Dave Windle

Evidence Submitted to the Scientific Advisory Sub-Committee on Sustainable Moorland Management

NEMT submitted a package of evidence that was essentially the Adam Watson data referred to in the previous issue together with some additional details on count areas, etc.

The sub-committee is due to report back in March. We're still waiting as we go to press.

Reply from Janez Potocnik - European Environment Commissioner

In the last issue, I reproduced the letter that I wrote to Ian Hudghton, our local MEP. Janez Potocnik, the European Environment Commissioner, sent this back as a reply.

Dated 24th September 2014

Dear Mr. Hudghton,

Thank you for your letter of 14th August, which sets out concerns about the excessive culling of mountain hares (Lepus Timidus) in Scotland.

The mountain hare is listed in Annex V of the Habitats directive, which provides for species of community interest whose taking in the wild and exploitation may be subject to management measures. This means that the capture and killing of the species is not prohibited but the Member State must ensure that any exploitation or control of the species is compatible with it being maintained at a favourable conservation status.

The latest national report under Article 17 of the Habitats Directive from UK in 2013 assessed the conservation status of this species, which occurs in England, Scotland and Northern Ireland as being in favourable status in UK with no negative trends. The findings seem to be based on a variety of published sources including reports from Scottish Natural Heritage (SNH). The Commission has in June and July 2014 carried out a public consultation on the finding of its EU-wide status assessments and no comments were received on this species. You can find the UK report on this species on the Joint Nature Conservation Committee's website.

I am aware that there is controversy over the management of certain grouse moor estates in UK in terms of alleged inappropriate management of certain habitats, illegal persecution of birds of prey (especially the hen harrier) and - as you now suggest - cases of excessive control of mountain hares.

The Commission has already raised the issue of the burning of moorland linked to grouse management and its implications for the conservation of blanket bog protected habitats. If the Commission is presented with clear evidence of a breach of implementation of the Birds and Habitats Directives linked to grouse moor management, it will also raise the matter with the UK authorities.

However, I would encourage your constituents to continue to liaise with SNH and other relevant authorities in Scotland in relation to the concerns they have raised, especially to ensure that there is a robust and objectively verifiable monitoring system in place for the mountain hare.

Yours sincerely, Janez Potocnik

The first point of note is that the letter shows an awareness of the problems created by modern intensive management of grouse moors. This is positive as it indicates that should/when we wish to complain further, the door is already open to a certain extent. Two points in the letter are worthy of comment.

We discussed whether to respond to the offer of submitting clear evidence. We believe that Adam Watson's data referred to above would provide suitable clear evidence. However, we decided that it would be better to wait until the SNH SAC sub-committee produces its report in March. This report has the potential to be very significant. We will have a better case to present to the EU if we are seen as trying to work with the national agencies rather than sniping at them.

Parliamentary Questions

We have also raised two Parliamentary Questions. Alison Johnstone, the Scottish Parliament species champion for brown hares, was prepared to be broad minded on the question of colour. Our hares are, of course, blue hares. She, and her team, have been very helpful. I set out below the two questions and their answers.

Question S4W-23614

To ask the Scottish Government when the Scottish Natural Heritage Scientific Advisory Committee sub-group on sustainable moorland management will (a) complete and (b) publish its report.

Reply: The Scottish Natural Heritage Scientific Advisory Committee plan to consider their report in March and to publish shortly thereafter.

Question S4W-23615

To ask the Scottish Government, further to the answer to question S4W-18470 by Paul Wheelhouse on 4 December 2013, whether it will provide an update on the information regarding mountain hares.

Reply: Scottish Natural Heritage (SNH), the James Hutton Institute and the Game & Wildlife Conservation Trust, acting on the advice of several mountain hare experts, have started work on field trialling a range of methods of assessing mountain hare numbers, to develop a better monitoring strategy and to improve the quality of the information used to assess population status and the sustainability of hare management measures. This programme of work is due to be completed in 2017.

Until this study is complete, and because of recent concerns about the status of mountain hares, SNH has developed a joint position statement on the subject of hare culling following consultation with key stakeholders representing moorland managers, namely Scottish Land & Estates and the Game & Wildlife Conservation Trust. The statement is evidence-based and argues that large scale culls of mountain hares to reduce tick loads, and thus to benefit grouse and other bird survival, are only effective when other tick-carrying animals are removed as well, or where they are absent. The intention is to work with estates to put in place effective but sustainable management of mountain hares. More information about the joint position statement can be found on the SNH website.

In addition, a review of sustainable moorland management is currently being undertaken by a sub-group of experts from SNH's Scientific Advisory Committee chaired by Professor Alan Werritty. This includes the management of mountain hares as one of a number of issues connected with sustainable moorland management practices. This review is due to be completed by March 2015.

Earlier in 2014, SNH was provided with additional hare count data, collected over many years in some cases. These quantitative data are potentially very useful, as previous evidence of local declines was largely based on anecdote. This information has been made available to the above SNH Scientific Advisory Committee sub-group as part of the review process.

Since these questions, Claudia Beamish, has asked some further questions. These and their answers are set out below.

Question S4W-24504

To ask the Scottish Government how many prosecutions have been made under the habitats directive for offences relating to native mountain hares.

Reply: There has been one prosecution made under the habitats directive for offences relating to native mountain hares.

Question S4W-24505

To ask the Scottish Government how many mountain hares there are in Scotland.

Reply: The only published population estimate for mountain hares is now 20 years old and suggested that there were 350,000 mountain hares in Scotland, but this estimate had large error margins attached to it (+/- 50%). Furthermore, it pre-dates the trend over the past 10-15 years towards intensive culls on some grouse moors that can result in locally depleted hare populations. Furthermore, caution is needed when interpreting indices of population density especially for species such as mountain hares that show population cyclicity.

Population trend data are available from two independent sources: the Game and Wildlife Conservation Trust National Gamebag Census data from 1995 to 2009 indicate a 36% decline in the index of mountain hare numbers, while the British Trust for Ornithology Breeding Bird Survey data suggests a decline of 26% over the same period. When combined these indices give a statistically significant decline of 28%, (see JNCC)

Scottish Natural Heritage, the James Hutton Institute and the Game and Wildlife Conservation Trust, acting on the advice of several mountain hare experts, have started work on field trialling a range of methods of assessing mountain hare numbers, in order to develop a better monitoring strategy and to improve the quality of the information used to assess population status and the sustainability of hare management measures. This programme of work is due to be completed in 2017.

Question S4W-24506

To ask the Scottish Government what research it has carried out into diseases that mountain hares may carry.

Reply: A study by Laurenson et al. (2003), which was part-funded by the Natural Environment Research Council (NERC) and the then Scottish Executive Environment and Rural Affairs Department (SEERAD), focused on how culling mountain hares can reduce tick burdens and louping ill virus (LIV) seroprevalence in red grouse. The study site, however, was unusual with very high LIV seroprevalence levels in grouse, and an absence of red deer. A review of the evidence concerning mountain hare culling as a management tool to reduce louping ill in grouse was supported by NERC and the Scottish Government Rural Environment Research and Advisory Directorate (Harrison et al., 2010).

In addition, NERC has funded or part-funded research into mountain hare intestinal parasites and their potential impact on population dynamics (e.g. Newey et al., 2005). Another paper by Newey et al. (2007) was part NERC funded and part RESAS funded (among others) and discusses diseases in mountain hares. Other work funded or part-funded by the Scottish Government (or SEERAD or the Rural Environment Research and Advisory Directorate) has focussed on louping ill virus which mountain hares carry. This consists of both empirical and mathematical modelling theoretical studies. Several papers have been published, e.g. Gilbert et al. (2001).

As noted above, nothing new, but it's good to keep up the profile. We are currently working on a series of questions for Alison Johnstone once the moorland management committee releases its report. Raising the profile of this report will be important. It should also give us something to ask meatier questions on, requiring answers that are less bland - here's hoping!

Scottish Land & Estates Offer of Voluntary Restraint

Scottish Land & Estates is the estate owners' club and has obviously got somewhat worried at the bad press building up on the subject and has announced a voluntary restraint. The following is an extract from the SNH website:

Dated 23rd December 2014

SNH, GWCT and SL&E interim-position

We recognise there are genuine concerns being expressed about the status of mountain hares in Scotland, and we need to ensure that current hare management measures are not damaging their long-term prospects. As well as sustainable game shooting, we recognize that controlling mountain hares is a legitimate practice in certain circumstances: for example, to protect young trees or as a quarry species. Large-scale culls of mountain hares to reduce tick loads, in order to benefit grouse and other bird survival, will only be effective when other hosts are absent, or their ability to host ticks are similarly reduced. This will not be the case for many estates in Scotland.

On the basis of the available evidence, there is no compelling field evidence for undertaking large-scale mountain hare culls to control LIV in areas of Scotland where there are high densities of other tick-bearing mammals. Culls should therefore not be undertaken for this purpose in these circumstances.

We recognise that there are concerns about the potential negative impacts of culling on the resilience of mountain hare populations and other protected species. To this end we:

This position may change as a result of new research and the outcome of the SNH SAC review of sustainable moorland management.

Interestingly, I can't find anything on the SLE or GCWT websites.

It's not much, but it's a start. At least, they are starting to acknowledge that there might be a problem. Given the past performance of SLE on these sorts of issues, it might well be just window dressing and will have no impact on the ground. However, the mere fact that they acknowledge that the window needs to be dressed is a step in the right direction.

In passing, we should note that there is no scientific evidence that culling hares helps to increase grouse chick numbers!

Extract from SNH Website on New research

SNH is working with scientists from the James Hutton Institute and the Game & Wildlife Conservation Trust to trial methods of measuring mountain hare numbers to underpin better monitoring and to improve the quality of the information used to assess population status and the sustainability of hare management measures. The work will be carried out across three years to ensure a robust evidence-base, and is due to be completed in 2017.

We have been in touch with Glenn Iason and Scott Newey from the James Hutton Institute and expect to meet them in April to find out more about this work and how they will attempt to ensure that the inherent bias of the GCWT will be kept in control.

Help from South West Action For Hares

Our campaign has been getting support from afar. Rodney Hale of SWAFH has put out a petition, which is now up to 7427 signatures. He has plans to start generating publicity via social media, which should generate a lot more signatures. He has also written to Aileen McLeod and is planning to write to the EU. This is substantive help and much appreciated.

Roy Dennis' call for a Moratorium

Roy Dennis has issued a call, via the Raptor Persecution Scotland website, for a moratorium on all culling of mountain hares until the above work has been completed and we have a good idea of what the true situation is on mountain hare numbers. We believe that this is the right way forward and are already lobbying SNH to do exactly this. There is clearly common cause here and we have written to Roy to see if some form of joint action might be useful once the SAC report on moorland management is published.

Help Sought from Hillwalkers

I have written about this in the editorial and here are the links: SNH has announced on 5th March 2015 that it is looking for feedback from hillwalkers on large scale hare culls (which, of course, SLE has promised to stop!) - the details.

The press release asks people to contact if they see anything indicating that large scale culling is going on. Alternatively, you can directly email the SNH officer directly responsible for the issue on

I do feel that we're making progress.

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