Chamber and committees

Scottish Government submission of 21 July 2021

PE1850/A - Natural flood prevention on grouse moors

In 2017 the Cabinet Secretary for Environment, Climate Change and Land Reform commissioned an independent group to look at the environmental impact of grouse moor management. The Cabinet Secretary’s decision to form the review group was prompted by the report from NatureScot in May 2017, which found that around a third of satellite-tagged golden eagles in Scotland disappeared in suspicious circumstances, on or around grouse moors and was part of a package of measures aimed at tackling the on-going issue of wildlife crime – and in particular, raptor persecution.

The Government published its response on 26 November 2020 and committed to bringing forward the legislation to license grouse moor management during the next parliamentary term. This will be preceded by a full public and stakeholder consultation.

The full copy of the response can be found on the Scottish Government website at:

Grouse Moor Management Group recommendations: Scottish Government response - gov.scot (www.gov.scot) 

The group had a clear remit: to examine the environmental impact of grouse moor management practices such as muirburn, the use of medicated grit and mountain hare culls, and advise on the option of licensing grouse shooting businesses. The review group did not consider the risks of flood damage occurring on grouse moors or the measures deployed by a grouse moor manager to mitigate flooding on their land.

The Scottish Government does recognise the importance of working with nature to manage flood risk; often referred to as “natural flood management” (NFM). A range of NFM measures and sustainable land management practices can play an essential role by storing or slowing flood water in the catchment. These measures include woodland planting, floodplain reconnections, upstream leaky barriers and wetland creation. Natural solutions can often be best implemented along-side more traditional engineered solutions. Importantly working with nature to manage flood risk in this way gives multiple benefits for the water environment i.e. biodiversity gains, improved water quality, fish habitat improvement and carbon capture.

SEPA, in conjunction with responsible authorities, have examined and mapped areas where implementing NFM techniques could be most effective. The maps can be found on the SEPA flooding website pages. As a result of this analysis, the flood risk management strategies and local flood risk management plans include a total of 104 actions with an NFM element, most of these being studies. These studies will further develop the contribution NFM can make to reduce flood risk to identified areas.

However, whilst we acknowledge the potential for working with natural processes to help mitigate flood risk on grouse moors, we do not believe that it would be appropriate to make the inclusion of NFM methods a condition of obtaining a grouse moor licence. As we have set out the primary driver behind the review of grouse moor management was raptor persecution and the purpose of any further licensing regime will be to implement the recommendations of the Grouse Moor Management Group.

Furthermore the issues the petitioner is seeking to address are not confined to grouse moors. The Flood Risk Management (Scotland) Act 2009, Scottish Government guidance, and the national flooding strategy clearly set out the importance of working with natural processes. SEPA and the responsible authorities will continue to set out where NFM forms part of the optimal suite of actions to mitigate flood risk in each cycle of regional Flood Risk Management Strategies and Local Flood Risk Management Plans.