The £424,000 Question: If Licensing Is the Answer, Why Is Defra Still Funding Enforcement?
- C4PMC
- 12 minutes ago
- 9 min read

There's a glaring contradiction at the heart of the hen harrier conservation debate, and it's one that neither Defra nor the RSPB seems willing to address. If licensing of game shooting is truly the solution to hen harrier persecution—as conservation groups insist with absolute certainty—then why is the government pumping £424,000 annually into the National Wildlife Crime Unit for enforcement that these same groups claim has spectacularly failed?
The Northern England Raptor Forum, never shy about attacking gamekeepers and estate managers, has been clear about the failure of enforcement-led approaches. Writing on their website, they state that Defra's 2016 Hen Harrier Action Plan aimed to reduce persecution by "improving Police enforcement of wildlife crime." Their verdict? "Nine years on, and with Hen Harrier persecution being just as prevalent, that part of the plan appears to be a spectacular failure."
The RSPB, which has built an entire fundraising empire on attacking the shooting industry, echoes this position. They've consistently argued that enforcement alone cannot solve the hen harrier crisis, that voluntary measures have failed, and that only licensing of driven grouse shooting will stop the killing. It's been their mantra for years—conveniently generating millions in donations from urban supporters who know nothing about moorland management.

So here's the uncomfortable question these campaigning organisations refuse to answer: if enforcement doesn't work—if nine years of NWCU operations, hen harrier task forces, satellite tagging programs, and criminal investigations have achieved nothing—why is Defra continuing to fund it to the tune of nearly half a million pounds per year? And why aren't NERF and the RSPB demanding that money be redirected to the licensing scheme they claim will solve everything?
The Logic Doesn't Add Up
On 10 September 2024, Mary Creagh, Labour Minister, confirmed: "Defra supports the valuable work of the NWCU. Defra is providing £424,000 for it in the financial year 2024-2025." Yet no budgets beyond 2025-2026 have been confirmed—a telling sign of uncertainty about the unit's future.
This creates three possible interpretations, none of which reflect well on Defra or the conservation lobby:
Possibility One: They Don't Actually Believe Licensing Will Work
If the RSPB and NERF genuinely believed that licensing would solve the hen harrier problem, they should be demanding that Defra redirect the NWCU's £424,000 budget toward implementing and administering a licensing scheme instead. After all, if licensing eliminates the crime, you don't need a wildlife crime unit to investigate it.
But they're not making that argument. They want both: the enforcement budget and the licensing scheme. This suggests they know perfectly well that licensing alone won't stop determined criminals, and that enforcement will still be necessary. In other words, their public position—that licensing is the solution—is disingenuous.
Possibility Two: The NWCU Budget Is Political Theatre
Perhaps Defra knows that enforcement has failed but continues funding the NWCU anyway as a fig leaf—a way of appearing to take hen harrier persecution seriously without actually implementing the licensing regime that would upset the shooting industry.
This would explain why the budget remains uncertain beyond 2025-2026. It's easier to maintain a wildlife crime unit that produces occasional press releases about forensic investigations than to grasp the political nettle of licensing. The £424,000 becomes the price of looking concerned while avoiding meaningful action.
NERF inadvertently supports this interpretation when they acknowledge the NWCU's precarious position. Any criticism of Defra would be "a tactical error for the NWCU to publicly berate the department that holds the purse strings," as one observer noted about the Natural England cover-up case. The NWCU is effectively muzzled by its dependence on Defra funding—hardly the foundation for robust, independent enforcement.
Possibility Three: Everyone Knows This Is Unsolvable
The darkest interpretation is that both Defra and the conservation groups understand that neither enforcement nor licensing will fundamentally change the hen harrier situation, but both sides need to maintain the appearance of action to satisfy their respective constituencies.
Defra needs to be seen supporting conservation. The RSPB needs to campaign for something. The shooting industry needs to demonstrate compliance with something. So we get an expensive ecosystem of satellite tags (£2,800 each), forensic investigations, task forces, action plans, and endless consultation—none of which changes the underlying reality on the ground.
The RSPB's Hypocritical Position
The RSPB's stance is not just problematic—it's a calculated deception designed to maintain their lucrative campaigning operation. They've spent years vilifying gamekeepers and estate managers, claiming enforcement-led approaches are inadequate, while simultaneously running their own enforcement operations and celebrating every prosecution as a victory.
They satellite-tag birds, work closely with the NWCU, celebrate forensic breakthroughs, demand more prosecutions, and maintain an entire Investigations Team specifically to gather evidence of wildlife crime. These are all activities that only make sense if you believe enforcement works and will continue to be necessary.
Yet their official fundraising position—the one that generates millions from urban donors who've never set foot on a grouse moor—is that enforcement doesn't work, that gamekeepers are criminals, and that only licensing will solve the problem.
Why does the RSPB maintain an Investigations Team if they believe investigations and prosecutions are futile? Why not redirect those resources and staff toward lobbying for licensing instead? Why continue satellite tagging if they claim it achieves nothing?
The answer is obvious and cynical: the RSPB knows that even with licensing, enforcement will still be necessary. They know that bad actors exist in every sector. They know that licensing won't eliminate wildlife crime any more than firearms licensing has eliminated gun crime. But admitting this would destroy their simplistic narrative that gamekeepers are the problem and licensing is the solution.
So they maintain both positions simultaneously: publicly attacking enforcement while privately depending on it, vilifying an entire profession while knowing their proposed solution won't eliminate the need for that profession's cooperation.
NERF's Campaigning Agenda
The Northern England Raptor Forum deserves credit for one thing: documenting the failure of every approach tried so far. They've meticulously recorded how Operation Artemis failed two decades ago, how brood management failed, how diversionary feeding failed, how partnership working failed, and how the Hen Harrier Action Plan's enforcement emphasis failed.
But this documentation serves a purpose. NERF volunteers contribute an estimated £400,000 worth of time and effort annually to hen harrier monitoring—almost exactly the same amount Defra provides to the NWCU. Yet despite this massive volunteer effort, NERF acknowledges that "the killing continues."
If voluntary monitoring effort worth £400,000 and government enforcement funding of £424,000 haven't stopped whatever is limiting hen harrier populations, why would anyone believe that adding licensing will somehow prove decisive?
NERF's answer is to blame gamekeepers and demand licensing. They compare the shooting industry to "drug cartels, international illegal arms dealers or the mafia" and describe wildlife crime as "organised crime." This inflammatory rhetoric serves their campaigning objectives but ignores inconvenient realities: that gamekeepers are the people who create and maintain the moorland habitat hen harriers need, that many estates welcome breeding hen harriers, and that persecution—where it occurs—represents the actions of individuals, not an entire profession.
NERF's £400,000 worth of volunteer effort demonstrates dedication, but it also reveals an uncomfortable truth: monitoring alone doesn't save hen harriers. Neither does satellite tagging. Neither does forensic investigation. Yet NERF continues demanding more of all three while attacking the gamekeepers whose habitat management makes hen harrier breeding possible in the first place.
What This Reveals About Policy
The £424,000 NWCU budget reveals the fundamental dishonesty in the hen harrier debate. Conservation groups claim licensing is essential while supporting enforcement funding. Defra funds enforcement while avoiding licensing. Everyone insists their preferred solution will work, despite decades of evidence that nothing has worked—except the habitat management provided by gamekeepers, which these groups refuse to acknowledge.
The truth nobody wants to admit is that the RSPB and NERF have built lucrative campaigning operations based on a false premise. The RSPB can't admit that gamekeepers create better habitat than they do because it would collapse their fundraising model. NERF can't admit that their £400,000 worth of monitoring effort achieves nothing because it would undermine their activist credibility. Defra can't admit policy failure because it would require acknowledging that persecuting an entire profession has been counterproductive.
So we're left with expensive cognitive dissonance: £424,000 for enforcement that conservation groups say doesn't work, while demanding licensing that would supposedly eliminate the need for that enforcement, while quietly knowing that even with licensing, enforcement would still be necessary, while ignoring that the best hen harrier habitat is created by the gamekeepers they're trying to regulate out of existence.
The Honest Questions Defra Must Answer
If Defra truly believes that improving police enforcement can reduce hen harrier persecution—as the 2016 Action Plan stated—then why has it continued funding the NWCU for nine years while persecution remains "just as prevalent"?
If Defra believes licensing is necessary, why hasn't it implemented licensing and redirected the NWCU budget toward administering the licensing scheme?
If Defra believes neither approach will work, why is it funding enforcement at all?
And most fundamentally: why is the RSPB not demanding that the £424,000 currently spent on failed enforcement be redirected toward the licensing scheme they claim will actually work?
Follow the Money
The uncomfortable reality is that the current system serves everyone's institutional interests perfectly. The RSPB maintains a campaigning narrative that generates donations and media attention. Defra demonstrates concern without alienating the shooting industry. The NWCU justifies its budget with forensic investigations and task forces. Everyone gets to appear committed to hen harrier conservation without actually solving the problem.
The only losers are the hen harriers themselves—and the taxpayers funding this expensive charade.
Their Inconvenient Truth About Grouse Moors and Gamekeepers
And here's the final, devastating irony that nobody in the conservation establishment wants to discuss: hen harriers are actually doing better on grouse moors than anywhere else in their range, and it's gamekeepers who create the conditions that make this possible.
Despite decades of the RSPB and NERF claiming that driven grouse shooting is the primary threat to hen harriers, the species' stronghold remains in areas where grouse moor management occurs. This isn't coincidence—it's cause and effect. The habitat created and maintained by gamekeepers—the heather moorland, the controlled burning, the predator management that protects ground-nesting birds, the high prey densities—is precisely what hen harriers require for successful breeding.
This is the same habitat management that the RSPB's own Geltsdale reserve struggles to maintain effectively, as evidenced by 47% of that site remaining in unfavourable condition after 20 years without shooting and without gamekeepers. When professional moorland managers are removed, habitat quality declines. It's that simple.
Gamekeepers aren't the problem—they're the solution. When hen harriers do well, it's on managed moorland with high prey densities maintained by professional keepering. When they struggle, it's often in areas without active moorland management where habitat degrades, bracken encroaches, heather ages out, and prey populations decline. The RSPB's own reserves prove this point better than any gamekeeper ever could.
This is an uncomfortable fact that destroys the entire narrative that the RSPB and NERF have built their campaigning empires upon. If grouse shooting and hen harrier conservation are fundamentally incompatible, why do hen harriers persist on grouse moors rather than thriving in areas without shooting?
If gamekeepers are criminals and habitat destroyers, why is the habitat they manage better quality than what conservation charities achieve?
If RSPB-managed reserves without any shooting pressure, without any gamekeepers, and with unlimited conservation resources can't achieve better results than working grouse moors allegedly riddled with persecution, what does that tell us about who really understands moorland management?
The conservation lobby's answer is to ignore these questions entirely, to continue demonising gamekeepers, and to keep demanding licensing based on the assumption that removing professional moorland managers will somehow improve conditions for hen harriers—despite their own reserves demonstrating that the absence of gamekeepers leads to habitat degradation and conservation failure.
Gamekeepers have been managing upland habitat successfully for generations. They understand moorland ecology, predator-prey dynamics, and habitat requirements in ways that urban-based conservation campaigners never will. Many gamekeepers actively welcome hen harriers on their moors, protect nests, and take pride in successful breeding. Yet they're collectively libelled as criminals by organisations that can't manage their own reserves as effectively.
The Real Policy Choice
If licensing is truly the answer, Defra should implement it immediately and abolish the NWCU, redirecting its budget toward license administration and compliance monitoring. If enforcement is the answer, Defra should double the NWCU's budget and give it proper investigative powers and resources. But maintaining both positions simultaneously—that enforcement has failed while continuing to fund it, and that licensing is essential while refusing to implement it—is intellectual cowardice dressed up as policy.
The £424,000 question exposes the entire hen harrier conservation strategy as fundamentally unserious. Until Defra and the conservation lobby are willing to answer it honestly, and until they're prepared to acknowledge that gamekeepers create better hen harrier habitat than conservation charities manage, the debate will remain mired in dishonesty and ideological campaigning.
The RSPB and NERF aren't doing everything they can. They're maintaining comfortable institutional positions, demonising an entire profession, promoting narratives that don't align with reality, and ignoring inconvenient evidence about their own failures—all while demanding that gamekeepers and estate managers be punished for achieving better conservation outcomes than they do.
Gamekeepers manage working landscapes that support viable hen harrier populations. The RSPB manages Geltsdale, where 47% of units remain in unfavourable condition. NERF volunteers contribute £400,000 worth of monitoring effort that they admit achieves nothing. Yet somehow gamekeepers are the villains and licensing is the solution.
The real solution might be to stop vilifying the professionals who actually know how to manage moorland, stop funding enforcement that conservation groups admit doesn't work, and start asking why conservation charities can't achieve with unlimited resources and no commercial constraints what gamekeepers achieve on working grouse moors.
Until that conversation happens, the birds will continue to pay the price for the conservation establishment's ideological blindness, while taxpayers fund a £424,000-per-year performance that serves everyone's institutional interests except the hen harriers themselves.






