The Scottish Government on the use of snares and increased SSPCA powers

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

We recommend answering YES. Points you may wish to include:

• Your thoughts on the cruel nature of these traps.
• It is a good use of this bill to ban them.

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

We recommend answering YES. You might want to highlight the following:

• You might suggest that the Scottish Government should apply the International consensus principles of ethical wildlife control for all wildlife management.
• There is an absence for the ethics behind trapping and killing animals to maximise the number of grouse to be shot for entertainment (‘Killing to Kill’).
• Due to the lack of regulation, non-target species are found in traps and snares.
• The option of banning snares at stage 2 is welcomed.
• Additional comments you have about banning snares in line with most other European nations.
• There should be an obligation to report on the number and species of animals killed in traps in the bill.
  
  

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

We recommend answering YES. In addition, you might want to discuss your views on the following:

• A Statutory training scheme administered by NatureScot is a better alternative to an industry led scheme, but 10 years refresher is too long.
• Animal welfare considerations should be integrated into the scheme, for example the 7 ethical principles for wildlife control mentioned above, and the need to use methods that cause less suffering.
• Monitoring traps should be carried out effectively at no cost to the public – with full cost recovery.

We recommend answering YES. In addition, you might want to discuss your views on the following:

• Raptor persecution on or around shooting estates have continued for decades and voluntary codes of conduct have failed to slow the killings.
• Licences should only be administered to specific individuals and not to trusts and companies to ensure better success in the licencing scheme.
• The licence should require full reporting on the use of medicated grit.
• A condition in the licence should be to obtain data on the number of grouse shot and the number of species of animals killed by all methods of predator control.
• Lists of wildlife crime offences should be considered for licence removal.
• We agree that a five yearly survey of keystone raptor species should be undertaken and included in this legislation and its cost included in the licencing fees.

We recommend you answer YES: You might want to highlight your views on the following:

• If the system devised by NatureScot is adequately funded to ensure full compliance.
• We recommend a licence fee that would recover the full cost of licencing and compliance monitoring.
• A named person should be responsible for holding the licence to avoid loopholes.

We recommend you answer YES. You might want to discuss your views on:

• The additional expertise from Scottish SPCA to help tackle wildlife crime would help assist and increase effective monitoring for reducing wildlife crime.

We recommend you answer YES. You might want to discuss your views on the following:

• Muirburn on grouse moors is damaging to our environment, threatens opportunities for greater biodiversity and disturbs local wildlife.
• We must protect public investment in peatland restoration. Burning puts peatlands at risk of not performing some of their vital functions - rewetting and sequestering more carbon.
  

We recommend you answer YES. You may wish to discuss the following:

• Should a licence to muirburn be given for the purpose of grouse shooting?
• Muirburn season ending on 15^th April is welcomed. BUT we think it should go further back to the end of march for ground nesting birds, climate change and the risk of wildfires.
• The definition of peat should be defined as 30cm in depth instead of 40cm.  An altitudinal limit should be considered to prevent burning on shallow and sensitive peatlands at higher elevations and which are at risk of erosion.
• We suggest the legislation requires that all alternative solutions (such as cutting) have been explored to the satisfaction of NatureScot before using fire as wildfire suppression technique is licenced.