AWresponse to SNH 15 March 2014

Reply to SNH Prof Philip Boon of 15 March 2014 in response to Dr Adam Watson of 14 February
I have received your letter and the 4-page account, both typed as dated 14 March, but in fact both
sent by email on 15 March at 0222. In Dr Raynor's acknowledgement of 14 February to my letter,
he stated 'we will respond in full within 20 working days'. In fact the response was sent after 20
working days had expired! Surely it involves lies if one dates documents as 14 February,
presumably to be perceived as meeting a time of 20 working days, and yet send them next day?
First your letter. Having been on Nature Conservancy staff and known many staff in NCC and SNH,
I do not doubt that SNH and SNH staff share my concerns on mountain hares. However, they
manifestly do not share them to anything like the depth of my concerns, or that of many colleagues
whose main interest is hill walking but who regard hare eradications as a scandal.
SNH has done too little, for too many years. You refer to SNH's attached response and say you hope
'this addresses' my concerns. The word 'addresses' has changed meaning and is now often vague, as
in your sentence. What your letter and account do not do is allay my concerns in terms of making
me stop complaints of unacceptable delay and unwillingness to respect the EC Habitats Directive
and the interests of the Scottish public in wildlife and landscape and outdoor recreation.
The SNH account was prepared by staff of two SNH units, Ecosystems and Biodiversity, and
Wildlife Operations, 'with input from staff in the James Hutton Institute'. The unit names may look
important to the uninformed, but are of little note. The meaningless 'Biodiversity' is just a fancy
new word for wildlife. Ecosystems include wildlife in its widest expression, as well as of course
climate, and how the term Wildlife Operations differs from wildlife in biodiversity seems somewhat
dubious and contorted. I expected several SNH staff to be involved, for SNH is the government's
statutory adviser on wildlife. However, it is inappropriate that SNH involved the JHI. I did not
permit SNH to show my account to JHI, and so I regard it as rude and unprofessional that SNH
must have done so in order for JHI to make 'input'.
Furthermore, I believe it strange that staff of the two SNH units involved in preparing the SNH
response are not named, and likewise whoever at JHI gave 'input'. Your letter, Prof Boon, is correct
and appropriate because you sign it and it is on your personal headed notepaper. The shadowy
anonymous individuals who prepared the response are different and unacceptable. Why not name
them, and let me and others see who they are? Presumably those to whom the response was
forwarded as copies are the relevant staff members. I know that Des Thompson, Ron Macdonald
and Rob Raynor are SNH staff, and Mairi Cole and Robbie Kernahan have SNH email addresses,
but I wish to know a) whether they helped prepare the SNH account, and b) the name/s of JHI staff
involved in 'input'. The public, MSPs, Government Ministers, media, and EC officers would wish to
know also. Doubtless they will wish to know whether you and the other five SNH staff above have
had any depth of experience of studying mountain hares and publishing on this. I am unaware of
such experience and publishing by you and the five. Can you please confirm?
On page 1 of the SNH account you note my 2013 book, which includes graphs showing declines at
two moors (not three as you state erroneously, for Corndavon was not one of the two, and you
misspell Tillypronie), and increases on two hills. These were just examples, and you ignore Tables
showing statistically significant declines at many moorland sites, along with a comment that in most
of these sites now the number of hares seen in spring now is zero. Because these data were
unpublished until recently, you claim that 'we' (i.e. SNH) were unaware of them.
Two issues arise here. Data for many of the study areas were published in 1973, and the authors of
one of SNH's commissioned reports mention the possibility of counting hares now on these areas,
but then dismissed it for invalid reasons. Given that possibility, why did SNH and commissioned
authors not contact me? I have most of the area boundaries on OS 1:25 000 maps, and a data-base
of areas and spring counts, and on a few areas also breeding success and winter deaths.
In contrast, SNH has spent over £100 000 on reports and meetings that have got nowhere in
reducing, far less ending, severe hare scarcity. You assert (foot of page 3, 'First, we shall compile
evidence on local hare declines and levels of culling from people such as you and others who are
willing to share data and information with us'.) Since retirement in 1990 I spent immense effort in
the field and recording data at home, and money on petrol, from my own pocket. SNH has a nerve
suggesting that I would be willing to share my data with SNH (presumably free, for you do not
mention a fee), especially when SNH's record is so bad on mountain hares over many years.
Tables in my book show year-spans, number of years with data, size of study areas in hectares,
correlation coefficients of spring numbers in comparison with calendar year, breeding success,
winter deaths, proportionate change in relation to density in the previous spring and breeding
success in the previous summer and winter death-rate in the previous winter, and winter death-rate
(recorded in spring) and breeding success in relation to snow cover in the previous winter. The full
original data are on my computer. What would their price be for you?
One aspect that I would be willing to share with you, without a commissioned fee, involves copies
of my maps of study areas. I would have to make photocopies and pay for postage, and would
charge you for this small amount. However, I would not be prepared to help on this unless you
assure me that the maps would be used for counts by SNH or others now or in the next year, not
after 2017. I will have done spring counts for 2014 on these areas, except for alpine and high
subalpine study areas where there is still too much snow for reliable counts.
As for 'levels of culling', I know nobody with such information. I doubt whether estates and staffs
recorded it, and see no chance of them sharing it with you in the unlikely event that they recorded it.
This is pie in the sky, and signifies SNH's poor understanding of estate staff and their thinking.
The second issue is that many SNH staff such as Dr Des Thompson know that since 1973 I have
continued to study numbers of several animal, and other topics, e.g. dotterel, snow bunting,
ptarmigan, red grouse, corn bunting, crossbill, mountain hare, pinewood, alpine vegetation, snow
patches, place names, Gaelic dialect. Since I retired in 1990, I have done this out of my own pocket,
and until CEH closed its Banchory Station I could easily be found there as an Emeritus Fellow.
In your page 1, paragraph 3, you refer to my suggestion that you and commissioned authors were
primarily interested in finding a national population estimate. You mention the Habitats Directive,
which requires this. SNH should have used its authority to tell the EC that a national estimate and
associated secondary aims were unrealistic and unattainable with any reliability for this species.
That does not excuse SNH from ignoring the crucial question, which I stated explicitly as being to
check a sample of grouse moors where I or others had found declines and scarcity. The question
would be whether hares had declined and the extent to which they had declined, and compare this
on moors without severe killing. This is simple hypothesis testing, ignored in your account though
stated clearly in mine. It signifies a clear case of a serious sin of omission and bias by SNH.
In the SNH account, page 2, first two paragraphs, you give me information on licences to kill
mountain hares, in response to a query by me. This information was largely new to me, so thank
you for sending it. The Scottish Government dealt with licence applications until 2011, when SNH
took over. For the five applications made in 2001 to 2006, you do not know the outcome. Surely
this is intolerable, for SNH should have received this information in the public interest. In 2007, a
single application was refused, and since 2011 under SNH control, two applications were made for
'disease control', in 2012, and both refused. It is right that they should be refused. However, the key
point is that a mere eight applications in 12 years does not tally remotely with the widespread
killing of hares on grouse-moor estates and shows that hardly any of the relevant landowners
respect the regulations, and most are ignoring them and paying no attention to SNH.
In your page 2, paragraph 3, you mention 'At present, we are working to establish a reliable
technique for assessing numbers of mountain hares across many people as possible
across various geographical areas'. Again you emphasise a national estimate to the exclusion of the
crucial question that I posed in the above paragraph. To use 'as many people as possible across
various geographical areas' is cloud cuckoo land and a recipe for unreliable results. Again, you
completely duck the main question on hare killing and scarcity, which is to concentrate on grouse
moors with severe killing and scarcity, and without.
Half way down paragraph 3 on page 2 you turn to dung-counts as being 'one well-used method'.
Here you are being economical with the truth, and duck my criticisms of the reasoning for trying
this method on mountain hares, that it had been used for snowshoe hares in North America by
Charles Krebs and others. You ignore my key point on this, that this reasoning was false and
misleading, because the study by Krebs was in the boreal forest at Kluane in the Yukon, where one
cannot see hares for trees. Dung-counts there were analogous to estimating densities of red deer in
Scottish coniferous plantations, where deer are hidden and dung-counts a necessity. Mountain hares
are so easily visible on grouse moors and alpine land that one need not resort to dung-counts. They
are an absurd method for such open land.
Again in paragraph 3 you mention gamekeepers and using them for dung-counts, though admitting
that this 'may not be their preferred method'. Anyone thinking it would be their preferred method
has little experience of gamekeepers on Scottish grouse moors. Non-cooperation will be a certainty,
just as the tiny number of licence applications signifies widespread non-compliance and disregard
for SNH by estates.
In page 2, paragraph 4, you mention my reasons criticising dung-counts for finding densities of
mountain hares. My reasons apply also to red grouse, ptarmigan, golden plover and other species
which can be counted accurately, using trained pointing dogs, just the same as for adult mountain
hares on moorland in winter and spring. So, why use an indirect method that is open to obvious
errors, when direct counts have been proved accurate and precise? Having spent over £100 k on
dung-counts which have got you nowhere in stopping hare slaughters, you now say 'In the absence
of other methods, and given the relative simplicity of this method, we do consider this to be worth
further field trials, which we propose to progress during 2014-17'. This claim on 'absence of other
methods' is avoidance of the truth. My 14 February account showed that direct counts by transects
with and without dogs attain total numbers (see my fifth to eighth last paragraphs below).
One reads in paragraph 4, 'given the relative simplicity of this method'. What is the point of using
what you call a relatively simple method unless it produces the required data? Also, I question the
term 'relatively simple'. Given the difficulties that the commissioned observers had in using it, and
the well-known and highly non-random dropping of dung by mountain hares, one could conclude
that it is neither simple nor useful.
Four more years of dung-counts are proposed, with doubtless another £100 k of taxpayers' money,
despite poor results so far. The public face four more years of delay and procrastination in tackling
the crucial question that I clearly stated above and in my 14 February account. SNH deserves
criticism for further complacency. It is like the proverbial ostrich with its head in the sand.
In your page 2, paragraph 4, second half, you mention Moorland Forum (MF) and the possibility of
'revised guidance' on moorland management. Revised guidance will solve nothing unless SNH adds
and uses teeth. Hare scarcity from severe killing has extended to other moors and worsened in scale
on individual moors, during the years of MF. In short, MF has done nothing to reduce, far less stop,
severe killing of hares on grouse moors. Because SNH plays an integral role in MF, and according
to my understanding funds it, one can conclude that SNH has been weak in MF. This has been well
known for years, but SNH has chosen to ignore it and persist with the cosmetic impression that
SNH is doing something useful. Certain participants in MF have informed me that meetings of MF
are characterised by much talking, but failure to resolve controversial issues. These participants can
remember little, if anything, useful said by SNH about hare conservation at MF.
In the next paragraph, 5, you are considering measures to 'encourage better practices and require
estates to provide evidence that their activities are not compromising the conservation status of hare
populations locally'. Then one sees that this will 'rely largely on volunteer engagement'. The
voluntary principle has been allowed for grouse-moor landowners for decades and has failed,
whether it be persecution of protected raptors, construction of unauthorised damaging vehicle
tracks, misuse of EU Regional Development Funds to erect obtrusive damaging fencing (with a lack
of stiles or gates) on the pretext of agriculture when in fact it is for grouse management, overburning of vast areas ostensibly for tick control, and severe killing of mountain hares, roe deer, red
deer and others ostensibly for tick control. Landowners of grouse-moor estates should be licensed,
because they have failed to put their own house in order within their own organisations.
You add that if 'volunteer engagement' fails and there is evidence of further decline of hares, then
SNH would consider changes to the law, which would entail hare control only by licence. Why does
SNH not do this now? Why should it require evidence of further decline of hares? Hares have
already been extirpated over big areas, to a point where further decline is scarcely possible.
At the end of page 2 you try to justify why references by Ray Hewson, John Flux and me to work
on mountain hares was ignored in the book The Nature of the Cairngorms. where Dr Raynor was a
co-author of the mammals chapter. You say our papers were known and widely consulted by SNH
staff. That is irrelevant and beside the point. I asked why they were ignored in the mammals
chapter, not whether they were known and used by SNH staff. Given that Dr Raynor was second
author of the mammals chapter, the brief inadequate coverage of mountain hares deserves serious
criticism. Also the chapter has surprisingly little knowledge of some other mammals such as brown
hares ('their current status in the Cairngorms is unknown'). This quotation is fatuous, and other
flaws demonstrate that authors had remarkably little field experience of the Cairngorms National
Park, and did not bother asking any observers who had some experience. Were they office-bound or
simply poor observers when out in the countryside? Either way, they should have had the humility
to ask others.
Strangely, you then add a sentence on McLeod. I mentioned his report in my account, and wondered
why Dr Raynor and commissioned authors had ignored it, for it had information on densities in the
Cairngorms region by an observer without a dog. You say it was a commissioned report, which I
knew already, and that you intend to publish it. I do not see the relevance of your thinking or why
you mentioned McLeod at all. It is illogical.
On your page 3, paragraph 3, you raise MF again. You assert that the British Trust for Ornithology
and the Scottish Raptor Study Groups (now one Group, singular) have 'considerable experience of
moorland management', and 'These organisations and others on the forum are well placed to bring
experience and expertise on moorland management'. This last sentence is an obvious exaggeration
for BTO and SRSG, to whom it does not apply. However, the key point is what has MF done to
reduce and stop severe hare-killing? The answer is nothing. The MF, SNH guidance on it, and SNH
statements at MF meetings, have obviously lacked teeth.
In your page 3, penultimate paragraph, you thank me for sending you an offer from Pat Wells of
Tomatin to show SNH staff some moors where hares have declined. You add that several SNH staff
have noted apparent declines at areas such as the Lecht while walking or skiing. SNH's Dr David
Bale sent me an email last winter on a woodland topic, but in passing wondered if the increasing
scarcity of mountain hares on grouse moors might be detrimental to golden eagles. Fine, but what
have the several staff who were at areas such as the Lecht done about it> Why should it need a busy
lady at Tomatin, up to her eyes in work against the proliferation of expensive wind turbines, to show
SNH staff some moors where hares are scarce? Why have a few of these SNH staff not done
something, taken some action within SNH, or tried to check their apparent declines at areas such as
the Lecht? It is pathetic and unacceptable, given the number of staff and the amount of taxpayers'
money used by SNH. Are they all so office-bound, and/or hide-bound by bureaucratic procedures?
SNH staff appear to do very little field study compared with their counterparts in NCC and NC.
Although now 84 years old and suffering two incurable illnesses, with consequent weakness on the
hill and in driving long distances, I continue counts of mountain hares and other species.
On your page 4, paragraph 1, what you claim about calibrating '(preferably) more than one method
against an independent measure of hare density and then confirm the method that is to be promoted
more widely' is illogical, presumes too much without stating your assumptions, and is further
evidence of tortuous woolly thinking. To confirm the method that is to be promoted more widely
jumps the gun, before you know which method is most accurate and which would be feasible for
gamekeepers and others. Then you turn to MF again. You stress a recent paper that found no
compelling evidence to suggest that killing of hares, deer etc for supposed tick reduction led to
bigger grouse bags. However, you then state that you shall work with Moorland Forum and the
Game and Wildlife Conservation Trust to 'promote the message more widely that large scale culls
(i.e. of hares) are ineffective and inappropriate' for managing red grouse.
Why have you not been doing that years ago? Why say you 'shall work' with them on this? Your
inaction has to be condemned. Your last sentence in this paragraph, on working with MF again,
where 'we shall develop threshold for sustainable management of mountain hares and devise
appropriate methods for monitoring and reporting on this management' may look important to the
uninformed, but to the informed is unrealistic gobbledygook and hope, a will o the wisp.
In the last paragraph of your account, you refer to Dr Raynor and say you and others whom you
have not named are also involved in conservation of mountain hares. I know that Dr Des Thompson
has worked with MF, and offered to meet me to talk about my concerns. However, Dr Raynor is
SNH Mammals Officer, so cannot escape responsibility, especially in his mammals chapter in the
SNH purple book. However, I accept your statement that several SNH staff have been involved. In
the end, it is clear that SNH has failed on mountain hares, because of institutionalised inaction,
unwillingness to criticise a small number of grouse-moor owners and willingness to defer to them.
Your account shows nothing that I did not already know, bar licences. I found your letter and
account depressing, because of defensiveness, lack of logic and philosophical scientific rationale,
absence of hypothesis testing and all that it entails, economy with the truth, eagerness to continue
with methods that have proved to get nowhere, unwillingness to face proven methods, and ducking
of what I had stated were the crucial questions. Given that your account was produced by several
staff in two SNH units, this is a damning criticism of the shortcomings of SNH.
So far, my comments relate to what is in your letter and detailed account. However, the main flaws
in SNH's thinking and response to me are not SNH's errors of commission in that letter and account,
but the errors and indeed sins of omission, i.e. issues which I raised on 14 February and stressed as
fundamental, yet which you ignore in your letter and account. The chief of these involves transect
counts by walking, transect counts using dogs, and scanning counts on alpine land and upper
moorland. In my 2013 book I presented data on the repeatability of scanning counts using
binoculars and compared them with data from dog counts on the same areas, on high moorland and
alpine land. Scanning counts and dog counts showed very similar results. Secondly, Flux's transect
counts where he walked without a dog must have produced a reasonably total enumeration, because
shooting by gamekeepers and others on a drive occurred on a given winter day, and Flux's counts
before and after tallied with the loss from shooting. I presented other data by me in Glen Esk,
showing that heavy losses to snaring by a sheep-farmer tallied with my counts using dogs, before
and after snaring. Hence, walking without dogs produces counts that are close to total counts, as did
scanning and counts with dogs. Transect counts with pointing dogs trained for counts allowed
observers to cover a much bigger area per hour than walking transects without dogs, and scanning a
yet bigger area per hour though suitable only for alpine land, subalpine moorland and heavily
burned or grazed moorland with little tall vegetation where hares can hide.
I believe it almost beyond belief that SNH's considered response to me ignored my comparisons of
methods and for that matter Flux's with his effective 'removal experiment' by shooting from
gamekeepers. The authors of SNH's response are so biased against direct methods that they ignore
the above evidence summarised from my book. This is a serious sin of omission, signifying
unacceptable unscientific bias. SNH and associates have wasted years and over £100 k on dungcounts that proved useless. Worse, they propose to do further trials of this method during the next
four years. The ironic aspect is that SNH is keen to find a method that gamekeepers could use
easily. Many gamekeepers have used transect counts with and without dogs for decades to count red
grouse, and some of them to count mountain hares and others as well.
On the issue of dog counts I quote from my account of 14 February, 'This is followed by further untested
claims in report 287 (Section 6) that, 'direct counts are likely to be of limited use at very low density and very high
density', but no evidence for this is adduced. The authors go on to dismiss counts using dogs, because Watson et
al. (1973) found that the coefficient of variation of counts was greater at medium and low population densities
than at high densities. However, the authors were wrong to claim that the greater CVs at medium and low
densities 'suggest that dog counts are of dubious use (Watson et al. 1973)', as if quoting from Watson et al. (1973).
Watson et al. (1973) stated nothing of the sort, so this was a serious misrepresentation by the authors of report 287
including yourself (note added by AW on 17 March, this referred to Dr Raynor, to whom my account was
addressed) as an SNH officer involved in commissioning this report. Higher CVs of counts at low density are
inevitable because the individual animal has a larger home range that may straddle the boundary of the study area
and therefore on a given count may be inside the boundary or outside. It is an elementary fact of statistical;
analysis that this can be easily solved by using a larger sub-area or by combining sub-areas into larger ones.'
In my account of 14 February I raised many other criticisms of SNH's illogical thinking and
inaction, as well as flaws of commissioned reports. SNH's response to me ignores most of these,
and typifies their lack of action to end the plight and scarcity of our mountain hares, for good.
I have better things to do than correspond further with SNH on this matter. For many decades I have
been used to trenchant criticism, both negative and positive, of my own work by colleagues and
others. They receive the same from me. This generates progress in science. The thinking on this is
international and well established, on the importance of hypothesis-testing, experiment, and work
designed to look for evidence against one's favoured hypothesis. The SNH response shows the
opposite, with repeated defensiveness, attempts to save favourite ideas and methods and
conclusions, and unwillingness to consider evidence or methods that would go against their
favourite ideas. I would have been willing to consider helping SNH on the hare issue, had SNH
shown an open scientific attitude. However, SNH demonstrates the opposite, with a closed
unscientific mind and defensiveness dominating their response. Hence it is a waste of time for me
or others to argue with individuals who show such scant respect for scientific principles.
The SNH letter and SNH account are seriously marred by being written so often in gibberish, like
the commissioned reports on mountain hares as I noted in my letter of 14 February. The SNH letter,
for example, has 'Your letter has been logged as a complaint', 'my colleagues leading on hare
conservation', 'We are actively working' (one cannot passively work, so why actively?), 'methods
and policies to address these' (what is meant in explicit English by the vague term 'address') and in
the next line 'I hope this addresses your concerns' (again the woolly and ambiguous if not largely
meaningless term 'address'). The SNH account is replete with more examples. I shall not list these,
for it is too depressing and wearying, but your lack of clear explicit English shows SNH in a poor
light and will be perceived as such by the public, politicians, media, and EC officers. I will end this
paragraph by noting a hilarious example of an unrelated or dangling phrase, in the SNH account,
page 1, paragraph 3, 5 lines up from the bottom, 'As an Annex V species, we are required to take
decisions on licensed bag limits'. SNH staff (i.e. we) an Annex V species?
I did think of acknowledging your letter and account, and saying I would not be further involved
with you, but on the other hand a critique of the conspicuous flaws in SNH thinking and actions
would be useful for anyone who intends taking this matter further to the EU or the media, so that is
why I wrote it. Given your repeated defensiveness, I doubt whether my critique will be of value to
SNH's thinking that is sadly politically rather than scientifically driven.
To conclude, I do not wish to correspond further with SNH on this, apart from a few brief questions
below, and do not wish SNH to reply to me, apart from answering these few questions:1. Is it acceptable SNH practice to type a date 14 March incorrectly on documents as SNH's
response to me within 20 working days, when they were not sent until 15 March?
2. Is this not lying?
3. Which named staff in SNH helped prepare the SNH account, and which named staff for the
'input' from staff of the John Hutton Institute?
4. Do you or any of the five SNH staff to whom you sent the account via email have
recognised experience of studying mountain hares and publishing scientific papers on this?
5. Why does SNH ignore my question of 14 February that the crucial issue is to count
mountain hares on a sample of grouse-moors where severe killing and consequent scarcity
have been recorded or observed anecdotally, compared with a sample of areas where severe
killing and consequent scarcity have not been recorded or observed anecdotally?
6. Why does SNH continue to stress a national estimate, when this is unattainable and is
irrelevant to the crucial question of severe killing and scarcity on certain grouse moors?
7. Does SNH put a price on my full data as specified in summary above, and in my 2013 book?
8. Would SNH be interested in receiving photocopies of my mapped study areas, on the basis
that I described above, provided that they are to be used by SNH or others for counts of
hares now or in the next year, not after other work planned by SNH for 2014-17?
Adam Watson, Clachnaben, Crathes, Banchory, Kincardineshire AB31 5JE. 21 March 2014
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