Ms E Cowan
By email: firstname.lastname@example.org
Our Ref: SIR150309/A2651567
15 June 2018
Dear Ms Cowan Information Request – Strathbraan Licence
Thank you for your information request, which we received on 23 April. We have considered
your request under the Environmental Information (Scotland) Regulations 2004 (‘the EIRs’). Your Request
1. “The full basis for Strathbraan Community for Waders and any other relevant persons/
associations for the initial proposal of the Raven Cull in relation to concerns raised be
that conservation or otherwise. If possible, full disclosure of the written proposal to
Scottish Natural Heritage in relation to this licence request.
2. Action otherwise undertaken by Strathbraan Community for Waders, Scottish Natural
Heritage and any other relevant bodies to investigate the concerns raised prior to the
grant of this licence.
3. Details of any action undertaken to explore alternatives to the Raven cull.
4. The full terms of the responsibility and expectations agreed between Strathbraan
Community for Waders and Scottish Natural Heritage in relation to the recent licence
grant. (This question relates to the practical and legal objectives set out within the
We have carried out a detailed search of the information we hold, and copies of all the
relevant documents are available at: https://www.nature.scot/strathbraan-licence-information-
The information includes the licence application, the licence application assessment, the
issued licence and all the relevant internal and external correspondence.
Some parts of the documents provided have been marked out (redacted). The reasons for
We have marked out (redacted) some parts of the documents where they contain
Scottish Natural Heritage, Battleby, Redgorton, Perth, PH1 3EW
Tel 01738 444177 Fax 01738 458611 www.nature.scot
Releasing the personal into the public domain in response to an access to information
request would breach the Data Protection Act 1998. We are therefore withholding the
information under EIRs Regulation 11(2) (Personal data).
We have redacted some information that was provided to us voluntarily and in
confidence. There are no other circumstances that entitle SNH to disclose this
information, and the correspondent has not consented to its disclosure. Making the
information publicly available would be likely to substantially prejudice the interests of
the correspondent. We are therefore withholding the information under EIRs
Regulation 10(5)(f) (Interests of the individual providing the information).
We have concluded that, in this case, the public interest in making the information
available is outweighed by the public interest in withholding it and maintaining the
confidence in which the information was provided.
We have redacted a small amount of information in the documents that falls out-with
the scope of your request.
Additional information is provided in the Annex to this letter to help address your specific
requests and provide further context on our responsibilities, the licence application and its
How We Handled Your Request
We believe you have asked for environmental information as defined in the Environmental
Information (Scotland) Regulations 2004 (‘the EIRs’), so we are dealing with your request
under those regulations. To be able to use the EIRs, we must apply an exemption under
section 39(2) of the Freedom of Information (Scotland) Act 2002 (‘FOISA’). The Scottish
Information Commissioner’s guidance recommends that public authorities apply this
exemption to environmental information and handle requests under the EIRs.
If you would like to find out more about the access to information legislation there is a
guidance booklet available on the Scottish Information Commissioner’s website:
http://www.itspublicknowledge.info/nmsruntime/saveasdialog.aspx?lID=5487&sID=5024. Review and Appeal
I hope this information meets your requirements but if you are dissatisfied with how we have
responded to your information request, please write to us within 40 working days explaining
your concerns. You can contact us at Battleby, Redgorton, Perth, PH1 3EW or email us at
email@example.com. We will carry out a review of our response and contact you with our findings
within 20 working days.
If you are not satisfied following this, you can make an appeal to the Scottish Information
Commissioner. The Scottish Information Commissioner can be contacted at:
Scottish Information Commissioner
Online appeal service: www.itspublicknowledge.info/Appeal
Telephone: 01334 464610
Yours sincerely Rhoda Davidson
Annex – Further information
Licensing and how we licence
around 2,500 licences and authorisations in relation to protected species every
year. The legislation sets out the specific purposes and criteria under which licences can be
granted. These purposes include preserving public health and safety, preventing serious
damage to crops or livestock, or for the purpose of science, research and education as is the
case here. We have to treat any licence application objectively and proportionately, on its
merits and against these criteria.
The application, licence and assessment
Populations of some of our wading bird species are declining rapidly. The causes of these
declines are not fully understood but predation, habitat quality and climate are all likely to be
important factors. Declines are largely thought to be due to low levels of productivity rather
than adult survival, and studies involving the removal of predators have been shown to boost
Many of these studies have looked at the removal of species that can either be controlled
without a licence (e.g. foxes), or of protected species that can already be controlled under
general licence (e.g. crows). This means that it can be difficult to differentiate between the
relative impacts of these species and that the impacts of any other predators, including
ravens, are poorly understood.
A correlative study looking at relative abundance of ravens and productivity of waders found
no significant relationship between the two but did find a weak negative relationship worthy of
further investigation. Furthermore the data used for this study is now quite old and in the
meantime the abundance of waders has decreased further, whilst raven numbers have
increased. A useful review of the relevant literature including on population trends of both
predators and prey and potential causes of these changes can be found in the Understanding
The licence application was submitted by the Strathbraan Community Collaboration for
Waders (SCCW) and was developed with input from scientists at the Game and Wildlife
Conservation Trust. This licence was granted on 4th April 2018 for the purpose of Science,
Research and Education. It permits the control of up to 69 ravens this year over an area of
c.30,000Ha. We are confident that this will not affect the wider conservation status of ravens
in Scotland on the basis of recent modelling work on raven populations undertaken on our
behalf by the British Trust for Ornithology and which will be published shortly.
The community-led proposal aims to compare productivity of curlew, lapwing and golden
plover in the study area before and after licenced reduction in raven numbers. Productivity
data is also being collected outside of the licence area and the land is managed positively for
Monitoring will be undertaken by trained land-managers, and the licence remains in place.
The project may run for up to five years, with progress reviewed annually before any further
licences are granted.
We accept that this proposal is not a full-scale academic study. However, the project is
designed to help contribute to our understanding of the factors affecting wader populations,
the usefulness (or otherwise) of potential interventions for their conservation, and the
feasibility of these more adaptive, community-led and co-productive ways of working. This
proposal is about testing an approach, on a limited scale and for a limited time-period, and
adapting it if needed, in order to improve our understanding. The potential benefits of the
project in this respect outweigh the impacts of the proposal on raven populations. We will
monitor the project and review it to ensure that this continues to be the case.
SNH’s Scientific Advisory Committee (SAC) are currently reviewing the application and wil
report their findings to the SNH board who will in turn consider how best to proceed in light of