Before Changing Grouse Moors, Show the Evidence for the Alternatives
Quick summary
The RSPB says its reserve bird data cannot show trends. We have asked what data it uses instead.
We asked how the RSPB judges whether its upland reserves are working for birds such as curlew.
If grouse-moor management changes, grazing, predator management and other land management change too, and need evidence.
The same standard of evidence should apply to all forms of upland management, including the alternatives.
The Moorland Association is currently preparing its response to Defra’s Call for Evidence on gamebird shooting.
In doing so, we believe it is important to consider not only the impacts of the management that exists today, but also the likely consequences of changing it.
If grouse-moor management is reduced or altered, what happens next? What happens to predator management, grazing and vegetation management? And what evidence shows that the alternative will deliver better environmental outcomes?
These questions matter because policy change has consequences of its own. The relevant comparison is not between the present system and an idealised alternative, but between realistic management systems and the outcomes they actually deliver.
As part of our work for Defra, the MA has therefore been looking at publicly available evidence that might help answer that question. One obvious source is the RSPB’s own reserve network.
The RSPB manages extensive areas of upland habitat and publishes Annual Reserve Avian Monitoring data through the NBN Atlas.
Last month we explained that, as part of this work, we had examined the RSPB’s Annual Reserve Avian Monitoring data and written to RSPB Chief Executive Beccy Speight.
We asked how those published data should be interpreted, what fuller monitoring information the RSPB holds, and how it assesses whether management on its own upland reserves is delivering the intended outcomes for birds. We said we would update members when the RSPB replied.
What the RSPB has confirmed
It has stated that the NBN figures are year-specific counts for individual RSPB reserves. But it has also said that its published data are not appropriate for trend analysis, because survey methods may differ between sites, sensitive-species data may be withheld or published at reduced resolution, and the area surveyed may change over time.
That raises a central question.
If the published data cannot show trends, what evidence does?
If the public monitoring data from the RSPB’s own reserve network cannot be used for analysis, what data and methodology does the RSPB itself use to determine whether management on its upland reserves is delivering the intended outcomes for bird populations? That is now the central question in our follow-up letter.
We have asked whether the RSPB holds more complete reserve-level monitoring data, whether the NBN Atlas represents its complete Annual Reserve Avian Monitoring record, whether more recent data are available, and how missing and presence-only records should be interpreted.
We have also asked what species-specific objectives, baselines, benchmarks and other measures the RSPB uses to judge the success of its upland management, and whether it has undertaken its own analysis of changes in species including curlew, golden plover, red grouse, black grouse, snipe and ring ouzel.
The missing comparison
The RSPB has also suggested that comparisons between species abundance under different land uses are “somewhat tangential” to Defra’s current Call for Evidence.
That may be a narrow reading of the questions Defra has asked, but it cannot be the end of the evidential exercise if the findings are subsequently used to consider policy change.
If changes affecting grouse-moor management are being considered on environmental grounds, the proper policy comparison is not between the existing system and an assumed or idealised alternative. It is between real-world management systems and the outcomes they actually deliver.
If game management changes or ceases, other things may change too: grazing, predator management, vegetation management, rewetting, forestry, public access, monitoring and conservation expenditure. Those consequences form part of the environmental outcome and need to be evidenced.
Those advocating change therefore have a responsibility to be transparent not only about any problems they identify in the present system, but also about the evidence for what is likely to happen next.
The same standard for everyone
The MA is not arguing that game management should escape scrutiny - but the alternatives advocated in its place should be subjected to exactly the same scrutiny.
The same evidential standard should apply to all forms of upland management.
If one system is challenged on the basis of measured outcomes, another should not be preferred on the basis of assumed benefits.
That is why the counterfactual matters. Before major changes are made to the management of England’s uplands, policymakers and the public should be able to see not only the evidence about the system being changed, but also the evidence about what is likely to replace it.
Following the evidence
We are not seeking to attribute changes in recorded bird numbers to RSPB management using data that the RSPB itself says are unsuitable for formal trend analysis.
Our question is simpler: what evidence is sufficiently robust to assess outcomes, and is the same standard being applied to all the alternatives being considered?
That is the question we have now put back to the RSPB.
For transparency, we are publishing the correspondence and our methodology so members and others can see the exchange in full.
