This wonderful, heartfelt Open Letter to Defra Ministers from Steve Downing, Chairman of the Northern England Raptor Forum (NERF), is published in full below with Steve’s permission, but you can see the original, and find out more about the tireless work of NERF on their website here.
Open Letter to Defra Ministers
Dear Minister Reynolds
“Don’t it always seem to go that you don’t know what you’ve got ‘til it’s gone.”
Mitchell 1970.
These words were written to reflect man’s indifference to the consequences of the selfish negative actions and impacts on the environment and the creatures that we share it with. They would fit perfectly on a memorial to the slaughter of Hen Harriers that has taken place, and continues to take place on land managed for grouse shooting in the northern uplands of England over many decades.
Despite, theoretically benefiting from the highest level of legal protection for the past 70 years, Hen Harriers remain the most persecuted bird in the UK. Many £millions of public monies, our money, has been spent by Government, Police and other public bodies including National Parks, AONBs / National Landscapes and charities including RSPB, Wildlife Trusts, National Trust. NERF Raptor Workers have committed 10s of thousands of volunteer hours to protecting Hen Harriers both during the breeding season and whilst they occupy winter roosts. In addition, many, many more £millions have been spent paying subsidies to millionaire and billionaire landowners to manage Protected Landscapes that are supposed to provide a safe sanctuary for Hen Harriers and other birds of prey. All for what?
The real tragedy is that everyone involved in monitoring and protecting Hen Harriers and many, if not most, of the people involved in the shooting industry across the North of England, know what the problem is and who is responsible. Yet it remains almost impossible to acquire sufficient evidence, beyond all reasonable doubt, to put those responsible before the courts and bring some level of justice for their victims.
In the meantime, committees are formed, consultations are launched and the same faces, from the same organisations, sit around different tables, making the same arguments, on the basis that it’s good to talk. It is also good to act. Unfortunately, those individuals and organisations that can do something to stop the killing may be listening; but they are not acting and the killing continues. Consequently the ‘Hen Harrier persecution ‘can’ is perpetually kicked into the long heather’.
The phrase ‘the road to hell is paved with good intentions,’ usually attributed to Saint Bernard of Clairvaux, perfectly describes the Wildlife and Countryside Act today. It is no longer fit for purpose and many aspects of the legislation need a metaphorical ‘root and branch’ rewrite to make them relevant to face the challenges of the 21st century. Currently, it does not provide a deterrent to the criminals who are actively, and persistently breaking the law. The chances of being caught and prosecuted are minuscule and the penalties imposed on those who are prosecuted are derisible. Consequently, anyone who is prepared to kill a Hen Harrier allegedly to ‘protect’ their livelihood’ or to ‘sustain rural communities’ is unlikely to be patrolling their beat with a firearm fearing prosecution.
Representatives of the shooting industry, constantly tell us that they are capable of self-policing their members and that additional legislation is not required. The evidence refutes that assertion. In reality they are powerless when it comes to controlling the illegal activity of their members or their metaphorical ‘few bad apples.’
Any, and all, organisations that are prepared to take on the metaphorical Herculean task of cleaning the shooting industry’s equivalent of the Augean stables, become a target for abuse on social media. When will members of the shooting industry ever thank the Police, the RSPB Investigations Team and Raptor Workers for putting their heads above the parapet and doing the job for them by calling out the criminals and giving evidence in court when required? Not in this lifetime. Their hand wringing and ‘we have a zero tolerance of raptor persecution’ statements are pointless without affirmative action.
In the meantime, the relentless unlawful killing of Hen Harriers continues unabated. There is a saying that is applicable to the current approach for dealing effectively with bird of prey crime in general and the persecution of Hen Harriers on land managed for grouse shooting in particular – ‘If you always do what you’ve always done, you always get what you always got.’
That is exactly where we are now. Trying to convince the shooting industry that raptor persecution can be eliminated, or at least significantly reduced, on land managed for game shooting. Talking to the shooting industry and using reasoned arguments has been tried for 25 years and failed miserably. A Hen Harrier Brood management scheme, a scheme, whereby chicks were removed from grouse shooting estates to be reared in captivity and then released weeks later away from grouse moors, a scheme praised by industry representatives as ‘the safety net’ allowing commercial grouse moors to continue to be profitable, also failed miserably to prevent Hen Harrier persecution in the northern uplands and has rightly been abandoned by Natural England.
The shooting industry has been given chance after chance, over decades, to get its house in order and has rejected every opportunity. From 2004 to 2008 the NWCU led project Operation Artemis proposed a solution that would reduce Hen Harrier persecution. It was not only totally rejected by the industry; the authors were subjected to continuous personal attacks in the shooting press. Operation Artemis was supported by MPs in Early Day Motion EDM755A1 tabled on 4 March 2004 by Tony Banks MP [Labour] in response to remarks by James Gray MP for North Wiltshire [Conservative] that tackling wildlife crime was a waste of time.
A revived version of Operation Artemis is currently being implemented by The National Wildllife Crime Unit – the Hen Harrier Task Force – to tackle persecution on shooting estates identified as being hotspots of Hen Harrier persecution across the North of England, is similarly being rejected by members of the shooting industry.
- Natural England’s own research revealed that 72% of Hen Harrier chicks were more likely to be located on grouse moors during the last 7 days of tracking prior to the date of death or disappearance than during other weeks.
https://www.nature.com/articles/s41467-019-09044-w
Additionally, Hen Harrier satellite tag data examined by the RSPB revealed that:
- Annual survival was low, especially among first-year birds (males: 14 %; females: 30 %), with illegal killing accounting for 27–43 % and 75 % of mortality in first-year and sub-adult (1-2 years) harriers respectively
- Illegal killing is the main cause of death for older birds, accounting for up 75% of deaths each year in birds between one and two years old
- It is also a major cause of death in birds under one year. Additionally, mortality due to illegal killing was higher in areas managed for Red Grouse shooting, high-lighting the role that persecution on some grouse moors plays in limiting Hen Harrier populations in the UK
- Illegal killing is likely attributable to grouse moor Management because a 10 % increase in grouse moor use resulted in a 43 % increase in mortality risk
ewing-et-al-2023-illegal-killing-hh-grouse-moors-biol-consv
Research has shown, that there is sufficient suitable habitat to support c330 breeding pairs of Hen Harriers in the northern uplands, however on average over recent years less than 10% of that number breed successfully annually. Combined data released by Natural England and the RSPB for the 2025 breeding season has revealed that 106 chicks fledged from 33 successful breeding attempts, average 3.2 per nest. With this rate of productivity, we could expect more than 1000 chicks from the 300 pairs. 2025 hardly gives cause for celebration.
If the low number of fledglings during 2025 doesn’t give continued cause for concern the distribution of the breeding pairs should:
These data graphically reveal, that, not only are Hen Harriers persecuted on grouse moors in the northern uplands, they appear to be deliberately prevented from breeding; therefore, they are facing population islandization based in Northumberland and on the United Utilities Estate in the Forest of Bowland.
Over the last 70 years Hen Harriers have had enhanced legal protection afforded to them by 2 Acts of Parliament:
- The Protection of Birds Act 1954, and,
- The Wildlife and Countryside Act 1981
and yet the killing continues.
Recognising that the current legislation over the last 20 years has failed to have any deterrent effect there have been 5 attempts to find a solution to ongoing problem of Hen Harrier persecution through dialogue with the game shooting organisations:
- National Wildlife Crime Unit led Operation Artemis – failed to achieve ‘buy-in’ from the shooting industry representatives and abandoned
- Defra sponsored, Conflict Resolution facilitated by the Environment Council – failed to achieve ‘buy-in’ from the shooting industry representatives and abandoned
- Peak District National Park bird of prey initiative – failed to achieve ‘buy-in’ from the shooting industry representatives and abandoned
- Yorkshire Dales / Nidderdale AONB bird of prey initiative – failed to achieve ‘buy-in’ from the shooting industry representatives and abandoned
- National Wildlife Crime Unit – Hen Harrier Task Force – currently active; but so far has failed to receive cooperation from the shooting industry and that is very unlikely to change.
It is not only Hen Harriers that are persecuted on grouse moors. Research shows that Peregrines are also under represented on their traditional breeding grounds. The research also shows that where they do breed successfully in the uplands, their productivity is similar to pairs breeding away from the uplands.
https://www.sciencedirect.com/science/article/abs/pii/S0006320711003831
Enough is enough; the time for talking is over. It is long past the time when more affirmative action is required by the UK Government. Having endlessly tried the collaborative approach (which has self-evidently failed) , if the Government is serious about tackling bird of prey persecution connected to the game shooting industry, now is the time to introduce licensing, for both upland and lowland game bird shooting. The licence should be attached to the land, not the landowner or a representative of the landowner. Breaches of the licence should be met with immediate suspension of the licence for a significant period. Second offences should incur a longer period of licence suspension and the withdrawal of Government grants. Individuals convicted of killing or attempting to kill, protected species need to face appropriate sentencing, including the loss of the privilege to own or possess firearms, commensurate with the severity of the offence.
Steve Downing
Chairman
Northern England Raptor Forum
20th October 2025