Wildlife Management and Muirburn (Scotland) Bill: business and regulatory impact assessment

7. Costs

Option 1 – Do nothing

Glue traps

There would be no additional financial costs from retaining existing provisions. However, the SAWC review unanimously concluded that glue traps cause animal suffering, with the majority of their respondents indicating the likelihood that the use of glue traps causes significant and potentially prolonged animal suffering to the target species. They noted that these concerns are not isolated to a particular aspect of the use of glue traps and even with optimal use (frequent checking and effective dispatch) there remains a significant animal welfare concern. It was their view that there is no way that glue traps can be used without causing animal suffering.

Glue traps are single use and non-recyclable, and so their use results in waste going to landfill.

Wildlife traps, grouse moor management and muirburn licences

There would be no additional financial costs from retaining existing provisions. However, the GMMG found that there were legitimate grounds for suspicion that under the present arrangements, "in at least some estates predator control included the illegal killing of raptors. This inference is supported by the frequent finding of poisoned baits and poisoned birds, traps and other signs of illegal activity".

Doing nothing would ignore those findings, alongside the views expressed in response to Scottish Government consultations that clearly signal the public's growing concerns regarding wild animal welfare.

By not taking forward the provisions in the Bill to further regulate grouse moor management and the use of wildlife traps, the issue of wildlife crime will remain unaddressed, having a negative impact on the populations of raptor species, and the welfare of wild animals.

While the wider impacts of muirburn are highly contested, there is evidence to suggest that muirburn has long-term detrimental impact to blanket bog or wet heath areas, and it has been widely assumed that regular muirburn is detrimental to peat-forming plant species.

The cost associated with not taking forward wildlife trap, grouse moor and muirburn licensing relate to the GMMG conclusion that the existing controls for these practices are not proving effective in guaranteeing appropriate and sustainable management.

Option 2 - Adopt the provisions of the Bill

The estimated financial costs arising from the provisions in the Bill are outlined in detail in the Financial Memorandum accompanying the Bill. There will be general costs to the Scottish Government of introducing and drafting the Bill and drafting the associated guidance. There will also be general introductory costs for many of the organisations involved in relation to staff training and procedural changes.

Glue traps

By taking forward the provisions in the Bill to prohibit the use and purchase of glue traps, most of the market for rodent glue traps in Scotland will be shut down. However, people in Scotland could still buy glue traps to be delivered outwith Scotland and Scottish businesses could still sell glue traps outwith Scotland. This would have an impact on;

• a range of businesses and suppliers who are no longer able to sell glue traps,
• rodent control workers, who are unable to use glue traps in their work, and
• non-professional individuals and businesses, who may have chosen to use glue traps in the absence of a ban but are now unable to.

A ban on glue traps would lead to reduced options in dealing with rodent problems. Some stakeholders suggest glue traps can, though not always, catch their target in a shorter time than more traditional traps or poisoned baits can take days.

Individuals and businesses will be required to adopt other methods of rodent control, such as snap traps, spring traps and poison. Some individuals and businesses may require a combination of these methods.

Professional rodent controllers may, in certain circumstances, be required to use less efficient methods of rodent control. In this case, they would either incur additional costs because the interventions they do are more time consuming, or they pass these additional costs on to customers and risk losing business as a result of the higher prices.

There may be costs associated with the enforcement of these provisions, but they are expected to be low once suppliers reduce the availability of glue traps.

Wildlife traps, grouse moor and muirburn licences

It is anticipated that changes to the legislation made by the Bill may initially result in a small increase in court cases relating to wildlife offences because the provisions in the Bill will aid the enforcement of the existing wildlife legislation. However, the broader expectation is of a longer-term reduction in the total number of cases as a result of increased regulation through licensing, training and codes of practice.

There will also be a cost to NatureScot as the designated authority responsible for issuing licences to use specified traps, manage grouse moors and make muirburn. This cost will not be passed on to the applicant however, as NatureScot do not currently charge for any licences relating to wildlife management.

However, although NatureScot do not currently operate licences on a cost recoverable basis the Scottish Government/Scottish Green Party Shared Policy Programme contains the commitment to review the wider species licensing system and assess the potential to apply the principle of full cost recovery to species licensing. The Bill will therefore include provisions to allow for the possible introduction of charges for licences issued under these provisions at a later date. This may result in a future cost to individuals and businesses applying for a licence, but as part of the review, consideration of those impacts will be examined.

The public consultation highlighted that individuals and businesses may see costs associated with the gathering, organising and presenting information to the licensing authority, and then complying with licence conditions, although in some cases these costs may be minimal.

Costs associated with the muirburn licence requirements, for example, developing and presenting a muirburn plan, and assessing peat depth across wide areas, may be more significant. However, due to the way in which muirburn is currently undertaken, the Scottish Government does not have data to estimate these costs. The impact of these requirements on those applying for licences to make muirburn on peatland will be considered when the licensing scheme is developed.

The Scottish Government and NatureScot as the Licensing Authority will work with stakeholders to ensure that costs incurred by applicants in this regard are kept to a minimum and the licensing schemes do not place an undue or unnecessary administrative burden on businesses.