National Wildlife Crime Unit: What Remains Unresolved
Why the Moorland Association is now publishing the correspondence
The MA continues to have unresolved concerns about how suspected wildlife crime, satellite-tag evidence and “hotspot” information are interpreted, communicated and attributed to individual estates.
We have spent almost two years seeking to resolve those concerns constructively with the police, including through a follow-up meeting which has still not taken place.
The NPCC is now due to release selected correspondence following an FOI request, so we are publishing the substantive record from both sides while continuing to seek resolution.
An update for Moorland Association members
For almost two years, the Moorland Association has sought privately to resolve a series of concerns about the approach of the National Wildlife Crime Unit (NWCU).
We deliberately kept the correspondence private while those discussions continued. However, on 7 September the National Police Chiefs’ Council (NPCC) informed us that selected extracts are due to be released following a Freedom of Information request.
We have therefore decided to publish the key correspondence from both sides, subject to appropriate redaction, so members can consider the exchanges in their proper context.
Our objective remains to resolve the outstanding issues constructively and restore an effective, evidence-led working relationship with the police.
How did we get here?
Members may remember that in July 2024 we raised concerns after the NWCU began approaching estates seeking permission to enter land and install cameras, proximity alarms and other monitoring equipment.
We questioned how these requests interacted with the normal safeguards surrounding police surveillance. The police subsequently emphasised that participation was voluntary.
Later that month, we informed members that the Moorland Association had been removed from the Bird of Prey Crime Priority Delivery Group after the relationship with the NWCU broke down.
Since then, we have repeatedly sought to resolve the underlying issues through correspondence and meetings rather than through public dispute.
In September 2024, those concerns were formally raised with DCC Harrison, as the national police lead for wildlife crime and rural affairs, with a request for a meeting and a constructive way forward.
What remains unresolved?
It is important to be clear that the Moorland Association condemns wildlife crime and supports its proper investigation and prosecution. Our concerns are about how evidence, intelligence and suspicion are interpreted and communicated, and about the safeguards surrounding information which may affect individual estates and the wider upland community.
The principal issues which remain unresolved are:
Crime, suspicion and unexplained incidents: we want a clear distinction between a proven offence, a suspected offence, intelligence, statistical association and an unexplained satellite-tag loss. We remain concerned that these categories have sometimes been blurred in police communications.
“Hotspot” terminology: the NWCU has described individual estates or areas as hotspots for suspected hen harrier crime. We have repeatedly asked for the definition, evidential threshold and methodology behind those designations.
Attribution to individual estates: we remain concerned about incidents being associated with estates where a bird was last recorded many kilometres away, or had already left the land concerned.
Transparency and contrary evidence: the MA has supplied satellite-tag and locational evidence showing that final transmissions and clusters also occur away from driven grouse moors. We want to understand how contrary or qualifying evidence is taken into account.
Surveillance and voluntary engagement: estates have been asked to permit cameras, monitoring equipment and police activity on their land. We accept that such cooperation can be requested voluntarily, but remain concerned about whether the purpose, safeguards and consequences have always been explained clearly enough.
Communications with land managers: we remain concerned about language which can imply established criminality while, in some instances, simultaneously acknowledging that there is no evidence against the individuals or estates concerned.
Information supplied to government: Defra is currently gathering evidence on gamebird rearing, release and shooting. The police have also confirmed that the work of the satellite-tagged bird-of-prey taskforce could form part of a future police response should Defra consult on gamebird shooting. We want assurance that any such material is properly validated and qualified, that suspected or unexplained incidents are not presented as established criminality, and that relevant contrary evidence is included before it is used to inform policy or regulatory decisions.
Governance and accountability: after almost two years, we still do not have a consolidated written response to the principal concerns originally raised with senior police leadership.
These are the issues we have been trying to resolve. The correspondence published below shows both the concerns themselves and the efforts made to address them..
What happened after those concerns were raised?
On 4 September 2025, the Moorland Association Chair and Chief Executive met Deputy Chief Constable (DCC) Nigel Harrison, the national police lead for rural and wildlife crime, and Chief Inspector (CI) Kevin Lacks-Kelly, Head of the NWCU.
A follow-up meeting between the Moorland Association and the NWCU was proposed so that the issues raised by both sides could be worked through, factual inaccuracies corrected and genuine areas of disagreement identified.
In December 2025, the police sent us the terms of reference for the Tactical Delivery Groups, together with material from the 4P plan for Bird of Prey Crime (covering Pursue, Prevent, Protect and Prepare), including the proposed accountabilities for NGOs.
We replied the following day, saying that the documents would be put to the Moorland Association Board “for consideration”. We also confirmed our willingness to meet CI Lacks-Kelly and work through the outstanding issues.
The proposed follow-up meeting did not take place. The MA sought to progress it again in May and June 2026.
Importantly, in his response on 18 June, Sergeant West recorded his own understanding that an MA representative would meet CI Lacks-Kelly to look at “the issues raised on both sides” against the aims of the group and the rural and wildlife crime strategy. That was substantially the same understanding of the proposed meeting that the MA had been expressing.
Why did we write again in August?
By August 2026, the substantive concerns remained unresolved.
We had also become concerned that information arising from the NWCU’s “hotspot” work might be supplied to Defra before questions concerning its methodology, validation and presentation had been resolved.
That concern is now particularly relevant because Defra is conducting a Call for Evidence on gamebird rearing, release and shooting in England. The police have separately confirmed that the work of the satellite-tagged bird-of-prey taskforce could form part of a future police response should Defra consult on gamebird shooting.
We are therefore concerned that unresolved assumptions or disputed methodology could ultimately influence government evidence-gathering or policy before they have been properly tested.
Until these issues are resolved, we believe disputed hotspot material or conclusions should not be supplied to Defra without appropriate senior review, validation and qualification.
We therefore asked, amongst other things, for clarification of what constituted a “hotspot”, how confirmed crime was distinguished from suspected crime and unexplained incidents, how the information was validated, and what safeguards would apply before material derived from that work was supplied to Defra or used to inform government policy.
We also again asked for the follow-up meeting.
The police response
On 3 September, North Wales Police responded on behalf of DCC Harrison. The letter provided some useful clarification. In particular, it confirmed that the particular hotspot report about which we had expressed concern had not been submitted to Defra.
It also confirmed that the NWCU provides Defra with quarterly stakeholder updates and said that work undertaken by the satellite-tagged bird of prey taskforce could form part of a future police response should Defra consult on gamebird shooting.
We welcomed those clarifications. They are useful, but they do not resolve the central questions above about methodology, terminology, attribution, validation and governance.
However, the letter also stated that the MA had not responded to an action concerning the 4P plan and that correspondence in December 2025 seeking to facilitate the follow-up meeting had not been answered until May 2026. It also said that the police considered several of our concerns to have been addressed at the September 2025 meeting.
What do the December emails show?
The proposed FOI disclosure includes the December emails exchanged at the time. They show:
2 December 2025: the police wrote to the MA.
3 December 2025: the MA replied — the following day.
In that reply: we said the 4P documents would be put to the Board “for consideration” and confirmed our willingness to meet.
Those emails therefore do not appear to support the suggestion that no response was received until May 2026.
There is another important distinction.
The December police email did not simply ask for our availability. It said that, for the NWCU to work with the MA, it would seek acknowledgement of the terms of reference and agreement to the “NGO accountabilities” in the 4P plan (the responsibilities proposed for non-governmental organisations participating in the group). It also said that removal of an MA blog and recognition that it was “fundamentally incorrect” were required before the proposed meeting could take place.
Our concern was that this effectively required the MA to concede one of the disputed issues before the meeting intended to resolve those disagreements had even taken place. We considered that disputed factual statements should instead be worked through as part of the proposed meeting, with inaccuracies on either side corrected where the evidence justified doing so.
What was agreed about the 4P plan?
For the avoidance of further misunderstanding, the Moorland Association did not understand that it had agreed at the September 2025 meeting, as an action arising from it, either to acknowledge the TDG terms of reference or to identify which elements of the 4P plan it would support.
The documents were subsequently received and our response said that they would be placed before the MA Board “for consideration”, rather than recording any agreement to them.
We have therefore asked the police that, if they maintain that such an action was expressly agreed at the September meeting, they provide the agreed minute, action note or other record supporting that account.
Why are we publishing the correspondence now?
We had hoped to resolve these matters privately. The proposed FOI disclosure means that selected parts of the correspondence are now due to enter the public domain.
We therefore believe members should be able to see the substantive correspondence from both sides and consider the record in its proper context.
Read the correspondence
Members do not need to read every document to understand the concerns set out above; they are provided so that anyone who wishes to examine the underlying record can do so.
Background
July 2024 – MA raises concerns about police surveillance requests
The Association explains its concerns after estates were approached about the installation of cameras, proximity alarms and other monitoring equipment, and asks how these requests sit alongside the normal safeguards governing police surveillance.
July 2024 – MA removed from the Bird of Prey Crime Priority Delivery Group
Following the breakdown in relations with the NWCU, the Association updates members on its removal from the group and explains the concerns it had raised about surveillance, police language and the distinction between suspicion and established crime.
The concerns and attempts to resolve them
2024 – MA first raises its concerns formally with senior police leadership
The Association sets out the concerns it wishes to resolve following the breakdown in relations with the NWCU.
August 2025 – MA consolidates its eight principal concerns
The Association sets out its eight outstanding concerns, including crime terminology, surveillance, transparency, hotspot methodology and satellite-tag evidence.
2-3 December 2025 – Police send the TDG terms and 4P material; MA replies the following day
The police supply the TDG terms of reference and proposed NGO accountabilities. The MA says the documents will go to its Board “for consideration” and confirms its willingness to meet.
May–June 2026 – MA repeatedly seeks the follow-up meeting
The MA asks for the meeting to be progressed. On 18 June, Sergeant West confirms his understanding that the proposed meeting was intended to look at the issues raised “on both sides”.
The latest exchange
14 August 2026 – MA seeks senior intervention over unresolved concerns and potential information supplied to Defra
With the concerns still unresolved, the Board asks DCC Harrison to exercise oversight and arrange the follow-up meeting.
3 September 2026 – North Wales Police responds
The police provide some useful clarification, including confirmation that the particular hotspot report about which the MA had expressed concern had not been submitted to Defra. The response also sets out the police position on the 4P plan, the December correspondence and the outstanding concerns.
7 September 2026 – MA asks for correction of the record and for the meeting to proceed
Following receipt of the proposed NPCC Freedom of Information disclosure, the Association writes again to DCC Harrison. The letter highlights discrepancies between the recent police account and the correspondence exchanged at the time, asks for the record to be corrected where necessary, and again proposes a constructive follow-up meeting.
The satellite-tag evidence
One of the underlying issues concerns what can, and cannot, safely be concluded when a satellite tag stops transmitting.
The MA has published its own register and methodology so that its analysis can be scrutinised and challenged. It is MA analysis, not a peer-reviewed finding. Our position is straightforward: important conclusions should be open to scrutiny, whoever holds the evidence.
What happens next?
On 7 September, we asked DCC Harrison personally to consider the position and provide proposed dates within five working days for the follow-up meeting.
We have suggested a straightforward purpose for that meeting: establish what can be agreed, correct factual inaccuracies on either side, identify information which can properly be shared, and clearly record those issues on which genuine disagreement remains.
The Moorland Association remains entirely willing to correct anything we have said which can be demonstrated to be factually wrong. We have asked the police for the same approach.
We will update members when we receive a substantive response.
