General Licences consultation

TAKE ACTION: Respond to NatureScot’s General Licences consultation

NatureScot is consulting on its proposed General Licences for 2027. These licences could continue to provide broad permissions to kill, capture and commercially exploit Scotland’s wild animals without applications being assessed individually.

This is your chance to speak up.

We’ve made it quick and easy to respond. Using the form below, you can send your personal response and call for greater scrutiny, transparency and a shift towards preventative and non-lethal approaches.

If you’re having trouble using our email tool—for example, if it isn’t loading properly or the recipient isn’t displaying—you can still take action.

Simply copy and paste the message below, add your own words, and send it directly from your email to: Licensing@nature.scot

First Name

Surname

Your Email

Subject

Message

Dear Sir/Madam,

I am responding as a member of the public. These responses reflect my own views.

Section A: Broader questions on General Licensing
Question 1: Have you used any of the 16 General Licences issued by NatureScot? If you have, which General Licence have you used?

No.

Question 2a: Do you think the current approach to General Licensing works well?

Answer: No

Question 2b: Please explain your answer:

I do not consider the current approach to General Licensing fit for purpose. I strongly oppose the use of General Licences to reduce the legal and administrative barriers to killing or commercially exploiting wild animals. Many of the licences under review provide broad permissions for lethal control without case-by-case scrutiny of whether it is necessary, proportionate or whether satisfactory non-lethal alternatives exist. This creates significant scope for misuse and, where meaningful reporting is absent, provides inadequate transparency or accountability.

I believe the current approach is not consistent with the direction wildlife management should be taking. Greater emphasis should be placed on preventing conflict, encouraging coexistence and developing non-lethal solutions, rather than relying on routine derogations from wildlife protections.

However, I support the use of General Licensing where their intention is to directly protect or improve the welfare of wild animals, as demonstrated by the rehabilitation (GL05) and veterinary treatment (GL06) licences, which allow sick or injured birds to receive care promptly without unnecessary administrative barriers.

Question 3a: On a scale of 1-5 (1 Strongly disagree, 5 Strongly agree), do you support the principle of General Licensing?

Answer: 2 – Disagree

Question 3b: Please explain your answer:

I do not support the principle of General Licensing where it is used to authorise the intentional harming, killing or commercial exploitation of wild animals.

General Licences authorising the killing or commercial exploitation of wildlife are inherently problematic because they transform activities that would otherwise be unlawful into routine management practices. Rather than treating the intentional harming of wild animals as an exceptional derogation requiring robust justification, they create broad standing permissions that normalise lethal intervention and exploitation.

I do, however, support the use of General Licences where they facilitate activities that directly benefit wild animal welfare, such as rehabilitation or veterinary treatment, and where removing unnecessary administrative barriers is clearly in the interests of the animals concerned.

Question 4a: Should all General licences include a condition to provide annual returns?

Answer: Yes

Question 5a / 4b: (I have answered 'Yes' rather than 'Some not all', so Question 4b does not apply. I comment on annual returns generally below.)

Mandatory, standardised, independently-auditable annual returns should be a condition of every single General Licence. I recommend that annual returns be required from every operator using every General Licence, that they record species, numbers, methods, dates and locations, that NatureScot publish aggregated data at least annually, and that a sample of returns be independently spot-checked.

Question 5a: Should new General licences be considered for any other purpose, species or legislation?

Answer: No

Question 5b: Please explain your answer:

No. I do not consider there to be a need for additional General Licences. Instead, I believe the existing framework should be refocused so that General Licensing is primarily used to facilitate activities that protect and care for wild animals, rather than authorising activities that intentionally harm, kill or commercially exploit them.

Section B: Proposed individual General Licences (GL01/2027 – GL16/2027)
Proposed GL01 – To kill or take certain birds or destroy their nest and eggs for the conservation of wild birds
Question 1: Do you agree with a General Licence to control wild birds for the conservation of wild birds?

Answer: 1 – Strongly disagree

I do not support the use of a General Licence to authorise the intentional killing or taking of one group of wild birds for the perceived benefit of another. While I recognise the importance of conserving native species and restoring ecosystems, I do not believe that routinely derogating from wildlife protections through broad standing permissions is an appropriate or proportionate approach.

Decisions to intentionally kill protected wild birds raise complex ecological, ethical and welfare considerations that vary considerably between locations and circumstances. These decisions should not be made under a blanket General Licence, particularly where the statutory test of there being "no other satisfactory solution" cannot be independently assessed in each case.

Genuine conservation problems are far better addressed through habitat management, nest protection and reducing the underlying pressures (including predator numbers artificially inflated by game-bird releases) rather than through the killing of wild birds under a blanket licence available to any landowner or occupier.

Therefore, I believe greater emphasis should instead be placed on preventing conflict, restoring habitats and addressing the underlying causes of biodiversity loss, alongside the development and implementation of effective non-lethal approaches wherever intervention is considered necessary.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Magpie, Carrion Crow, Hooded Crow, Jackdaw, Jay, Ruddy Duck, Canada goose.

Question 2b: Comment on species you have selected above.

I do not agree with any of these species being listed.

Question 3: Are there any other species which should be included on this General licence? If yes, tell us which species and why.

No. I oppose any expansion of the list of species that may be killed under this or any other General Licence.

Methods
Question 4a/4b: Do you agree with these permitted methods?

I wish to comment on all of the items listed: Pricking of eggs, Oiling of eggs, Destruction of eggs and nests, By hand, Targeted falconry, Shooting with any firearm, A multi catch cage trap, A Larsen mate trap, A Larsen pod trap, A Larsen trap.

Question 5a: Comment on methods selected above.

I do not agree with the permitted methods because I do not believe it is appropriate for a General Licence to authorise interventions that intentionally harm or kill wild birds. Many of the proposed methods raise significant animal welfare concerns, including the potential for pain, distress, injury and prolonged suffering.

Question 5b: Are there any other methods which should be included on this General licence? If yes, tell us which methods and why.

No. I propose narrowing, not widening, the methods permitted.

Conditions
Question 6a/6b: Do you agree with the conditions proposed under this General licence?

Answer: No

The proposed conditions do not require independent assessment that a specific conservation need exists, nor do they provide sufficient assurance that non-lethal approaches have been fully explored. These shortcomings illustrate why this type of intervention is unsuitable for a General Licence and should instead be considered through an individual licensing process and limited to preventative, habitat-based and non-lethal measures that support long-term coexistence with wildlife.

Proposed GL02 – To kill or take birds listed or damage or destroy their nest and eggs for the prevention of serious damage to livestock, foodstuffs for livestock, crops, vegetables and fruit
Question 1: Do you agree with a General Licence to control wild birds for the prevention of serious damage to livestock, foodstuffs for livestock, crops, vegetables and fruit?

Answer: 1 – Strongly disagree

I strongly disagree. Modern agriculture has a wide range of well-established non-lethal means of protecting crops and feed from birds. NatureScot's own evidence base for how much serious damage is actually prevented by killing feral pigeons, wood pigeons, corvids and geese, as opposed to using these non-lethal measures, is thin.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Feral pigeon, Wood pigeon, Carrion crow, Hooded crow, Jackdaw, Magpie, Rook, Canada goose.

Question 2c: Comment on species you have selected above.

I do not agree with any of these species being listed.

Question 3: Are there any other species which should be included on this General licence? If yes, tell us which species and why.

No.

Methods
Question 4a/4b: Do you agree with these permitted methods?

I wish to comment on all of the items listed: Pricking of eggs, Oiling of eggs, Destruction of eggs and nests, By hand, Targeted falconry, Shooting with any firearm, Night-shooting devices for feral pigeon, A multi catch cage trap, A Larsen mate trap, A Larsen pod trap, A Larsen trap.

Question 5a: Comment on methods selected above.

Question 5b: Are there any other methods which should be included on this General licence? If yes, tell us which methods and why.

No.

Conditions
Question 6/6b: Do you agree with the conditions proposed under this General licence?

Answer: No

As with GL01, I consider the conditions inadequate because they do not require evidence of actual, serious, current damage, and do not require non-lethal deterrents to be demonstrably exhausted. I ask that this licence be withdrawn in favour of an individual licensing process and limited to preventative, habitat-based and non-lethal measures that support long-term coexistence with wildlife.

Proposed GL03 – To kill or take or damage or destroy nest and eggs of certain birds for the preservation of public health, public safety and preventing the spread of disease
Question 1: Do you agree with a General Licence to control wild birds for the preservation of public health, public safety and preventing the spread of disease?

Answer: 1 – Strongly disagree

I recognise the importance of protecting public health, public safety and preventing the spread of disease. However, I do not believe a General Licence is an appropriate mechanism for authorising the routine capture or killing of wild birds for these purposes.

The level of risk posed by wild birds, the evidence supporting intervention and the availability of effective non-lethal measures will vary significantly between locations and circumstances. These are inherently case-specific assessments and should not be authorised through broad standing permissions. Where intervention is proposed, it should instead be considered through an individual licensing process supported by robust scientific evidence, independent scrutiny and clear justification.

Preventative measures should be the primary response to public health and disease concerns. Improved waste management, reducing access to anthropogenic food sources, biosecurity, exclusion techniques and public education can all reduce conflict without harming wildlife and should be fully implemented before any intervention is considered.

I am also concerned that the term 'public safety' is not clearly defined within the licence, creating scope for inconsistent interpretation and the risk that relatively minor issues or perceived nuisance could be treated as sufficient justification for lethal intervention. Where a genuine and evidenced public health or safety risk exists, I do not consider routine lethal control to be an appropriate response. NatureScot has not demonstrated that killing wild birds provides a lasting or effective solution - suitable preventative and non-lethal measures should be used.

Species
Question 2a/2c: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Feral pigeon, Canada goose.

Question 2c: Comment on species you have selected above.

I do not agree with either species being listed for this purpose.

Question 3: Are there any other species which should be included on this General licence? If yes, tell us which species and why.

No.

Methods
Question 4a/4b: Do you agree with these permitted methods?

Question 5a: Comment on methods selected above.

Question 5b: Are there any other methods which should be included on this General licence? If yes, tell us which methods and why.

No.

Conditions
Question 6a/6b: Do you agree with the conditions proposed under this General licence?

Answer: No

I consider the conditions inadequate because they do not require evidence of actual, serious, current risk, and do not require non-lethal approaches to be demonstrably exhausted. I ask that this licence be withdrawn in favour of an individual licensing process, supported by robust scientific evidence, independent scrutiny and limited to preventative, habitat-based and non-lethal measures that support long-term coexistence with wildlife.

Proposed GL04 – To take red grouse using certain methods in order to administer medication or collect samples
Question 1: Do you agree with a General Licence to permit red grouse to be taken by certain methods, in order to administer medication or collect samples?

Answer: 2 – Disagree

In practice, this licence exists to support the medication and disease surveillance of red grouse on managed moorland, in order to keep grouse populations productive for driven grouse shooting. I oppose driven grouse shooting, and I do not accept that maintaining artificially high densities of a game bird for a shooting 'sport' is a legitimate purpose for a general licence to catch and handle wild birds. Where genuine, independent disease surveillance in wild grouse populations is required for conservation reasons unconnected to the shooting interest, this should be considered through an individual licensing process. This would enable NatureScot to assess the purpose of the intervention, the evidence supporting it, the welfare implications for the birds involved and whether the proposed methods are necessary and proportionate.

Methods
Question 2a/2b: Do you agree with these permitted methods?

I wish to comment on all of the items listed: By hand, Hand-held net (minimum 30cm opening), Artificial lighting, mirror or other dazzling device.

Question 2c: Comment on methods selected above.

I do not object to these methods solely because of the techniques themselves, but because of the purpose for which they are authorised under this General Licence. Any method used to capture wild birds has the potential to cause stress, fear and injury if not carried out appropriately. Where capture is proposed to support the management of red grouse in connection with shooting interests, I do not believe these methods should be authorised under a broad standing General Licence.

Question 2d: Are there any other methods which should be included on this General licence? If yes, please provide justification and evidence for the potential inclusion of this/these methods:

No.

Conditions
Question 5a/5b: Do you agree with the conditions proposed under this General licence?

Answer: No

I do not consider the proposed conditions to provide sufficient safeguards. They do not distinguish between activities undertaken in the interests of wildlife welfare or genuine scientific research and those undertaken to support the management of red grouse for shooting. These are fundamentally different purposes and should not be treated equally under a General Licence.

Proposed GL05 – To keep unregistered disabled, wild-bred Schedule 4 birds for rehabilitation
Question 1: Do you agree with a General Licence to permit the keeping of unregistered disabled, wild-bred schedule 4 birds for rehabilitation?

Answer: 5 –  Strongly Agree

I strongly support this General Licence. It is an appropriate use of General Licensing, enabling an activity that directly protects and improves the welfare of wild animals while removing unnecessary administrative barriers for those providing care.

Conditions
Question 2/2b: Do you agree with the conditions proposed under this General licence?

Answer: Yes

I encourage NatureScot to keep the conditions under review in consultation with wildlife rehabilitators and veterinary professionals to ensure they continue to reflect best practice and support positive welfare outcomes for birds undergoing rehabilitation.

I would welcome the annual publication of anonymised, aggregate data on the use of this licence, including the species admitted, numbers of birds received, rehabilitation outcomes (such as release, transfer or death), and, where known, the primary causes of injury or admission. This would improve transparency, provide valuable insight into the pressures facing Scotland's wild birds, and help inform future wildlife conservation, welfare and policy decisions.

Proposed GL06 – To keep unregistered disabled, wild-bred Schedule 4 birds for veterinary treatment
Question 1: Do you agree with a General Licence to permit the keeping of unregistered disabled, wild-bred schedule 4 birds for veterinary treatment?

Answer: 5 – Strongly Agree

Conditions
Question 2a/2b: Do you agree with the conditions proposed under this General licence?

Answer: Yes

As with GL05, I encourage NatureScot to keep the conditions under review in consultation with wildlife rehabilitators and veterinary professionals to ensure they continue to reflect best practice and support positive welfare outcomes for birds undergoing rehabilitation.

Proposed GL07 – To rear unregistered chicks from captive-bred Schedule 4 birds
Question 1: Do you agree with a General Licence to permit the rearing of unregistered chicks from captive-bred schedule 4 birds?

Answer: 1 – Strongly disagree

I strongly disagree. This licence exists to administratively support the captive breeding of birds of prey for falconry and aviculture. I oppose the keeping and breeding of birds of prey (or any wild bird) in captivity for hobby or commercial purposes. The keeping and breeding of wild birds in captivity raises significant animal welfare and ethical considerations, including the lifelong confinement of birds whose biological and behavioural needs are difficult to meet fully in captivity. I do not believe the General Licensing framework should be used to legitimise or facilitate the captive breeding of wild birds for falconry, aviculture, showing or other private purposes. These activities do not benefit wildlife and are not an appropriate use of General Licensing.

Conditions
Question 2a/2b: Do you agree with the conditions proposed under this General licence?

Answer: No

I do not agree with these conditions, as we do not agree with the purpose of the licence itself.

Proposed GL08 – To permit the competitive showing of certain captive-bred live birds
Question 1: Do you agree with a General Licence to permit the competitive showing of certain captive-bred live birds?

Answer: 1 – Strongly disagree

I strongly oppose the use of a General Licence to facilitate the competitive showing of captive-bred wild birds. Competitive showing subjects birds to confinement, transport, repeated handling and unfamiliar environments purely for human recreation, with associated risks of stress and compromised welfare.

I do not consider removing legal or administrative barriers to such activities to be an appropriate use of General Licensing.

I am also concerned that legalising showing for a wide range of species creates demand that indirectly sustains wild-bird trapping and trading pressure more broadly.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

Question 2c: Comment on species you have selected above.

I object to the inclusion of every species listed, and to the concept of a showing licence for any wild bird species.

Question 3: Are there any other species which should be included on this General licence? If yes, tell us which species and why.

No. I propose that no species be shown competitively, and that this licence be withdrawn entirely.

Conditions
Question 4a/4b: Do you agree with the conditions proposed under this General licence?

Answer: No

No. No set of conditions can justify the use of a General Licence to facilitate the competitive showing of captive-bred wild birds.

Proposed GL09 – To keep certain captive-bred live birds in show cages for training purposes
Question 1: Do you agree with a General Licence to permit the keeping of certain captive-bred live birds in show cages for training purposes?

Answer: 1 – Strongly disagree

I strongly disagree with this General Licence. The confinement of birds in show cages to train them for competitive exhibition serves no conservation or animal welfare purpose and unnecessarily restricts their movement and natural behaviours, raising significant welfare issues.

I do not consider it appropriate for General Licensing to remove barriers to an activity that confines and exploits wild birds for human recreation.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence? If no, please provide your reason for not supporting the inclusion of any captive-bred wild bird species, including which species should be included.

No. I do not support the inclusion of any captive-bred wild bird species in a show-cage training licence. No species should be included; I consider the practice of confining a wild-type bird in a small cage purely to train them for exhibition to be a serious welfare and ethical violation regardless of species.

Dimensions
Question 3a/3b: Do you agree with the proposed dimensions?

I wish to comment on all of the items listed: Height 24.13 cm, Breadth 25.4 cm, Depth 11.43 cm.

Question 3c: Comment on dimensions selected above.

I do not agree with any of the proposed dimensions. The minimum dimensions proposed provide insufficient space for birds to express natural behaviours or experience an appropriate standard of welfare. However, my objection is not simply to the dimensions. I do not consider it appropriate to keep wild birds in show cages for training or exhibition, regardless of their size.

Conditions
Question 6a/6b: Do you agree with the conditions proposed under this General licence?

Answer: No

The proposed conditions do not address my fundamental concern with the licence itself. Rather than safeguarding bird welfare, they establish a framework for the routine confinement of captive-bred wild birds in show cages for training purposes. I do not consider this to be an appropriate use of General Licensing and ask that this licence be withdrawn.

Proposed GL10 – To sell certain live captive-bred species of wild bird
Question 1: Do you agree with a General Licence to permit the selling of certain live captive-bred species of wild bird?

Answer: 1 – Strongly disagree

I strongly disagree with this General Licence. It is fundamentally inappropriate for a General Licence to facilitate the commercial trade in protected wild birds. It not only raises significant welfare concerns for the birds involved, but also creates commercial incentives for continued breeding and increases the risk of illegal wild-taken birds being laundered into the captive population.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Blackbird, Brambling, Bullfinch, Reed bunting, Chaffinch, Dunnock, Goldfinch, Greenfinch, Jackdaw, Jay, Linnet, Magpie, Barn owl, Redpoll, Siskin, Starling, Song thrush, Twite, Yellow hammer, Common scoter, Egyptian goose, Ferruginous duck, Garganey, Goldeneye, Goosander, Long-tailed duck, Mute Swan, Red-breasted merganser, Ruddy duck, Velvet scoter.

Question 2c: Comment on species you have selected above.

I object to the inclusion of every species listed.

Question 3: Are there any other species which should be included on this General licence? If yes, tell us which species and why.

No.

Conditions
Question 4a/4b: Do you agree with the conditions proposed under this General licence?

Answer: No

No set of conditions can overcome my fundamental objection that the commercial sale of protected wildlife is not an appropriate activity to facilitate through the General Licensing framework.

Proposed GL11 – To sell feathers and parts of certain dead birds which have been captive-bred or legally taken from the UK
Question 1: Do you agree with a General Licence permitting the selling of feathers and parts of certain dead birds which have been captive-bred or legally taken from the UK?

Answer: 1 – Strongly disagree

I strongly disagrees with this General Licence. It is fundamentally inappropriate for NatureScot to propose a licence whose sole function is to make it easier to buy and sell the remains of protected wild birds. The existence of a market for feathers and body parts perpetuates the commercial exploitation of protected species and undermines the principle that protected wildlife should be afforded greater, not lesser, protection from commercial interests.

Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Mallard, Pintail, Pochard, Shoveler, Teal, Tufted duck, Wigeon, Snipe, Golden plover, Woodcock, Coot.

Question 2c: Comment on species you have selected above.

I object to every species listed, for the reasons given above.

Question 2d: Are there any other species which should be included on this General licence? If yes, please provide justification and evidence for the potential inclusion of this/these species:

No.

Conditions
Question 4a/4b: Do you agree with the conditions proposed under this General licence?

Answer: No

In my view, no set of conditions can overcome the fundamental inappropriateness of using the General Licensing framework to facilitate the commercial trade in protected wildlife or their parts.

Proposed GL12 – To sell certain dead birds which have been captive-bred or legally taken from the European Union
Question 1: Do you agree with a General Licence permitting the selling of certain dead birds which have been captive-bred or legally taken from the European Union?

Answer: 1 – Strongly disagree

I strongly disagree with this General Licence. Many of the species listed are routinely shot for sport, and this licence enables birds killed through recreational shooting to be subsequently sold. The ability to sell shot birds gives them an additional financial value and risks further entrenching shooting interests within wildlife management.

More broadly, I do not consider facilitating the commercial trade in protected wild animals to be an appropriate use of General Licensing, particularly where this may create additional incentives associated with their killing.

Species
Question 2a/2b: Do you agree with the proposed species listed on this General Licence?

I wish to comment on all of the items listed: Coot, Tufted duck, Gadwall, Goldeneye, Canada goose, Greylag goose, Pink-footed goose, Black grouse, Red grouse, Mallard, Moorhen, Grey partridge, Red-legged partridge, Common pheasant, Pintail, Golden plover, Pochard, Ptarmigan, Shoveler, Common snipe, Teal, Wigeon, Woodcock, Barnacle goose, White-fronted goose.

Question 2c: Comment on species you have selected above.

I object to every species listed.

Question 2d: Are there any other species which should be included on this General licence? If yes, please provide justification and evidence for the potential inclusion of this/these species:

No.
Conditions
Question 4a/4b: Do you agree with the conditions proposed under this General licence?

Answer: No

No amendment to the conditions could alter my view that facilitating the commercial trade in protected wildlife is not an appropriate function of the General Licensing framework. I ask that this licence be withdrawn.

Proposed GL13 – To take unsuccessful eggs laid by wild birds from nest boxes
Question 1: Do you agree with a General Licence to permit the taking of unsuccessful eggs laid by wild birds from nest boxes?

Answer: 3 – Neutral

I give cautious, conditional agreement. I recognise that removing genuinely abandoned and unsuccessful eggs can help ensure nest boxes remain available for future breeding attempts, and that requiring individual licences in every case may be disproportionate. However, I believe stronger safeguards are needed to ensure the licence cannot be misused, including safeguards to ensure that eggs cannot be treated as abandoned where human disturbance or deterrence has caused or contributed to the adults' absence.

Conditions
Question 2/2b: Do you agree with the conditions proposed under this General licence?

Answer: No

The proposed conditions would benefit from greater clarity. The licence should define 'unsuccessful' and 'abandoned' eggs using objective, evidence-based criteria, rather than leaving this determination entirely to the operator's discretion. For example, collection should only be permitted after a minimum period of confirmed inactivity has demonstrated that the breeding attempt has failed.

The licence should require reporting of the species, number and location of eggs collected, and confirmation that the eggs were demonstrably unsuccessful. This would improve transparency, enable NatureScot to monitor the use of the licence, and help ensure that collections continue to serve genuine conservation purposes.

Proposed GL14 – To use certain traps to kill stoats for the conservation of wild birds or for prevention of serious damage to livestock

Question 1: Do you agree with a General Licence to permit the use of certain traps to kill stoats for the conservation of wild birds or for the prevention of serious damage to livestock?

Answer: 1 – Strongly disagree

I strongly disagree with this General Licence. I do not believe the killing of stoats for the conservation of wild birds or prevention of damage to livestock is appropriate for a broad General Licence. Preventative and non-lethal measures should be strictly prioritised, including improved husbandry, exclusion and proofing measures, habitat management and, where appropriate, the relocation of animals. Any application to interfere with stoats should instead be considered through an individual licensing process, allowing NatureScot to assess the specific circumstances, evidence and non-lethal alternatives on a case-by-case basis, rather than providing a broad standing permission that facilitates lethal control.

Conditions
Question 2/2b: Do you agree with the conditions proposed under this General licence?

Answer: No

The proposed conditions do not address our fundamental concern that the killing of stoats is being authorised through a broad standing permission. They do not provide sufficient case-by-case scrutiny of the circumstances or ensure that preventative and non-lethal approaches are prioritised. I do not believe additional conditions can adequately address this concern; any intervention requiring a licence should instead be considered through an individual licensing process, with NatureScot able to scrutinise the evidence, circumstances and alternatives in each case.

Proposed GL15 – Sale, advertisement, possession, transportation of Greylag geese, Greylag goose meat by hunters, caterers and retailers

Question 1: Do you agree with a General Licence to permit sale, advertisement, possession and transportation of Greylag geese and Greylag goose meat by hunters, caterers and retailers?

Answer: 1 – Strongly disagree

I strongly disagree. I object to the killing of Greylag geese and other wildlife under General Licences and therefore object strongly to proposals that facilitate the commercial sale, advertisement and distribution of animals killed under those licences. Creating a commercial market for birds killed under licence risks attaching financial value to their killing and undermines the principle that wildlife management should not be driven by commercial interests and based on preventative, non-lethal approaches.

Species
Question 2a/2b: Do you agree that this General Licence is restricted to Greylag goose only?

Answer: No

I disagree with the whole premise of a commercial licence for the sale of goose meat, whether restricted to greylag goose or not, so I cannot support extending it to further species.

Areas
Question 2a/2b (Areas): Do you agree with the proposed areas listed on this General Licence?

I wish to comment on all of the items listed: Orkney, Tiree and Coll, Outer Hebrides.

Question 2c: Comment on areas you have selected above.

I object to the inclusion of all three areas.

Question 3: Are there any other areas which should be included on this General licence? If yes, tell us which areas and why.

No. I propose that the areas covered be reduced to none, i.e. that this licence be withdrawn.

Conditions
Question 5a/5b: Do you agree with the conditions proposed under this General licence?

Answer: No

The conditions fail to address the risk that allowing the sale and advertisement of wild birds creates commercial incentives that are incompatible with the purpose of responsible and ethical wildlife management. In my view, wildlife management decisions should never be influenced, or appear to be influenced, by the potential for commercial gain.

No set of conditions can overcome my fundamental objection that General Licensing should not be used to facilitate the routine killing of wildlife nor commercial markets for them.

Proposed GL16 – Sale, advertisement, possession and transportation of mountain hare and mountain hare meat by controllers, caterers and retailers
Question 1: Do you agree with a General Licence to permit sale, advertisement, possession and transportation of Mountain Hare and Mountain Hare meat by hunters, caterers and retailers?

Answer: 1 – Strongly disagree

I strongly disagree. Mountain hares were given specific legal protection in Scotland in 2020 following long-standing concern, which I share, about large-scale culling on grouse moors and evidence of declining populations and unfavourable conservation status. Introducing a commercial market for mountain hare meat under this licence risks re-creating exactly the financial incentive to kill hares in volume that the 2020 protections were intended to reduce, by giving culled hares a saleable value. As with GL15, this normalises and monetises a cull rather than addressing the underlying land-management practices (in particular driven grouse shooting) that drive the perceived need for hare culling in the first place.

Conditions
Question 2/2b: Do you agree with the conditions proposed under this General licence?

Answer: No

As with GL15, the conditions fail to address the risk that allowing the sale and advertisement of hares creates commercial incentives that are incompatible with the purpose of responsible and ethical wildlife management. In my view, wildlife management decisions should never be influenced, or appear to be influenced, by the potential for commercial gain and should be based on preventative, non-lethal approaches.

No set of conditions can overcome my fundamental objection that General Licensing should not be used to facilitate the routine killing of wildlife nor commercial markets for them.

Shop

donate

Adopt

TAKE ACTION: Respond to NatureScot’s General Licences consultation

© 2025 Protect the Wild | All Rights Reserved