Ravens could be culled in Scotland, while badgers are threatened with mass slaughter in England…
and Network Rail chops down thousands of trees in a nationwide programme of “vegetation management”
August 28th 2018
This year has seen a number of initiatives by the UK Government in pursuit of a commitment to “leave our environment in a better state than we found it.” In January, the Government published a 25-year plan that sets out its ambitions to improve the environment within a generation . In February, it launched a consultation on its proposals to replace the Common Agricultural Policy with a policy that will reward farmers for making environmental improvements . And in April, new rules for farmers came into force, designed to protect water quality, reduce the risk of pollution, and prevent soil erosion .
In stark contrast to these plans and goals, however, the last three months has seen a licence to cull ravens in Perthshire, issued by Scottish Natural Heritage; a proposal from the UK Government to extend the cull of badgers in England; the destruction of habitat in Clashindarroch Forest in the Scottish Highlands due to logging by the Forestry Commission, which threatens the survival of the few remaining wildcats in the UK; and the destruction of large swathes of wildlife habitat across the UK by Network Rail. Whilst government ministers may voice their aspirations to “leave our environment in a better state than we found it”, the rift between rhetoric and recent activities on the ground seems glaringly obvious and shocking in its polarity.
Licence to Kill – Ravens in Scotland
On 4th April 2018, Scottish Natural Heritage issued a “research licence” to a group calling itself the “Strathbraan Community Collaboration for Waders”. The licence permitted the culling of ravens in an area of Perthshire. The reasoning behind this decision was provided a month later in a response to a petition started by Alison Lowther on Change.org, calling on Scottish Natural Heritage to stop the cull . The Chair of Scottish Natural Heritage (SNH) said that wildlife legislation permits the control of birds, plants and animals, on the condition that their wider populations are not affected. Under this legislation, he continued, Scottish Natural Heritage regularly issues licences to control a range of birds and mammals including corvids (i.e., members of the crow family, which includes jackdaws, rooks, crows, and ravens):
“These activities are widespread and are carried out by farmers, gamekeepers and conservationist organisations alike in order to protect bird populations that are at risk. Curlew and lapwing are listed as Red status in the Birds of Conservation Concern (BOCC) review, with declines in abundance of over 50% in the past 20 years. They are also listed as Vulnerable at a European level. Ravens are currently on the Green list with no indication that licensed control is having any impact on the population of this species. This trial will help us and others to better understand the impact of ravens on species in grave danger.”
Alison Lowther responded with a further letter to SNH, pointing out that there was no evidence that ravens were contributing to the demise in wader populations, and that the Chair’s response provided inadequate justification for the cull. The letter was accompanied by an updated petition that had now reached over 120,000 signatures. SNH responded by treating this further letter as a formal complaint which had now reached the second and final stage of its complaints handling procedure. The final response was delivered in June by email, in which the Chair outlined further the rationale for SNH’s decision and provided further details of the licence. Further dissatisfaction, he said, would mean asking the Scottish Public Services Ombudsman to investigate the complaint.
Ravens versus Waders: A numerical problem?
The email from the SNH Chair states that the licence was granted for the purpose of “Science, Research and Education” and permits the control of “up to 69 ravens this year over an area of around 30,000 hectares.” The Chair says that SNH is confident that this will not affect the wider conservation status of ravens in Scotland on the basis of recent modelling work on raven populations undertaken on its behalf by the British Trust for Ornithology. The research project may run for up to five years, with annual reviews of its progress before granting further licences. The aim of the research is to investigate whether there is a statistical correlation between the size of the raven population and wader productivity:
“Populations of some of our wading bird species are declining rapidly. The causes of these declines are not fully understood but predation, habitat quality and climate are all likely to be important factors. Declines are largely thought to be due to low levels of productivity rather than adult survival, and studies involving the removal of predators have been shown to boost productivity.”
However, the Chair continues, many of these studies have looked at the removal of species that can either be controlled without a licence (such as foxes), or of protected species that can already be controlled under a general licence (such as crows), which means “that it can be difficult to differentiate between the relative impacts of these species and that the impacts of any other predators, including ravens, are poorly understood.” Further rationale is provided as follows:
“A correlative study looking at the relative abundance of ravens and productivity of waders found no significant relationship between the two but did find a weak negative relationship worthy of further investigation. Furthermore the data used for this study is now quite old and in the meantime the abundance of waders has decreased further, whilst raven numbers have increased…This community-led proposal aims to compare productivity of curlew, lapwing and golden plover in the study area before and after licensed reduction in raven numbers. Productivity data is also being collected outside of the licence area and the land is managed positively for waders.”
The Chair says that SNH accepts “that this proposal is not a full-scale academic study.” However, he continues, “the project is designed to help contribute to our understanding of the factors affecting wader populations, the usefulness (or otherwise) of potential interventions for their conservation, and the feasibility of these more adaptive, community-led and co-productive ways of working. This proposal is about testing an approach, on a limited scale and for a limited time-period, and adapting it if needed, in order to improve our understanding. The potential benefits of the project in this respect outweigh the impacts of the proposal on raven populations.” The Chair also states that SNH’s Scientific Advisory Committee are currently reviewing the application “and will report their findings to the SNH board who will in turn consider how best to proceed in light of that information.”
The rationale concludes on a note of desperation:
“I appreciate your concerns over this licence. However, given the plight of our waders we need, with some urgency, to look at the suite of actions available to everyone to better understand and address these declines. This is one such approach. Building on the outcome of the SAC review and some of the concerns raised over the proposal we will work with the applicant and others to ensure that we can maximise this learning without detriment to the wider raven population.”
In response, Alison Lowther submitted a complaint to the Scottish Public Services Ombudsman, who said that the decision to award the licence was now the subject of a judicial review lodged by the Scottish Raptor Study Group; the Ombudsman could not investigate the complaint due to the potential conflict with those legal proceedings.
RSPB Scotland is “outraged” by SNH decision
Meanwhile, in a blog post on the 24th of April, Duncan Orr-Ewing, RSPB Scotland’s Head of Species and Land Management, wrote: “Like so many of our supporters who have been in touch with us over the weekend, we were similarly outraged when we learned that SNH has, after some deliberation, finally decided to issue a Research Licence to local estates to cull over 60 non-breeding ravens per annum over 5 years in the Strathbraan area of Perthshire.”  He said that the RSPB had written to the SNH Chair, and also to the Scottish Secretary of State for the Environment, Climate Change and Land Reform, expressing its concerns over the decision. There were a number of reasons for those concerns, he said, and went on to outline the RSPB response.
Firstly, he stated the RSPB’s position on the conservation of breeding waders, which he said “is a very high priority for the work of RSPB Scotland”:
“Sadly, some of these species, notably the curlew, redshank and the lapwing have suffered large population declines in recent years. The negative factors affecting these populations of birds are well understood, and include changes in habitat as a result of some modern farming practices; afforestation of important open landscapes; as well as increasing impacts of ground predators, especially red foxes.”
He outlines the work that the RSPB is currently undertaking in this area, including the hosting of more than 4,200 pairs of breeding waders on 27 RSPB sites in Scotland, and collaborative work on private estates with sympathetic landowners. On RSPB sites, he writes, “we employ both effective habitat management and also legal predator control where necessary to conserve these important wading bird populations, and they often occur alongside healthy breeding populations of a wide variety of protected predatory birds such as raptors and ravens.”
A raptor persecution ‘black hole’ in Perthshire
Moving on to discuss the licence, he says the motive for the application is not what it seems:
“In the first instance, we doubt very much that the proposal in this case has anything to do with the given reason for the research licence request – ostensibly to ‘improve understanding of factors affecting key wader species’. In light of previous loud complaints by estates in this and other grouse shooting areas about raven predation of red grouse, we and many others see this raven research proposal as simply a rather transparent mechanism whereby a perceived pest species can be removed to benefit red grouse, with the conservation of wading birds as a by-product.”
The location for the cull, he says, should have set some alarm bells ringing amongst SNH staff, “since this area has been clearly identified by the Scottish Government, the police and other authoritative commentators for many years as a raptor persecution ‘black hole,’ where golden eagles and other protected raptors suspiciously disappear without trace or explanation”:
“Indeed, most recently SNH’s own Commissioned Report 982 published in May 2017, titled Analysis of the Fate of Satellite Tracked Golden Eagles in Scotland, clearly identified Strathbraan as one of several areas of concern across Scotland for missing golden eagles. Only last month a satellite tagged white-tailed eagle disappeared in this very location in the same circumstances to those which are identified in the above report as ‘suspicious,’ and indicative of a further wildlife crime incident. Typical moorland raptor species that used to breed in the area, such as the hen harrier, have now disappeared… In addition, our Investigations team have also encountered a number of other confirmed and suspected raptor persecution incidents in this area in recent years, all of which have been reported to the police and are documented. It worries us a good deal that SNH apparently do not seem to have taken any of this contextual information into account as part of this licensing decision.”
He also notes that red kites, although they breed and thrive close to this area of Perthshire, are notoriously unsuccessful when they try to establish breeding pairs in the central Strathbraan area.
Scottish Raptor Study Group excluded from consultation
Duncan Orr-Ewing also questions the science behind the decision, pointing out that the link between increases in raven populations and declines in breeding wading species across the British uplands is weak, as demonstrated by an authoritative study published in 2010, which was also commissioned by SNH and produced by Aberdeen University and the RSPB:
“This report also recommended that robust evidence of a predatory impact of ravens on a prey species would be needed before considering any experimental studies to test the potential impacts of raven removal. As far as we know, no such evidence has been provided, and if it has, this has not been shared with stakeholders such as ourselves.”
Finally, he says, “this licence seems to have been granted without enough consideration for collaboration and partnership, and with what appears to be some effort to exclude local organisations and individuals that could have provided expert advice and monitoring data to inform the decision in the first place.” In particular, he adds, “the Tayside members of the Scottish Raptor Study Group, who have been monitoring ravens in Perthshire for decades, were excluded from consultation.” This exclusion is reflected across other collaborative forums, he says, “where this application was only recently shared in spite of the fact that it has clearly been in development for some time with the assistance of SNH.”
He concludes by stating that any proposal to halt the decline of breeding waders, “especially where it might involve the lethal control of other predatory species,” needs to be founded on an extremely robust evidence base before such intervention is considered. Proposals also need to be deliberated in the wider context of the history of the location where such intervention is being considered, he says, especially its history relating to illegal persecution or justifiable suspicions.
RSPB Scotland: Why has SNH ignored the science?
Three days later, Anne McCall, Director of RSPB Scotland, provided an update on the situation . Whilst she welcomed SNH’s decision to review the licence, she said that the latest communication from SNH provided “no information on withdrawing the licence” and no acknowledgement of raptor persecution in the location, which was a “critical omission”. She also continued to question the scientific justification for the cull, pointing to the lack of evidence for the link between raven numbers and wader productivity:
“Indeed, the most recent and relevant piece of peer-reviewed science examining any such relationship between wader declines and ravens found “no significant negative associations between raven abundance and population changes in upland waders, and so does not provide support to justify granting of licences for the lethal control of ravens in the interest of population‐level conservation of these upland wader species.” This science did identify a “weak” negative relationship between the change in raven abundance and trends of curlew and lapwing, and suggested that this relationship “may warrant further investigation.” But it also emphasized – in our view quite rightly – the importance of “making a thorough evaluation of the evidence base before making decisions regarding predator control.” In this case, it appears that SNH has done the opposite.”
She says that the RSPB had yet to see “anything approaching a robust scientific evidence base justifying the cull,” and that SNH did not allow its Scientific Advisory Committee to consider the proposal prior to issuing a licence, “instead directly proceeding to permit the killing of ravens to see what happens”:
“What’s more, from the information currently available, this cull may not take the form of a legitimate scientific experiment as currently proposed – as far as we understand there is no ‘control’ on which to monitor and properly evaluate the efficacy of this lethal act. Considering all of the above, RSPB Scotland maintains that there is no justification for this extreme course of action, and will continue to pursue that SNH withdraw this licence. Alternatively, the option is always open for those who have sought the licence to voluntarily pause any culling in order to allow time and space for the SNH Scientific Advisory Committee to conduct a thorough and meaningful analysis. Choosing not to pause a cull in order to make sure the science is in order has to beg the question, why on earth is this being done at all?”
Last month, BBC News reported that the licence had been suspended following the review by SNH’s Scientific Advisory Committee, which found that the project “was inadequate at providing robust scientific conclusions” . Kevin Keane, BBC Scotland’s environment correspondent, reported that the committee has made a series of recommendations which will be incorporated into the terms of the licence. The “Strathbraan Community Collaboration for Waders” has volunteered to suspend the project until the new licence is drawn up.
Licence to Kill – Swifts and Robins?
Last week, however, the RSPB reported that it had received several enquiries over the last few weeks regarding licences issued by Scottish Natural Heritage for otherwise protected birds including swifts, robins, and others . On the killing of swifts, it said it was initially struggling to find a legitimate reason for the licence:
“What serious threat to public health is posed by this endangered species that requires indefinite numbers of them to be killed?… It does seem possible that the licence applicant has mistaken swallows for swifts and that SNH has not realised this. Apparently, there has been an issue of birds nesting in safety critical equipment at an airfield and removal of the nests is what has been intended.”
In the case of swallows, the RSPB says that if the action taken is confined to the early removal of nests before the swallows lay eggs, “then this does start to look a bit more proportional. Swallows will readily relocate if discouraged from nesting in the early spring. Swifts, however, have very strong nest site fidelity and are much less flexible.” More openness from SNH, it says, would help to answer many unanswered questions by allowing licenses to be subject to a better-informed public scrutiny: “For example, is it really always necessary to kill any robin that ends up in a food store? Killing is supposed to be the option of last resort, not the standard procedure.”
Mass Slaughter – Badgers in England
An issue that has attracted widespread coverage in the national press is the culling of badgers, which Defra (the Department for the Environment, Food & Rural Affairs) says is necessary as part of a 25-year strategy to eradicate the spread of bovine TB. Environmental campaigners have argued that there is no evidence that the culling of badgers is effective in combating the spread of TB and that vaccination of badgers and cattle should be the priority. Despite expert advice, however, and despite the fact that killing badgers does not prevent the spread of the disease from cattle to cattle, the Government has persisted in trials of the cull in an increasing number of English counties. BBC News reported in March that around 20,000 badgers were culled in eight counties in 2017 . The cull took place in 19 locations in Gloucestershire, Somerset, Dorset, Devon, Cornwall, Herefordshire, Cheshire, and Wiltshire. Culling started in 2013 in Somerset and Gloucestershire, in 2015 in Dorset, and in 2016 in Devon, Cornwall, Herefordshire, and another location in Gloucestershire. The licences allow badgers to be killed every year between 1 June and 31 January.
In May, the Government announced plans to expand its badger culling program this autumn, with farmers being offered a £50 bounty for each animal killed . Natural England had announced earlier that it had already received new licence applications or “expressions of interest” from nine locations in or near areas of “high risk,” situated in Avon, Berkshire, Derbyshire, Hampshire, Oxfordshire, Shropshire, Staffordshire, Warwickshire, and Wiltshire . News of the cull expansion prompted another petition on Change.org, started by Lee Jenkins, calling on Environment Secretary Michael Gove to stop the cull . The petition had attracted over 200,000 signatures by the time it was delivered in July. On the Government’s proposals, Lee Jenkins said:
“Over 50,000 badgers were culled by farmers in the last two years, and if we keep on going this way it will have a serious impact on our environment. In the past, wolves, lynxes and wild boars were hunted to extinction and are now having to be reintroduced – why are we repeating the same mistakes again with the badger? The government says this is part of a program to stop the spread of bovine TB, but previous trials of culling badgers have not successfully stopped the disease. Vaccinations would be a far more ethical way of stopping TB, along with increased hygiene measures in farms. Badgers are an iconic symbol of the British countryside, and killing them will leave a huge hole in the ecosystem and do long term damage to our environment.”
Having spoken to farmers, Lee Jenkins says that some farmers in Somerset have released rescued badgers onto their farms. Rescued badgers are vaccinated before they are released and will keep other badgers off their territory as they are very territorial, he says, which demonstrates that vaccination works.
News of the proposed cull extension was reported in the Daily Mail way back in February . Professor Rosie Woodroffe, senior research fellow at the Institute of Zoology, is quoted as saying:
“Defra is considering licensing more than 10 new areas a year, so the total cull zone would start to engulf entire counties, and the numbers of badgers killed each year would climb into the many tens of thousands. Slaughtering wildlife on this scale needs to be well justified – unfortunately there is not yet robust evidence that the current badger culling policy is helping to control cattle TB.”
Environmental campaigners continue to argue that the main reason for the spread of TB in cattle is contact from cattle to cattle; not via badgers. The Wildlife Trusts point out that cattle in the UK are already vaccinated for up to 16 diseases, but the Government has failed to develop one for TB . It says that 25% of the European badger population is found in the UK, and we therefore have an international responsibility to conserve them. In contrast, the current policy of mass slaughter could see the badger threatened with extinction.
Habitat Destruction – Wildcats in Scotland
Meanwhile, in the Highlands of Scotland, campaigners are working to save another animal from extinction: the Scottish wildcat. In May, wildlife photographer Steve Piper started a petition on Change.org calling on the Scottish Environment Minister to prevent logging by Forestry Commission Scotland in a location that provides a home for 13 of the UK’s dwindling wildcat population . The Scottish wildcat is only found in Scotland, and according to Steve Piper the total population is estimated to be around 35, making it “one of the world’s rarest wild animals.”
Ten years ago, Steve Piper set up a project to conserve the Scottish wildcat, called Wildcat Haven . Field work by the project established a count of 13 wildcats living in Clashindarroch Forest in Aberdeenshire, some miles north-east of the Cairngorms, and some miles likewise from those well-known glens, Glen Fiddich and Glen Livet. Steve Piper says that the forest also provides a home for red squirrels, pine martens, and goshawks, and is the wildcat’s last and only known major stronghold and breeding site, “but logging is taking place in the middle of the kitten season, disturbing wildcat mothers, which could make them abandon or even eat their young.” Logging by Forestry Commission Scotland has failed to identify territories, he says, which have been felled as a result, creating a disturbance during the breeding season that goes against the legislation that protects wildcats and their habitat.
By June, the petition had reached 200,000 signatures, but news emerged of plans to install two wind farms in the forest, one by Fred Olsen, the details of which were unknown, and one by Vattenfall, which would extend an existing wind farm by clear felling 1560 hectares of Clashindarroch Forest, about a quarter of the whole. Steve Piper said that there are many other locations in the area that are suitable for wind turbines, and that the company’s plans clearly show that the turbines will cut the forest in half, and that the 1560 hectare site is almost all forestry, “including some ancient woodland immediately where the turbines are to be sited.” In its plans, the company also said that clear felling will be carried out at the appropriate time .
Wildcat Haven questions the claim that felling can benefit the wildcat population
Responding to these developments, Wildcat Haven wrote a letter at the end of June to Scotland’s First Minister Nicola Sturgeon, expressing its concerns over the work currently being carried out by Forest Enterprise Scotland, on behalf of the Forestry Commission, and its concerns over the wind farm proposals. The letter states:
“As required, Forest Enterprise Scotland (FES) do appear to be carrying out pre-felling surveys to check for wildcat presence. However, it has been proven that those surveys have failed to identify wildcat territories which were subsequently felled… In one case, FES were shown evidence of a wildcat on a site already being clear-felled. They briefly ceased operations accepting the cat was present, then continued clear-felling anyway… An FES species ecologist commented that ‘cats can move,’ even though the law expressly forbids this happening. He is also the only ecologist we are aware of with the opinion that forcing the movement of highly territorial, legally protected, and critically endangered animals is no big deal.”
The letter also casts doubt on the science behind the claim by Scottish Wildcat Action that wildcats benefit from 90 hectares of their territory being clear-felled. The letter states: “There is absolutely no evidence that Scottish wildcats benefit in any way from clear-felling, and a considerable body of evidence and legal protections making it clear that it is extremely detrimental to their survival.” 
On the Vattenfall proposal to extend its wind farm by felling a quarter of the forest, the letter says that “FES were keen to keep this ‘under the radar’ according to their internal emails, expecting wildcats would be an issue; which we find outstandingly poor behaviour for a public agency, managing a public forest, talking about a legally protected and critically endangered species.” The letter also criticises Scottish Natural Heritage for its spending £2m on “allegedly saving the wildcat” while dropping its own population estimates from 400 to 100 over the same period. The letter concludes:
“We, and over 200,000 other people, believe the case is clear: the wildcat is not safe so long as Clashindarroch can be commercially exploited. Scotland has many windy hills and many commercial forests, but this is the only one with a resident population of wildcats… We feel the only sensible choice is to put a moratorium on all forest exploitation in Clashindarroch Forest until Parliament is next in session and able to deliver a fully informed decision on whether it can be protected.”
Steve Piper said that he had also written personally to Scotland’s First Minister, requesting a stop to all logging activities in the forest, and pointing out “that the actions of the Forestry Commission there are very much illegal.” Wildcat Haven had also written separately to the Forestry Commission, he said, “outlining the same legal complaint and making it clear that any further logging will be reported to the police as a wildlife crime.” By August 8th, the petition had reached 300,000 signatures, but neither Scotland’s First Minister nor the Forestry Commission had responded to the concerns expressed in the letters.
Habitat Destruction – The Rail Network
Large-scale tree felling became the subject of a fourth petition on Change.org, started by Ray Walton in response to a massive clearance operation by Network Rail . The UK’s rail network consists of about 10,000 miles of track, and the 20,000 miles of trees and vegetation on either side provide significant corridors for wildlife, second only to the road network in terms of scale . The seasonal problem of fallen leaves is well-known to rail passengers, and Network Rail has always had a policy of clearing trees and vegetation growing close to the track, and any foliage that is deemed to pose a risk to train and passenger safety.
However, on the 29th April, the Guardian published an exclusive by environment correspondent Sandra Laville, which disclosed that millions of trees were at risk in a secretive Network Rail felling programme . She reported that the company “has created an aerial map of its 40,000 hectares of railway and identified ‘hotspots’ where mature trees might cause a problem at an unspecified time in the future.” Network Rail’s head of media Kevin Groves denied that the programme was secretive, saying that information on its tree-felling programme was freely available on its website, and that its tree census had enabled the company’s operations to be more targeted, “eliminating needless clearance work and enabling us to be more efficient and better at managing the line-side.” He is reported to have said that “biodiversity matters to us,” but Sandra Laville says that its engineers “are operating in a targeted felling programme that dwarfs the operation by Sheffield City Council that was paused in the face of huge public protest and condemnation from the environment secretary, Michael Gove.”
“Thousands of poplars, sycamores, limes, ash trees and horse chestnuts have already been chopped down across the country from Yorkshire to Dorset, and the scale of the potential destruction outlined in a Network Rail blueprint involves 10m trees growing within 60 metres of track… Over the last fortnight, people around the country have woken to the sound of chainsaws and expressed concern at the lack of consultation and the scale of the destruction. In one incident, police in Bournemouth were called by residents to complain that engineers were operating illegally as the felling is taking place during the nesting season. At one west London station this week, an engineer felling five mature trees said they were carrying out a ‘pre-emptive strike’ in case branches or leaves fell on the line in future… In Sutton Coldfield, teams working for Network Rail have been felling hundreds of track-side trees…”
The eye-witness accounts reported by the Guardian suggest that Network Rail’s idea of “targeting” is to select a length of the rail network for the mass obliteration of all trees and vegetation:
• “Ray Walton witnessed hundreds of trees being chopped down along the length of track between Christchurch and Bournemouth. ‘It was total mass destruction, they obliterated every tree,’ he said. ‘These trees were mature 30-foot-high trees which have been there for 50 years in some cases and never caused a problem. This went far beyond reasonable management of the trees. They took them all out, and destroyed the habitat for wildlife.'”
• “James Graham from Manchester said he saw thousands of trees being felled last week along a 10-mile section of the Trans-Pennine route from Manchester to Leeds. ‘I know they have to manage the trees, but this was excessive,’ he said. ‘It looked like some kind of logging operation. I was sitting in the train and looking out at the countryside and all you could see was mile after mile of tree stumps and sawdust. They had felled trees which were a long way from the track. It was extreme.'”
Network Rail’s “slash and burn” approach
Network Rail admitted to the Guardian that the vast majority of the trees being felled were healthy but defended the operation, saying that its new tree database of hotspot problem trees has “revolutionised” its approach to “vegetation management” and cut delays and risks to passengers from tree branches. Sandra Laville said that the timing of the operation has caused increased outrage because it is taking place during the nesting season, “despite promises by Network Rail that no felling would take place when birds are nesting.” Network Rail’s media head Kevin Groves said that those assurances about the nesting season do not hold true if trees constitute a risk, such as locations where train drivers are unable to see line-side signals.
However, the eye-witness accounts show that the operation is far more extensive. Caroline Lucas of the Green Party is reported to have said that the scale of the operation was shocking and an act of environmental vandalism. “While some tree work is required on safety grounds,” she said, “Network Rail’s approach tends to be one of slash and burn. To be taking action in the nesting season is even more reckless.” Friends of the Earth criticised the clearance of habitat as “insensitive,” while the RSPB said that Network Rail may well be in breach of the legislation that protects nesting birds.
The Guardian published a further exclusive on the 9th of May, after receiving a leaked Network Rail document that “sets out a series of alternatives for dealing with the millions of trees along Britain’s railway over the next five years.”  According to the Guardian, Network Rail says it owns 6m trees and the internal document identifies 13m trees within falling distance of the tracks, “some on third-party land and some on its own land.” Sandra Laville reports that Network Rail’s preferred option is a programme of “enhanced clearance”:
“Entitled Lineside Asset Management Control Period 6 (CP6), the document’s preferred option involves the “removal of all leaf fall species” within falling distance of the track, “intensive intervention” on vegetation in close proximity to the railway, and the removal of emergent lower level growth at the earliest stage. The area for management of scrub, grasses, trees and shrubs will also increase from five metres either side of the railway – which has been the policy for the last five years – to a minimum of 6.5m. Grasses and scrub alongside Britain’s railway lines are made up of more than 1,600 species of plants, including 900 varieties known as ‘railway species’ that are exclusive to the track-side.”
Network Rail said that the preferred option has not been adopted as policy and denied that the document is a statement of intention. In an email to the Guardian, it said: “It is a piece of modelling work our regulator asked us to do that actually demonstrates that moving to a more aggressive vegetation approach is very costly and does not represent value for money.” According to the Guardian, the document specifies that it would need £41,000 per mile of track for the enhanced clearance and states that this would result in “a far better performing safer railway.” However, “if the estimate is extrapolated across the entire 20,000-mile network, it would cost more than £800m.”
Network Rail’s CEO summoned for talks
Sandra Laville says that the 2019-24 policy document emerged as Environment Secretary Michael Gove summoned Network Rail’s CEO Mark Carne for talks over its approach to environmental management following her revelations about nationwide tree felling. As a result of those talks, Transport Minister Jo Johnson set up a review into Network Rail’s vegetation management and called for all tree felling to be suspended during the current nesting season of March to August .
She also says that some facts have emerged following the submission of a Freedom of Information request to Network Rail. Network Rail said in its response that it cuts down about 50,000 trees a year, and that 30,000 trees were felled on the west coast mainline between Euston and Carlisle in the twelve months between February 2016 and February 2017. Network Rail said there were no plans to replace any of the trees. The Guardian also reports that Network Rail has not responded to requests to provide an aerial map highlighting “problem” trees earmarked for felling.
On a positive note, a further article by Sandra Laville revealed that Bromley Council in Greater London had issued Tree Preservation Orders to prevent Network Rail from felling any track-side tree within its boundary . This means that Network Rail will now have to seek permission from the council before it can fell a tree and will have to provide reasons for the removal. In June, however, Ray Walton reported that Network Rail was still removing trees in parts of the country, despite the Government’s call for a temporary suspension .
Corporate Interests and Conspiracy Theories
Ray Walton also suggested that Network Rail had ulterior motives for the mass slaughter of healthy trees. Since the start of his petition, he said, two reasons had come to light as to why this was taking place nationwide. First, he hinted at the links between Stobart Rail, one of Network Rail’s contractors, and Stobart Energy, who supply wood for biomass power stations:
“At least one of Network Rail’s tree and vegetation management contractors has a contract to supply wood to be burned in biomass power stations around the UK The contractor’s sister company manages around 2 million tonnes of arboriculture and forest residues per annum. They have a huge appetite for material nationally, and collect the material and process it into saleable fuel, which is supplied to the renewable energy sector. This in-house connection allows the company to offer significant savings back to Network Rail as it can harvest, extract, and sell material that would usually be chipped to waste.”
Ray Walton voices the opinion that “they” (unspecified, but presumably he means Stobart) “are looking to destroy all our healthy UK trees for this purpose, and are on the prowl for new sources of healthy trees and forests to exploit, mass fell and burn for profit, to sustain their profiteering biomass wood burning interests in the UK, using what they call the ‘De-vegetation Framework’.” The company claims that the framework provides a sustainable source of fuel, he says, because new saplings are planted in place of the felled trees, but not on land owned by Network Rail.
The claim that a Network Rail contractor is “looking to destroy all our healthy UK trees to support its profiteering wood-burning interests” does sound like a conspiracy theory, but the relationship between Network Rail and its contractors does need, as Ray Walton suggests, “serious scrutiny and investigation.” For instance, why has Network Rail’s contractors persisted in a programme of mass destruction when the Government has ordered a pause? Does Network Rail monitor the work being undertaken on its behalf? If so, is the monitoring adequate in reducing the risk of a contractor “going rogue”? 
The second reason is the new 5G mobile phone network:
“Network Rail is ‘preparing’ to receive and introduce the new 5G ‘microwave’ phone signal in 2020 to its clientèle on the trains and along the rail system. However, leafed tree and foliage along the sides and embankments ‘block the signal’ and hence ‘it won’t work’ as good as the older 3G and 4G signals already in place. Hence another relevant but omitted reason for felling all the trees along the railway lines. There seems to be a corporate profiteering tree-felling conveyor belt operation here and it can only get worse –unless we expose and stop it.”
Whether there is any substance to Ray Walton’s claims , the scale of the devastation is apparent. A nationwide wildlife corridor spanning 10,000 miles has received significant damage because of Network Rail’s clearance programme. And despite its claims to support biodiversity, its actions have done nothing to prevent the decline in the UK’s wildlife. 
Photograph: Little Glenshee to Strathbraan road, 3km from Milton, Perth And Kinross. © Copyright Richard Webb and licensed for reuse under this Creative Commons Licence. Scottish Natural Heritage has issued a licence to cull ravens in Strathbraan, ostensibly to investigate possible correlations between raven numbers and wader productivity in the breeding season. The RSPB has expressed outrage at the decision, pointing out that the area is managed for grouse shooting and is a notorious “black hole” for raptors, where birds of prey, including eagles and hen harriers, have disappeared under suspicious circumstances. The RSPB says that estates in this and other grouse shooting areas have been complaining “loudly” about raven predation of red grouse: “We and many others see this raven research proposal as simply a rather transparent mechanism whereby a perceived pest species can be removed to benefit red grouse, with the conservation of wading birds as a by-product.” 
 See the ENA article: “UK Government publishes its 25 year plan for the environment”.
 See the ENA article: “The future for farming: UK Government publishes proposals for a post-Brexit agricultural policy”.
 See the ENA article: “New rules for farmers ‘will help to protect the water environment'”.
 Alison Lowther’s petition, “Stop the proposed raven cull by Scottish Natural Heritage,” can be found on the Change.org website.
 See the article, “Concern over Raven research licence – RSPB Scotland’s response,” on the RSPB website.
 See the article, “Raven research licence: an update,” on the RSPB website.
 See BBC News, 30 July 2018, “Raven cull licence suspended for being ‘not scientifically robust’,” at https://www.bbc.co.uk/news/uk-scotland-45003370.
 See the article, “Response to licences granted by Scottish Natural Heritage,” on the RSPB website.
 See BBC News, 8 March 2018, “Nine areas of England apply to join badger cull,” at https://www.bbc.co.uk/news/uk-england-43328066.
 The news was reported in the Telegraph on 27th May 2018, in an article titled “Farmers to be offered £50 a kill as badger cull is rolled out across most of England.”
 See .
 Lee Jenkins’ petition, “Stop the nationwide cull of Badgers,” can be found on the Change.org website.
 Lee Jenkins cites the article, “Controversial badger cull to stamp out TB could be extended,” published by the Daily Mail on 16th February 2018.
 See the Wildlife Trusts website at https://www.wildlifetrusts.org/wildlife-and-wild-places/saving-species/badgers.
 Steve Piper’s petition, “Save the Scottish wildcat by protecting Clashindarroch Forest,” can be found on the Change.org website.
 See the Wildcat Haven website.
 The plans are revealed in a scoping report, published as a PDF document on the Vattenfall website, and discussed by Steve Piper in a petition update on 21st June 2018. News of the proposed wind farm was reported in an article in The National, which headlined with the claim that almost a third of Scotland’s wildcat population could be wiped out by the development.
 The basis for citing a figure of 90 hectares is unclear. Presumably however, as Clashindarroch Forest is a commercial forest, the size of a felled area must meet a certain standard of commercial viability. Scottish Wildcat Action, which works in partnership with Forest Enterprise on the conservation of wildcats in Clashindarroch Forest, has responded to these criticisms by saying that in any one year around 1.5% of the total forest area is thinned or felled. This area is “made up of relatively small patches in relation to the home range of the wildcats living there.” They argue that grasses start growing when the timber crop is removed, and that this provides ideal habitat for voles, an important food item for the wildcats. They cite research on wildcat conservation elsewhere in Europe, which shows that “wildcats prefer habitat mosaics of open ground and closed cover.” For the full response, see the Scottish Wildcat Action website.
 Ray Walton’s petition, “Stop Network Rail Chopping Down Millions of Trees!”, can be found on the Change.org website.
 The precise length is reported in documents published by the Office of Rail and Road and summarised on a Wikipedia page.
 Sandra Laville, “Millions of trees at risk in secretive Network Rail felling programme,” published by the Guardian, 29th April 2018.
 Sandra Laville, “Revealed: Network Rail draws up option to remove all ‘leaf fall’ trees from wider trackside area,” published by the Guardian, 9th May 2018.
 In a GOV.UK news story published on the 10th of May, Jo Johnson said that “the review will look at whether Network Rail has the capacity and capability to manage vegetation in a way that minimises harm to wildlife.” The review was expected to report its findings in the summer.
 Sandra Laville, “Local council issues tree preservation orders to stop Network Rail felling,” published by the Guardian, 11th May 2018.
 See the petition update on Change.org. Ray Walton cites the example of Newbury in West Berkshire, where tree felling was still continuing on a large-scale despite the call for a temporary suspension. In an article for the Newbury Weekly News, Fiona Thomas reports that the work was expected to continue through the summer, and provides a number of eye-witness accounts of the scale of the destruction.
 In a petition update , Ray Walton provides a number of links to justify his claims. For instance, Stobart Rail claims to be Network Rail’s “vegetation management specialist,” while Stobart Energy claims to be “the UK’s number one supplier of biomass fuel.” An article in the energyst reported in March that Stobart was “on track” to deliver 2m tonnes of biomass per annum, presumably as a result of its work on Network Rail’s clearance programme.
 On Network Rail and the new mobile phone network, Ray Walton cites a government press release, which announced at the end of 2017 that “ministers are now looking at ‘future proofing’ rail connectivity to help pave the way for a 5G rollout.”
 See the ENA article on The State of Nature 2016, a report that examines the causes of wildlife decline in the UK. See also the ENA article on the UK’s bird populations. For the significance of wildlife corridors, see the ENA article on the Wildlife Trusts’ vision of a “Wilder Britain”.
 See .