust, there is a real danger for this to have negative consequences which may not have been the initial intention.

There is also an increasing likelihood that it will be abused by activists who will see it as a green light to try to undermine legitimate estate work.

“At present, if someone is convicted by legal means in a court of law, then it is right that they have to deal with the consequences and we feel this is the standard of proof which should be maintained.

“There is also the further issue that a decision based on ‘good reasons to believe’ may not actually stand the legal test so there is a lot of work that must be done here before the Government has a policy that will work.

“If it doesn’t achieve that, it will lead to an erosion of trust between the gamekeeping community and land management sector, which would be a big step backwards for relations, jobs and wildlife.”

To read the consultation and submit your comments, visit