Response 827760873

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Scottish Gamekeepers Association
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Inveralmond Business Centre, 6 Auld Bond Road, South Inveralmond, Perth.
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PH1 3FX.
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Land Rights in 21st Century Scotland

1. Do you agree that the Scottish Government should have a stated Land Rights and Responsibilities Policy?

Please select one item
Ticked Yes
No

2. Do you have any comments on the draft Land Rights and Responsibilities Policy?

Enter comments here.
In the section: Principles. Point 1: public interest and collective benefit, while being laudable aspirations, are difficult to define. They are also subjective and it will be necessary to set out clear criteria to determine how 'public or collective benefit' is decided when substantively differing imperatives arise between national policy and local interests. An example of this would be the building of the Trump golf links at Menie Estate in Aberdeenshire, on an environmental SSSI. How were 'best interests' defined or arrived at by Scottish Government in this case and how transparently were they demonstrated? Point 2: Agreed. Point 3: The terms 'fairer society' and 'social justice' are poorly defined in this context. There is no helpful indication or guideline offered as to how altered land rights can bring about greater societal fairness. Equally, social justice remains a conceptual notion unless rigorously explained. If land reform is to be meaningful to people, it would be best to avoid linking vague strands or concepts. These should be removed. The economic and environmental objectives are more definable and will lead to clearer policy direction. Point 4: Diversity and a dispersed pattern of ownership should not be a goal in itself. It is possible to have a myriad of ownership models all delivering detrimental outcomes. Beneficial outcomes must surely be the goal. The usefulness of Point 4 is debatable, therefore, as Scotland currently has a mix of different types of public and private ownership. Point 5: Agreed. Point 6: Agreed. What is delivered by land ownership in Scotland, as opposed to who delivers it, or the size of holding, should be the guiding principle. Point 7: Public engagement should always be encouraged although decisions should not be made on the basis of majority opinion alone. Policy decisions should be arrived at by taking cognisance of the best available evidence as well as local priorities.

3. Considering your long term aspirations for land reform in Scotland, what are the top three actions that you think the Scottish Government should take?

Action One:
1/ Move ahead with the Registration of land ownership in Scotland, thereby improving the transparent information on land holdings which is publicly available.
Action Two:
2/ Identify clear examples where community right to buy could be used to enable communities to purchase neglected and state-owned land, in the first instance, if the communities desire to do this.
Action Three:
3/ Rather than viewing land reform and changing ownership patterns, in itself, as an outcome, the Scottish government should consult widely, across a broad range of interests, in order to identify clearly what Scotland expects its land to deliver in terms of economic prosperity, employment and opportunity, community cohesion, energy, etc. By doing this, the end result of land reform will be concrete, productive and befitting of modern Scotland. Pursuing land reform as a goal in itself, with no clear image of what these new arrangements will look like and could be expected to achieve, makes land reform appear more an ideological aspiration which may actually prove counterproductive to national long-term interests. For example, land reform should recognise where current ownership/land uses are working well and delivering tangible benefits. These businesses/land use models should then be supported as key deliverers of positive benefit, regardless of whether the benefits are derived as a result of public or private ownership. Without a clear, detailed and fully costed idea of desired result, land reform for its own sake could do more harm to fragile communities than it could deliver in prospective benefit.

A Scottish Land Reform Commission

4. Do you agree that a Scottish Land Reform Commission would help ensure Scotland continues to make progress on land reform and has the ability to respond to emergent issues?

Please select one item
Ticked Yes
No

5. What do you think the advantages or disadvantages of having a Scottish Land Reform Commission would be?

Advantages:
Any Scottish Land Reform Commission, in order to work with credibility, should operate wholly independently from Scottish Government, comprise representatives from a cross-section of the population and contain individuals with a robust working knowledge (through experience) of the sectors likely to be affected, positively or negatively, by changes i.e: in rural areas, working crofters, farmers and land managers as well as landowners and conservation groups, tourism industry workers and other business creators who understand the difficulties of delivering prosperity and other benefits in challenging conditions, should be significantly represented. If the group is set up with the proper breadth of knowledge at its disposal and is allowed to work independently of government, the benefits could be ease and speed of decision making, a clear understanding of what is required to make things work and a sound knowledge of how changes might be applied beneficially at ground level.
Disadvantages:
Possible disadvantages of having a Scottish Land Reform Commission would be the danger that the group could become a delivery arm of whichever majority political administration was in place at the time. Should this happen, it would undermine the idea that those best placed to serve local or community interest are those living and working in those very communities.

6. Do you have any thoughts on the structure, type or remit of any Scottish Land Reform Commission?

Enter comments here.
For the answer to this question, see question 5: Advantages, above.

Limiting the legal entities that can own land in Scotland

7. Do you agree that restricting the type of legal entities that can, in future, take ownership or a long lease over land in Scotland would help improve the transparency and accountability of land ownership in Scotland?

Please select one item
Ticked Yes
No

8. Do you agree that in future land should only be owned (or a long lease taken over land) by individuals or by a legal entity formed in accordance with the law of a Member State of the EU?

Please select one item
Ticked Yes
No

9. What do you think the advantages or disadvantages of such a restriction would be?

Advantages:
Such restrictions may improve traceability and transparency.
Disadvantages:
Making non-EU nationals register a company within the UK is adding another level of bureaucracy and, aside from the possible legal complications and consideration of exemptions, Scottish Government will have to weigh up whether this method of improving traceability is worth creating a potential barrier to inward investment. It may be that there are better ways to improve traceability. Overseas investors currently see Scotland as a desirable place to invest wealth; something which should be celebrated but seems poorly understood and undervalued. This wealth often reinvigorates stagnating communities where opportunity is limited, often by the nature of the terrain, remoteness, lack of visitors, lack of modern communications, centralisation of services, etc. If overseas investors are discouraged from injecting wealth into Scotland, this could have repercussions for a small country which cannot afford to cut existing seams of revenue without just cause. Scotland's rural areas, for example, are only just recovering from the worst aspects of depopulation but its economy remains constantly fragile, with ever-present challenges. The benefits of empowerment aside, because of this, communities are often reticent to enter into ownership as they are aware that assuming the liabilities currently shouldered by a private or other owners would place a heavy burden upon them. This was evidenced in September 2013 when Scottish Government initially granted the lease of stalking and fishing rights on Raasay to a private company in Ayrshire. During re-negotiation on this - resulting ultimately in the rights being given back to the Raasay Crofters Association - the islanders were asked if they would be interested in community ownership options on the island but refused as ownership was not seen as the biggest obstacle to the community’s sustainability.

10. How should any restriction operate and be enforced, and what consequences might follow if the restriction is breached?

Enter comments here
This is something for Scottish Government to decide.

Information on land, its value and ownership

11. Do you agree that better co-ordination of information on land, its value and ownership would lead to better decision making for both the private and public sectors?

Please select one item
Ticked Yes
No

12. Do you hold data you could share or is there any data you would wish to access?

Do you hold data you could share or is there any data you would wish to access?
N/A

13. What do you think the advantages of disadvantages of wider and more flexible sharing of land information would be and do you have any recommendations about how this can best be achieved?

Advantages:
Having more information is always better than having less. However, Scottish Government will have to weigh up the cost of putting this in place this with how useful it will be. For example, information, if not acted upon, is only information. What do public bodies intend to do with this information regarding private land and will this justify the expense of gathering and holding it?
Disadvantages:
See above.
Recommendations for achieving better co-ordination of information on land
No view.

Sustainable development test for land governance

14. Do you agree that there should be powers given to Scottish Ministers or another public body to direct private landowners to take action to overcome barriers to sustainable development in an area?

Please select one item
Yes
Ticked No

15. What do you think the benefits would be and do you have any recommendations about how these can best be achieved?

What do you think the benefits would be and do you have any recommendations about how these can best be achieved?
We do not believe granting such powers to Scottish Ministers is the way to overcome the barriers to sustainable development that we see in rural areas.

16. Do you have any concerns or alternative ways to achieve the same aim?

Do you have any concerns or alternative ways to achieve the same aim?
There are several major concerns with this. Firstly, the statement pre-supposes that barriers to sustainable development are most likely to occur on land held in private ownership. While there is always more people can do, this is merely a supposition and is also open to challenge. No mention is made, for example, of a similar responsibilities being placed upon public bodies or charities (also significant landowners in Scotland) to overcome barriers to economic development on their land. The fairness of this is questionable. Tasking private owners with achieving something national governments themselves have failed to achieve satisfactorily is onerous. Wielding the further threat that they may be forced to release or sell land if they fail in a duty only apportioned to them, is problematic and unlikely to encourage successful private ownership, which should be a national aspiration. We would suggest the principal responsibility of private ownership, like other forms of ownership, is to make a success of whichever enterprise is being pursued. If this is realised, further benefits to society and communities will be derived in terms of employment, opportunity, prosperity, confidence and resilience. We see this frequently in our own industry, where the investment of a landowner leads to employment of gamekeepers and ghillies in an area as well as college trainees, helps support trades and populate schools, produces local food and attracts international tourists to areas which would otherwise contract. If the move towards land reform is to be seen by the public as something more substantive than an attack on private ownership per se, it needs to focus on the specifics truly affecting economic development and less on more semantic arguments of who owns what. No one expects Scottish Ministers to force a land sale on the islanders of Gigha (in community ownership, supported by the Land Fund) because they are experiencing the difficulties of making things work in a challenging, remote, situation. People would instead expect Ministers to give appropriate support and encouragement and this should be expected for private owners, also. For example, if high fuel costs, poor transport links, centralisation of key services and poor or non-existent access to broadband are viewed as major barriers to sustainable economic development in rural areas- and they are- people expect these issues to be tackled appropriately and through co-operation. If land reform can do this, it will achieve something truly worthwhile.

A more proactive role for public sector land management

17. Do you agree that public sector bodies, such as Forestry Commission Scotland, should be able to engage in a wider range of management activities in order to promote a more integrated range of social, economic and environmental outcomes?

Please select one item
Yes
Ticked No

18. What do you think the benefits would be and do you have any recommendations about how this can best be achieved?

What do you think the benefits would be and do you have any recommendations about how this can best be achieved?
We believe Forestry Commission Scotland's role is currently sufficient and wide enough and do not believe there would be benefits in extending their range of powers.

19. Do you have any concerns or alternative ways to achieve the same aim?

Do you have any concerns or alternative ways to achieve the same aim?
While Forestry Commission Scotland should be commended for work such as promoting the health and education benefits of forest exercise and learning and its efforts in renewables, we believe its remit is currently extensive enough. We do not believe FCS, therefore, is the best body to promote social, economic and environmental outcomes in the public interest, on top of its present responsibilities. Scotland's rural landscape is under increasing pressure from development and this will accelerate in the future. Ambitious energy priorities, coupled with Scottish Government's Forestry Strategy, which desires significant afforestation of our landscape if it is to meet its objective of 25 per cent of woodland cover by 2050, means FCS will have a large enough task in balancing the need for an economic timber resource with environmental sensitivity and issues such as tourism/ business impacts. Large scale afforestation programmes, for example, can have significant negative impacts on the availability of suitable habitat and food for species such as golden eagle. If FCS is to be tasked with achieving the Scottish Government's ambitious Forestry Strategy targets, it is almost certain it will have to broach the sensitive issue of the planting of forestry on moorland. Semi-natural moorland is one of the characteristic vegetation types of Scotland and is of global importance. It is a declining resource, a major store of carbon (released into the atmosphere by tree plating) and is a key habitat for iconic species such as red and black grouse, mountain hare, Ptarmigan and Golden Plover. We would suggest it would be a major time and public resource burden to also task FCS with further responsibilities whilst it will have a significant task in delivering current governmental objectives. If land reform is to deliver the best outcomes for Scotland and lead to greater community prosperity, there may indeed be scope for FCS, as a public body, to review some aspects of its existing policy towards the management of deer in Scotland. For example, greater collaboration with local communities could lead to the extension of some employment opportunities for local qualified stalkers within the National Forest Estate, with the venison resource produced remaining in the local food chain as a premium, healthy product, with low food miles. Presently, FCS make significant use of contract stalkers, some of whom are our members, but could also let some of the deer management to local stalkers. Their central management ethos frequently involves making use of special authorisations from SNH for night shooting, which does not carry the same animal welfare assurances as daytime culling. For example, night licenses are not granted in England yet nearly 60 per cent of all deer culled on the National Forest Estate were taken outwith legal seasons (by authorisation from SNH) or at night, in 2013/2014. The venison leaves the locale and goes to one of the larger corporate game dealers in Scotland, missing out local markets. Through greater joined-up thinking and co-operation with the local people in the areas in which they work, we believe FCS could make a significant improvement to community fortunes, now, without the need for Ministers to extend its powers through land reform.

Duty of community engagement on land management decisions to be placed on charitable trustees

20. Do you think a trustee of a charity should be required to engage with the local community before taking a decision on the management, use or transfer of land under the charity’s control?

Please select one item
Ticked Yes
No

21. What do you think the advantages or disadvantages would be?

Advantages:
We believe in co-operation between all land-owners and the communities in which they operate when it comes to management decisions which are likely to have an impact upon others. We believe that this same principal should be extended to all types of landowner. Greater engagement can lead to trust, better working relationships and a sense of empowerment. We have seen, through the work of deer management groups, many examples where positive engagement can bring about the best outcomes. The greatest problems often arise when there has been a lack of, or insufficient, engagement.
Disadvantages:
We perceive there to be no disadvantages to engagement.

22. How should “community” be defined?

How should “community” be defined?
Community is a the sum of people resident in a geographic area.

23. What remedies should be available should a trustee of a charity fail to engage appropriately with the local community?

What remedies should be available should a trustee of a charity fail to engage appropriately with the local community?
Most major decisions over land in the present day require a level of community engagement and support if they are to advance. This is sufficiently understood without having to resort to the imposition of penalties.

Removal of the exemption to business rates for shooting and deerstalking

24. Should the current business rate exemptions for shootings and deer forests be ended?

Please select one item
Yes
Ticked No

25. What do you think the advantages would be?

What do you think the advantages would be?
We would see only a trail of damaging negatives from any move to end these exemptions.

26. What do you think the disadvantages would be?

What do you think the disadvantages would be?
One of the first impacts of the ending of business rate exemptions for shoots and deer forests would be job losses. We have spoken to many in our industry and the stark message is that the likeliest way for such a proposed change to be assimilated by a business is through the loss of a working person. All businesses, whether public or private, need to make management decisions and adjust accordingly. Sporting estates, like agriculture, fishing and forestry are key providers of employment in Scotland's rural areas, with 8800 full-time jobs sustained, not to mention part-time and seasonal workers. There is neither financial wisdom, equity or justification for ending business rate exemptions for shooting and deer-stalking and not doing the same for other rural industries. If this goes ahead, we believe Scottish Government will be responsible for the jobs of many rural workers and their families who would then face great uncertainty in an employment marketplace neither as dynamic or diverse as that of an urban area. It could also have repercussions for family housing, with accommodation often tied with jobs. Scottish Government will have to weigh up whether the loss of employment for people who want to work, often in remote areas, is worth what it will recoup in rates. Singling out shoots and deer forests, solely, for an end to business rate exemptions sends out a clear signal from Scottish Government that it has a subjective preference for how land should be used. In summary, we have stated consistently that trying to alter the distribution pattern of ownership, as an end in itself of land reform, will actually have the unintended consequence of punishing hardest the rural working and their families. We would caution against this and its possible repercussions for community, cohesion, population and family life. In 2013, Peter Fraser, highly respected stalker and SGA Vice President, authored the report, The Economic Importance of Red Deer to Scotland's Rural Economy which focused on deer stalking estates in Sutherland. Accumulated stalking income derived from the estates was £1.6 million. However, the wage bill was £2 million in the same period and the total cost of deer management (to protect crops, minimise environmental impact) was £4.7 million. Instead of being a drain on the public purse, the stalking estates in the report were delivering employment, housing, food, lardering and wider environmental protection at a level which, if passed to the exchequer, would quickly prove unsustainable. Similarly, it does not take Carol Vorderman to work out that, with red deer stalking incomes already diminishing in many parts of Scotland due to less deer, coupled with such moves to end rates exemptions, the likeliest way for a business to cope is by resorting to reduce the number of estate workers, and scale back operations. To substantiate this further, we refer to the 2014 report, The Benefits and Volume and Value of Country Sports Tourism in Scotland, prepared by independent consultants PACEC. Of the 675 respondents, who were providers of country sport activity in Scotland, just over a third of shooting and stalking providers (38%) said shooting at their sites was self-supporting and broke even, while 12% said it was profitable and 22% said it was loss-making but financed by other activities. Three quarters of the providers were open for less than 60 days in the year and in both shooting/stalking and fishing, respondents expressed similar future concerns over the general impacts of rising costs, the regulatory environment on the stock of quarry, value for money and the impact of regulations. We would suggest this is not in the public interest to increase costs for sporting providers at such a critical juncture. Neither would it be in any way beneficial to Scotland's environment or iconic wildlife. In the 2013 paper, Economic Contribution of Estates in Scotland by Rural Solutions and SRUC, commissioned by SLE, of the 277 owner respondents, 186 from that 277 had some sporting interest on their estates. This supported 366 full time jobs and generated £12.4 million. However, expenditure was £16.9 million, including wages of £7.4 million. While this figure does not take account of additional ‘package’ revenue streams such as leisure and accommodation, which helps to make such sporting activity worthwhile, it is further evidence that estates are helping retain employment opportunities in communities; opportunities which other business models would struggle to sustain without significant financial assistance. Margins, then, are tight and measures such as the withdrawal of business rate exemptions for shoots and deer forests, are likely to tip the balance negatively for some. In our estimation- if you scale up this respondent study to cover Scotland as a whole—this move, taken in tandem with other changes affecting sporting operations could lead to the loss of well over 100 sporting-only jobs in rural areas, at the outset, and potentially much more as accumulative regulations take hold. We form this view also from taking soundings from our members across the country. We know that, in 2015 already, for example, many estates with rivers are losing sporting lets due to lack of fish. This is very worrying in an industry worth over £110 million annually for Scotland. On top of this, the uncertainties of land reform plus the potential costs of rod licensing, proposed in the Scottish Government’s Wild Fisheries Review (running in tandem with Land Reform) have led- quite naturally- to a climate where there are business safeguards in scaling down staff. Similarly, in the wake of the first successful Vicarious Liability case, many smaller shoots now face new uncertainty as landowners do not want to end up in court for actions of third parties accessing or shooting on their land. The withdrawal of business rate exemptions, in the context of current challenges and accumulative changes already affecting sporting estates, we believe, would be a serious misreading of contemporary realities and will not be of economic benefit to rural Scotland. In discussions with Scottish Government Ministers on this very issue, we have been told that Scottish Government will defray some of this cost, helping to preserve employment. We look, however, to the stripping of wildlife ranger posts by Forestry Commission Scotland on the National Forest Estate over recent years as an indicator that we cannot guarantee to concerned members and their families that the public purse will pick up the tab or provide job safeguards in the same way they currently are.

Common Good

27. Do you agree that the need for court approval for disposals or changes of use of common good property, where this currently exists, should be removed?

Please select one item
Yes
Ticked No

28. If removed, what should take the place of court approval?

If removed, what should take the place of court approval?
We have no view on this.

29. Should there be a new legal definition of common good?

Please select one item
Yes
Ticked No

30. What might any new legal definition of common good look like?

Do you have any other comments on this issue?
We have no view on this.

31. Do you have any other comments on common good?

What might any new legal definition of common good look like?
We have no view on this.

Agricultural Holdings

32. Do you agree that the Scottish Government should take forward some of the recommendations of the Agricultural Holdings Legislation Review Group within the Land Reform Bill?

Please select one item
Yes
Ticked No

33. What do you think the advantages would be?

What do you think the advantages would be?
We have no view on this.

34. What do you think the disadvantages would be?

What do you think the disadvantages would be?
We have no view on this.

Wild Deer

35. Do you agree that further deer management regulation measures should be introduced to be available in the event that the present arrangements are assessed as not protecting the public interest?

Please select one item
Yes
Ticked No

36. What do you think the advantages would be?

What do you think the advantages would be?
We do not believe this should be a part of this consultation as it is already under timetable for governmental review in 2016. Therefore, we can see no advantages in pre-empting the findings of that review through a public consultation.

37. What do you think the disadvantages would be?

What do you think the disadvantages would be?
We question the motives of including the subject of further deer management regulation in this consultation on land reform as this is currently a work in progress moving towards governmental review, with a timetable for conclusion in late 2016. The arguments surrounding this subject were argued exhaustively at hearings of the RACCE Committee; a clear timeline was put in place for changes and Scottish government provided some resource in order to help local deer management groups publish transparent management plans by 2016. The thrust of this was to give the voluntary deer management structure time to work better, with very prescriptive conditions attached. SNH currently has powers of intervention and, rather than being given more powers in the short-term (before the conclusion of the 2016 review) could use the powers it currently holds. Deer management can be a contentious subject with more and more bodies expressing a stake in it, many with differing views on the importance of deer; their place in public consciousness and as a keynote species defining Scottish landscape. If Scottish Government is to seek to be granted more powers and if the direction of travel is towards greater statutory control of deer management as opposed to local collaboration, which we believe it inevitably is, we feel there would have to be clear guidelines published as to how 'public interest' will be assessed and defined, by whom and in what circumstances any use of new powers would be deployed. Without this, deer could become a political football and deer management driven more by agenda than respect for their national importance.

Clarifying Public Access: core paths planning process

38. At present, section 18 of the 2003 Act is silent on the issue of resolving objections to a core path plan consultation. Do you agree that access authorities should be required, in the interests of transparency, to conduct a further limited consultation about proposed changes arising from objections?

Please select one item
Yes
Ticked No

39. Do you agree that section 20 of the 2003 Act should be clarified so that Ministerial direction is not required when an access authority initiates a core path plan review?

Please select one item
Ticked Yes
No

40. Do you think that the process for a minor amendment to core path plan (as set out in section 20 of the 2003 Act) should be simplified to make it less onerous than that for a full review of a core path plan?

Please select one item
Yes
Ticked No

Assessing Impact

41. Please tell us about any potential impacts, either positive or negative, you feel the draft Land Rights and Responsibilities Policy or any of the proposals for the Bill may have on particular groups of people, with reference to the “protected characteristics” listed above. Please be as specific as possible.

Please tell us about any potential impacts, either positive or negative, you feel the draft land policy or any of the proposals for the Bill may have on particular groups of people, with reference to the “protected characteristics” listed above. Please be as specific as possible.
A significant proportion of our 5300 members are rural workers employed by estates which provide country sport experiences. Their work is often undertaken in unsociable hours, they operate often as lone workers and the rate of pay, like salaries in rural areas comparative to larger population centres, is modest. The dedication to their work gives rise, often rightly, to the expression that theirs is a 'way of life' rather than a means to amass prosperity but the provision of an estate house in which to raise a family acts as a welcome and necessary addition to the wage. As we have made clear earlier in this response, if the marginal profitability of sporting businesses is hit further by measures such as ending business rate exemptions for shoots and deer enterprises, we understand the likelihood is that jobs of gamekeepers, ghillies and pony men will go and staff will be reduced. There are numerous academic papers and reams of official statistics which highlight the fragility of rural economies and point to the resilience of urban economies in comparison, with the advantages of scale, transport, access to modern communications, etc. It is our view, therefore, that some of the proposals relating to sporting estates will, instead of ensuring individuals access benefits, actually exacerbate rural poverty. We have grave concerns over this and caution Scottish Government to take cognisance of this.

42. What differences might there be in the impact of the Bill on individuals and communities with different levels of advantage or deprivation?

What differences might there be in the impact of the Bill on individuals and communities with different levels of advantage or deprivation?
See the answer above.
How can we make sure that all individuals and communities can access the benefits of these proposals?
It would not be possible to make sure all individuals and communities can access the benefits. However, before any substantive change are made, detailed financial costings should be undertaken by independent auditing experts, and, if land reform is to succeed beyond an aspiration in itself, those affected negatively should have their livelihoods secured, as far as possible, so that they can support the land reform journey as equal and empowered individuals. It will also be necessary to recognise where wider community benefits are already being derived from private ownership so the public purse is not being drained simply to try to replicate a model already in existence and funded adequately by private investment.

43. Please tell us about any potential costs or savings that may occur as a result of the proposals for the Bill, and any increase or reduction in the burden of regulation for any sector. Please be as specific as possible.

Please tell us about any potential costs or savings that may occur as a result of the proposals for the Bill, and any increase or reduction in the burden of regulation for any sector. Please be as specific as possible.
Costs: Set-up of a Land Reform Commission. Using public money to support community land purchase through the Land Fund will have to be taken from the budgets for other services. Scottish Government will make some money if it chooses to end the business exemption for shoots and deer forests but this will have to be balanced against potential job losses and falling sporting tax revenues which may outweigh any income gained.

44. Please tell us about any potential impacts upon the privacy of individuals that may arise as a result of any of the proposals contained in this consultation. Please be as specific as possible.

Please tell us about any potential impacts upon the privacy of individuals that may arise as a result of any of the proposals contained in this consultation. Please be as specific as possible.
No comment.

45. Please tell us about any potential impacts, either positive or negative, you feel any of the proposals contained in this consultation may have on the environment. Please be as specific as possible.

Please tell us about any potential impacts, either positive or negative, you feel any of the proposals contained in this consultation may have on the environment.
The potential affects on the environment are many and of great concern to us. It is widely acknowledged that habitat fragmentation is a driver of species decline, along with predation and poor breeding success. In the Scottish uplands we still have the advantages of management at scale which, undertaken responsibly, benefits a whole assemblage of birds and mammals; wildlife which attracts visitors to Scotland. However, both Wales and Ireland are examples close to hand that demonstrate the negatives of the break-up of larger holdings. In Wales, significant portions of the uplands were formerly used for grouse shooting, like several upland regions of Scotland. Predator control and habitat management by gamekeepers was part of the daily stewardship until larger grouse estates began to disappear through grouse decline and the moor lands (devalued because of what they could then be productively used for) were sold off in parcels, with their use changing as a result. Management was withdrawn as part of this change. The consequences for ground-nesting birds has been cataclysmic. The rate of decline of the Curlew, for example, is estimated at between 50-80 per cent in 15 years. It has been predicted the upland wader will be extinct in Wales within a generation. The situation in Berwyn, Wales, was studied by Game and Wildlife Conservation Trust. In 1994, there were 10 active grouse moors in Berwyn, also a Special Protection Area (SPA) for hen harrier, merlin, peregrine and red kite. When grouse shooting disappeared in the late 1990s, studied plots showed that lapwing completely disappeared, golden plover declined by 90 per cent, curlew declined by 79 per cent and Hen Harrier declined by 49 per cent as a result of the loss of red grouse management. Fragmentation of the land, by breaking it into smaller parcels and the change of use away from grouse moor management has now forced Welsh Government to fund projects aimed at trying to halt a serious decline in wildlife. Ireland's story is similar. With Scottish Government's own Forestry Strategy setting a target of 25 per cent of Scotland's land under trees by 2050, we must accept that the move towards habitat fragmentation is already with us. Estates in Scotland currently manage forestry and woodlands as part of their ‘mix’. However, if rough grazing is to be excluded, the scale of afforestation proposed by the Forestry Strategy represents almost a third of Scotland's landscape. Not only will this have a major visual impact on our land and how it is viewed, there will have to be encroachment onto globally rare, species-rich, moorland if targets are to be fully realised. Afforestation poses a threat to golden eagle habitat (linkage of territories) as well as that of other birds. Large conifer plantations also provide cover for corvids and foxes, which predate birds and small mammals. If our landscape is also to support ambitious onshore renewable energy targets, our wildlife faces a very challenging future. Animals much loved by the Scottish public, such as the red deer, will require to be culled in even greater number in order to facilitate increased woodland expansion and any further moves, without very good reason, to fragment remaining habitat should be considered very seriously. If land currently used for grouse shooting loses its value, or businesses find the conditions increasingly trying to sustain a reasonable margin and sell-on value for the land, it is inevitable the land will be sold in lots and, most likely for a different use. Experienced land managers will acknowledge that is not easy to eke out profitability (something the treasury benefits from) on such land, other than for grazing or forestry. The loss of land management staff and predator control will have a detrimental affect on already declining upland birdlife, as was amply demonstrated at Langholm Moor in the Scottish Borders, when gamekeepers lost their jobs as a result of grouse shooting becoming unviable due to predation. There were 75 per cent reductions in wader numbers and the Hen Harrier population crashed from 28 to 2. As mentioned elsewhere in this submission, moves which are more likely to see shoots and deer forests lay off skilled wildlife managers will not only be bad for species, it is likely to be counterproductive for the economy. Aside from the sporting surplus, stalkers also keep deer numbers in check, through agreements with neighbours and local communities. Scottish Government benefits from this management; management which is necessary and would have to be undertaken and funded in another way. Estates and shoots in the UK, according to the 2014 report, The Value of Shooting, by independent consultants PACEC, spent £250 million in 2013 on conservation. In comparison, the RSPB spent £29.6 million on its nature reserves in the same period, with a percentage of that coming from public sources. Scottish Government currently benefits in many tangible ways from the rural stewardship delivered by sporting concerns, although operations are always striving to improve. We hope that, through the process of this consultation, this will be recognised and valued.