Goose management policy in Scotland: 2010 review

3 National policy framework: structure, delivery and effectiveness

3.1 Institutional structure

The structure set up by the Scottish Executive in 2000 to deliver the National Policy Framework ( NPF) consists of: the NGMRG, the national consensus building and coordinating body; local goose management groups ( LGMGs) which were also designed as consensus building and policy delivery institutions at local level; and GSAG, a scientific advisory body. SNH is heavily involved in supporting the framework by acting as the funding conduit and providing administrative capacity at both local and national levels. It also intervenes independently in goose management.

The key characteristics of the NPF are:

• Core objectives sufficiently broad to allow negotiated policy development within the constraint of meeting the UK's conservation obligations.
• Consensus seeking at both national and local levels as a central element in the process of reviewing and delivering policy.
• A high measure of devolved management to local level.

Here we review the effectiveness of the various institutions in their delivery of the NPF.

3.2 National Goose Management Review Group

The NGMRG convened in 2000 to implement the framework ¹¹. Its main functions were to (Scottish Government, 2010):

• Implement the national policy framework.
• Advise Scottish Ministers on goose management in Scotland in relation to the effectiveness of, and any potential need for adjustment to, goose management in Scotland.
• Conduct a multi-disciplinary review of the national policy framework every five years.
• Evaluate (and approve or not approve) proposals for new schemes.
• Carry out an annual assessment of existing schemes.
• Assess the results of monitoring of goose populations.

The powers given to the NGMRG are central to its ability to deliver on the NGF objectives. NGMRG does not have explicit powers to proactively establish LGMGs or to make robust interventions into the activities of LGMGs once they are approved, although it does have the power to recommend termination of a LGMS if necessary. In principle, it cannot intervene directly to secure policy objectives unless a LGMG is formed and puts a proposal for a LGMS before the NGMRG. In the absence of such action, the NGMRG must act indirectly to influence policy by providing appropriate advice to Scottish Ministers. However, in practice the NGMRG can attempt to negotiate changes in structures or mechanisms that it considers desirable. The NGMRG commands a budget indirectly through Scottish Ministers. Thus NGMRG contrasts with SNH, which can set up and direct management agreements and schemes proactively.

3.2.1 Recommendations of the 2005 review

The NGMRG (2005) review produced 31 recommendations which included re-formulated objectives, recommendations regarding the status and protection of different goose species and guidelines for LGMSs set up by local groups. The slightly modified objectives proposed by NGMRG in the 2005 review were as follows:

• To meet the UK's nature conservation obligations, within the context of wider biodiversity objectives;
• To minimise economic losses experienced by farmers and crofters as a result of the presence of geese; and
• To maximise the value for money of public expenditure.

These objectives together with the 31 recommendations act as a set of principles that have underpinned policy and its delivery since 2005. In Appendix A the implementation of each of the 31 recommendations is reviewed. The majority have been implemented satisfactorily or involve no change from policy in 2000. A small number are either not formulated in such as way as to allow implementation (either through a lack of clear definition or because the mechanisms for implementation do not exist) or do not indicate clear responsibilities for implementation.

3.2.2 Effectiveness of NGMRG in delivering the remit

The NGMRG was set up to deliver the NPF and fulfil other functions as indicated above. Implicitly it was also expected to deliver the NPF core objectives. The NGMRG recommended the establishment of seven local goose management groups ( LGMGs) covering the major locations where there were significant administrative goose issues. LGMGs are assessed mainly through annual reports to the NGMRG, periodic visits by NGMRG representatives to examine how schemes operate in practice, and direct contact with SG and SNH representatives. NGMRG conducted a review in 2005, which was well received by Scottish Ministers who approved its recommendations.

The NGMRG has played a successful part in reducing tension on goose issues in most locations where LGMSs are in operation, and in establishing effective collaboration between stakeholder groups at national level. Both Scottish Ministers in their comments on the 2005 review and all other national stakeholders considered the NGMRG a valuable, consensus-building and partnership activity. Many stakeholder representatives on the NGMRG were appreciative of the opportunity to contribute positively to goose management. In political terms, the NGMRG provides a useful forum to which SG and SNH can refer goose issues for advice and action.

However, in terms of delivering on the policy objectives, success appears less categorical. SNH consider that the UK has failed to deliver on its legal obligations for the Greenland White-fronted Goose because of the decline in numbers and the disappearance of several small wintering flocks. Nevertheless it is not clear that NGMRG could have contributed more given the restricted range of influencing mechanisms open to NGMRG and the uncertainty concerning the factors responsible for population decline (see Section 2.5.3). NGMRG and GSAG have certainly discussed the issues surrounding the decline of Greenland White-fronted Geese in Scotland and thus ensured that Scottish Government was made aware of these issues. NGMRG and GSAG do not appear to have explicitly addressed the fact that the Islay Local Goose Management Scheme may not have given specific focus to Greenland White-fronted Geese in their intervention mechanisms on Islay.

More generally, implementation of the NPF has resulted in generally increasing goose populations with an increasing social and public expenditure cost associated with damage to agriculture, and possible negative impacts on other species (e.g. as reported in the Uist 2009 scheme report to the NGMRG). The NGMRG has thus contributed to the formulation and delivery of SG policy that is increasing costly to maintain and for which there are no in-built limits provided by target populations or budgetary ceilings. The only limits that may exist are thus natural (environmental carrying capacity; predators). Policy has supported substantial increases in Barnacle, Greylag and Pink-footed populations to a point where the value for money of increased numbers is questionable, and in an era of reduced public expenditure possibly unsustainable ¹².

Our discussions with stakeholders and our examination of how the institutions operate indicate a number of other aspects of policy delivery that are worthy of comment. These are:

• Information - The annual assessment of schemes is limited by a lack of detailed information and analysis ¹³. Not all LGMGs report their monitoring and payment systems in a consistent and transparent way, such that information is often difficult to interpret ¹⁴. This makes the assessment of schemes difficult and the more detailed analysis in the current review is sometimes at variance with the assessments given in the NGMRG minutes. Improved information and analysis are required in order that the NGMRG can base its interventions on appropriate reporting of local scheme data and its analysis.
• Governance and audit - We have been unable to locate any formal scrutiny or audit of LGMG payment systems. Neither SG or SNH have been able to identify clear lines of responsibility for audit, although it would appear that NGMRG has some relevant powers in that it has intervened to correct financial mismanagement on more than one occasion. Given a situation in which those directly or indirectly instrumental in determining the allocation of funding are also recipients of funding, the establishment of more transparent allocation processes and formal procedures for scrutiny would be highly desirable.
• Delivery of national policy - Following the annual assessments of LGMSs, and at other times, the NGMRG typically responded to local groups by 'expressing concern' over certain matters. These concerns have often not been acted upon by the LGMGs, presumably because an LGMG takes a view different from the NGMRG and is under little pressure to change. The evidence is that NGMRG has not always been able to effect modifications to aspects of schemes that it finds unsatisfactory. This is presumably because the NGMRG finds it difficult to operate except through negotiation and consensus, its policy delivery powers being limited by the balance between centralised and distributed decision making.
• Success of local groups ¹⁵ - The success or otherwise of local groups in part reflects the role of the NGMRG in agreeing to their proposed structure and funding. In terms of achieving a local consensus (which underpinned the NPF) five of the seven groups have performed well in creating excellent partnerships between the interest groups and minimising tension between potentially conflicting interests (see below). Two (Uist, and Tiree and Coll) have been less successful although this is in part a reflection of the limitations on intervention imposed by the existing distribution of shooting rights on land under crofting tenure.
• Communication between NGMRG and the LGMGs - A number of local groups felt that communication between the NGMRG and the local group could be improved to increase the effectiveness of the schemes: One LGMG commented that "communication from the NGMRG to the groups is sporadic, slow to filter down and often focuses on issues which could have been dealt with very quickly if the local group chairman had been able to attend NGMRG meetings to answer questions. Links to wider stakeholders through the national group could be improved". The slow response presumably reflects the fact that the NGMRG meets quarterly and decisions are mainly left to such meetings in order to ensure consensus.

3.3 Local goose management groups

3.3.1 Remit and situation

Seven LGMGs have been established following acceptance of their proposals by the NGMRG. As such they have no constitution and no remit other than the objectives contained in their proposals and any conditions initially imposed by the NGMRG. All LGMGs stated that they have adopted the national objectives given in the 2005 recommendations (See Appendix G), although some do not list these in their annual reports. Most LGMGs have felt it necessary to define local objectives, in part because the national objectives provide a substantial degree of policy space and local group objectives need to be more focussed.

Table 3.1 gives some basic characteristics of the seven local groups. The schemes are quite diverse and many stakeholders regarded this as a strength of the NGF structure - that schemes were designed to fit local circumstances. To a degree this is essential because schemes must account for the variability in farming enterprises (and associated damage), variation in the seasons at which damage occurs and differences in the aspirations of farmer/crofters in how best to respond to damage. It was surprising that some schemes had substantial populations of more than one species but in their reports (which presumably reflected their activities) did not specify the species present or differentiate their policy according to species. This casts some doubt on the effectiveness of such schemes in delivering conservation objectives for individual species.

Appendix G describes each of the seven local groups and analyses their activities, cost and impacts in detail. Chapter 4 deals in more detail with the cost-effectiveness and value for money of the groups. Here we discuss some generic aspects of the effectiveness of the groups structure in:

• Meeting conservation obligations.
• Minimising economic losses experienced by farmers and crofters
• Reducing conflict.
• Delivering value for money.
• Communicating with the NGMRG.
• Implementing NGMRG recommendations.

Table 3.1 Characteristics of the local goose management groups

Local goose management group	Species targeted	Season	Management agreements with farmers or crofters (payments made)	Shooting occurs on farms/crofts within scheme?	Conflict reduction in the farming or crofting community
Islay LGMG	Barnacle and Greenland White-fronted	Winter	Yes	Barnacle under licence	Good
Kintyre LGMG	Greenland White-fronted	Winter	Yes	No	Good
Solway Barnacle Goose Management Scheme	Barnacle	Winter	Yes	No	Some concerns from excluded farmers
Loch of Strathbeg LGMG	Not specified but mainly pink-footed	Spring	Yes	Greylag and Pink-footed	Good
South Walls LGMG	Barnacle	Winter	Yes	No	Concerns from excluded farmers and those not receiving payments
Tiree and Coll Goose Management Scheme	Not specified but principally Greylag	Summer	No	Greylag	Partial
Uist Greylag Goose Management Scheme	Greylag	Summer	No	Greylag	Partial

Meeting conservation obligations

The extent to which the goose NPF has been successful in meeting the UK's conservation obligations is addressed in Section 2.6).

Minimising economic losses experienced by farmers and crofters

Measuring the absolute costs of goose damage was not within the agreed remit of the current review. However, participation levels approaching 100% of those eligible in most of the payment schemes (see Appendix G for details) and the contentment with payment rates evident in our interviews indicated that payment rates were sufficient to more than cover the costs of contract obligations (restrictions on scaring etc.) in most cases. A small number of farmers were dissatisfied either because they considered the goose counts were too low or because they were excluded from schemes despite suffering damage. Appendix G gives more detail on these aspects.

In the Western Isles (where no payments were made) there was dissatisfaction amongst some of the crofting community because economic losses were continuing despite the existence of the scheme. However, considerable progress had been made in addressing the cause of the damage by reducing the Greylag Goose population and it is not clear how any scheme could remove all goose damage while geese remained present (see Appendix G).

Reducing conflict

The National Policy Framework was developed to resolve a situation of major conflict particularly on Islay and principally between farmers and SNH. Damage from geese, the impact on farm incomes and the inability of farmers to act because of perceived restrictions on shooting resulted in a politically fraught situation.

National and local stakeholders were generally very positive about the success of groups in reducing these historic goose-related tensions. SNH, for example, valued the structure because the group was the key to resolving issues and this had produced positive benefits in terms of good relations with the farming community which allowed conservation (not just goose-related conservation) to proceed more cooperatively.

In five cases, the groups had achieved very good working relations amongst the interests represented (Table 3.1). In Solway, for example, the group reported "broad support for the Scheme which had considerably reduced the animosity towards geese that had developed prior to the Scheme. Overall, the Scheme has allowed a conflict situation to be resolved and a considerable degree of co-operation achieved in the management of geese".

On Islay, the scheme has delivered very good working relationships with all interests, and the Islay LGMG note that "the current arrangement has resulted in more efficient delivery, a joined up approach, and better protection of geese. The flexibility within the scheme has meant adjustments to suit local situations have been quick and easy to make, particularly as most of the day to day decision making can be done on the island".

The Kintyre LGMG considered that "the local set up with statutory organisations, farmers and stakeholders making up the membership of the local goose group has resulted in a better understanding of all the issues relating to goose management across the board, a feeling of local involvement, use of local expertise in the development of the scheme and a sense of local ownership in the day to day running of the scheme". These comments are typical of the majority of the groups.

However, some groups have adopted policies aimed at concentrating geese in certain areas and this has left excluded farmers suffering goose damage without any direct contribution to costs. The Islay group (which does not have this policy) noted that "in the past individual goose management agreements focussed on a few areas located within protected sites. Whilst these agreements worked to the satisfaction of the individual farmers they did not contain the goose population within the protected sites and there was a great deal of dissatisfaction from farmers outwith these areas who could not enter into these agreements but who still had to support feeding geese". LGMSs which aim at concentrating geese (Solway, South Walls) both have tensions from farmers not receiving payments. It is true to say, however, that tension would be much greater were there to be no scheme at all.

The Western Isles LGMGs (Table 3.1) did not appear to have achieved a good consensus and the schemes were not totally fulfilling local ambitions (see Appendix G 2), although considerable progress had been made during the five-year life of the schemes. The ambitions of the crofting community for reductions in the population of geese (and hence damage) are difficult (and may well be impossible) to achieve due to the control of shooting rights by the estates and a budget that was insufficient to enable more complete goose control, even if further control was deemed acceptable from a population management viewpoint.

Delivering value for money

The cost-benefit analysis undertaken for NGMRG (2005) concluded that "compensation payments made by the government to farmers for damage caused by wild geese represent good value for money to the tax-payer". Local schemes used this as the basis for arguing that their schemes delivered VFM. However, we question the continuing validity of this conclusion in areas where goose numbers have increased. This is discussed in Section 4.

None of the participants in local schemes had any strong incentive to improve the VFM of their schemes. The overriding concern in the majority of cases was to obtain sufficient funding to remove tensions between farmers, conservation interests and government. This is entirely explicable because good relations with farmers improve the quality of life for those officers involved and allow other environmental objectives to be more easily delivered.

It could be argued that the SGRPID chairman and SNH secretary have a particular responsibility to ensure payment rates represent good value. But this is unrealistic under the current arrangements. With a goose budget separate from the SNH budget there is no in-built trade-off that would affect the ability of SNH to deliver on its other obligations, and hence no incentive to moderate budgets. The SGRPID chairs are confronted with the dual and ambiguous roles of SGRPID representative and independent chairperson, which represents a conflict of interest in the context of seeking VFM. The chairs also have little incentive to restrain bids for funding since maintaining a local consensus is inevitably their primary aim.

Communication with the NGMRG

We found the annual reports from the LGMGs extremely variable in information and quality. Whilst some were thorough and provided a clear picture of the performance of the scheme others did not give adequate data on numbers, trends or payments that would allow any serious assessment of the scheme. This could represent a strategic decision to under-inform the national group. On the other hand it may reflect an inadequacy in local SNH or SGRPID resources allocated to the group and uncertainty about what information the NGMRG require. Whatever the reason, it leads to difficulties in interpreting the reports.

Some chairmen would have valued representation on the NGMRG but the national stakeholders were not generally in favour of this because of the risk of concentrating on local rather than national or more strategic issues at meetings. We concur with this view but asking chairmen to present and discuss their reports in person or via video conferencing at one meeting annually would facilitate improved communication and feedback.

Implementing NGMRG recommendations

All the LGMGs considered that they had implemented these recommendations in the sense that the schemes conformed to the recommendations ( Appendix G). None indicated that scheme design or operation had changed as a consequence of the recommendations, nor was it clear that in all cases LGMG committees had considered them. Some recommendations were difficult to interpret (e.g. as regards the achievement of value for money) and others were ambiguous (as regards innovation and dissemination of best practice and the setting of targets). Whilst all groups claimed that they adhered to the core NGMRG (2005) objectives this was not apparent in all annual reports. Even so, in broad terms we concluded that all schemes could argue that they were compliant with those recommendations that were within their remit to adopt.

3.4 GSAG

GSAG was set up primarily to advise the NGMRG on scientific issues regarding Scottish goose populations. The group is chaired by SNH's Head of Science. Secretariat support was formerly provided by SG but this role has been temporarily adopted by SNH until other arrangements can be made. The group meets at least once a year and minutes are usually uploaded to SG web pages (although there have been omissions over the last few years due to the uncoordinated change-over of the Secretariat role). Representatives on GSAG are from SNH, RSPB, BASC, WWT and SASA who are all employed as scientists within their own organisations.

GSAG is responsible for overseeing and making recommendations for the monitoring of goose populations in Scotland. It also reviews the monitoring from the LGMSs and advise NGMRG of any notable changes in population numbers. In addition, GSAG has advised SNH on the commissioning of a series of Population Viability Analyses ( PVAs) for the main wintering population of geese and reported back to NGMRG the main findings and the implications for future management and policy making. The group is also involved in making recommendations for future research into goose populations.

Strengths of GSAG include the ability to draw on a wide range of strong scientific expertise and applied experience from a number of organisations with varying goose-related interests. These include representatives from a number of NGOs, who provide their input voluntarily and this in-kind advice represents very good VFM. It is important to ensure that representatives of organisations sitting on GSAG remain of high scientific standing in the future. Recommendations made by the group are reached by consensus and should be based on objective evaluation of the scientific evidence presented. The experience of the current review has been that the advice provided by GSAG is scientifically rigorous and objective, and does not stray into policy advice. However, this may be more difficult to ensure in future if there is an increasing need for GSAG to advise on adaptive management-type approaches to managing goose populations more proactively ¹⁶.

The Chair and Secretary of GSAG play key roles in terms of taking forward the advice of GSAG effectively, and interfacing effectively with NGMRG. It is important that these key staff have sufficient time allocated each year for these GSAG responsibilities.

One criticism of GSAG has been made by LGMGs over the lack of dissemination of relevant research. GSAG feel that there is scope to provide a website to publish summaries of the main findings and from which reports could be downloaded. We conclude that the ability of GSAG to communicate their scientific advice and findings more widely (e.g. with LGMGs) is limited by resources. The translation of documents discussed by the scientists on GSAG into a form suitable for wider dissemination requires time and appropriate expertise (from scientists who work regularly at the interface between science and public understanding). It would be useful for GSAG to produce short briefings in an accessible style on the key issues that they discuss, for regular dissemination to all the LGMGs (links to a website providing more information could be offered).

3.5 SNH

3.5.1 Role in the National Policy Framework

SNH provides the Secretariat for the NGMRG and currently also GSAG. It provides the funding conduit for the local schemes, organises the contracts with farmers and administrates the schemes at local level through their regional offices. It also intervenes in goose management with its own schemes and agreements.

Within the NPF payment schemes there was strong appreciation from participants with regard to the efficiency with which contracts and payments were administered, and with the general responsiveness of staff to issues. The most common negative comment from a small minority of participants was that counting systems in use underestimated the total number of geese on their fields during the year. SNH also organise scaring and shooting where this is part of the LGMG plan. There was criticism from some farmers as regards the level of support and its responsiveness to perceived needs but overall SNH delivered these services well.

The payment schemes, with the exception of Strathbeg, are 'light touch' with few contractual obligations, minimal compliance monitoring and minimal penalties for non-compliance. SNH was unclear on where responsibility lay for the financial probity and auditing of payments. This clearly needs clarification. The effectiveness of the scheme would be improved with levels of scrutiny and penalties for non-compliance typical of the SRDP, with which farmers are familiar.

There are no payments under the summer schemes so financial and scrutiny issues are less relevant. But there was less enthusiastic comment from crofters and farmers on the SNH roles in the summer goose schemes and this reflected the schemes' lack of success in building local partnerships and meeting local needs. These aspects are discussed in Appendix G.

3.5.2 Direct intervention in goose management

SNH launched a 5-year Species Action Framework in 2005 ( SNH, 2005) with the Greenland White-fronted Goose as a named species. The aim was to halt the decline in the population by 2010, and to maintain and, where possible, enhance its wintering range. The limited measures proposed under the Framework were additional to the measures introduced through NGMRG. SNH has not yet reported on the outcomes of the Framework.

SNH operates a number of Management Agreements ( MAs) that relate partially or wholly to geese. Brief details of these are included for completeness in Appendix H. They are typically small scale and often relate to a single farm where ( EU Birds Directive Annex 1) geese graze. These expenditures and their effectiveness have not been formally reviewed as part of the current study.

The SNH management agreements fit well with the larger NGMRG/ LGMG schemes in providing a comprehensive suite of mechanisms for the delivery of policy. Stakeholders have indicated that SNH confer with NGMRG on how best to respond to new challenges that relate to geese.

3.6 Conclusions

The NGMRG in its delivery of the NPF has produced a degree of harmony between interest groups, and contributed to substantial increases in some Annex 1 goose populations, but at considerable and increasing cost to the taxpayer. Whilst it can be said to have generally delivered on its objectives (conservation obligations for Greenland White-fronts apart), these objectives define a very broad policy space and one which has little focus.

The institutional structure has been less successful in delivering in areas where farmers/crofters' preferences are for reduced goose populations rather than management agreements (with payments involved). A number of factors may explain this lack of effectiveness. A consensus for population control/reduction is harder to achieve than one based on management agreements and this has limited the extent to which conservation interests will support such a policy. In addition, where shooting licences are essential to secure effective population management, the level of shooting is typically restricted by constraints in the licensing system. Finally, the ownership of shooting rights may be such as to restrict shooting especially on crofts. In general, there has not been a coherent intervention through policy to limit the increasing damage cost associated with the expansion of the Scottish goose population and this has left a situation that remains to be addressed.

There are several areas where it appeared that the institutions could operate more effectively. The NGMRG could be better informed about the operations of local schemes and undertake or require more rigorous analysis of effectiveness. Neither the annual reports nor the local databases provide the information that the NGMRG needs to assess policy delivery. The responsiveness of NGMRG to local schemes was slow, although this might reflect the constraints imposed by consensus management or the resources available ( NGMRG Chair and Secretariat). Local governance was at times questionable and responsibility for scrutiny and audit uncertain. The extent to which schemes could be said to be equitable also differed.

SNH has no specific goose policy but does intervene through the Species Action Framework (Greenland White-fronted Goose), designated sites, and Natural Care (Management Agreements). Its activities appear to complement those of the NGMRG.

This review concludes that GSAG is successful within its original remit of providing advice to NGMRG on scientific issues relating to geese. This is largely due to having the involvement of experienced scientists from a wide range of organizations, who reach a consensus and objective view of key scientific evidence for dissemination to NGMRG. There is scope however to improve reporting back directly to LGMGs and making them aware of evidence available, which could help inform management of goose populations within their schemes. GSAG may find it more difficult to stay focused on science issues and not stray into policy in future if there is an increasing need to advise on proactive management of goose populations, and external independent scientific advice may be required as additional policy support.

In summary, the NGMRG in its implementation of the NPF has been highly successful in delivering a policy acceptable to most stakeholders and reducing tension that existed previously. Policy now needs to address the consequences of increasing populations of most species with associated increases in damage costs ¹⁷ and escalating budgetary expenditure. These changes raise questions about the longer-term effectiveness of the framework, its delivery and the associated legislation. The resilience of the consensus-based framework in the face of any substantial cut in the budget is also questionable.