The views of The Scottish Gamekeepers Association is that what is taken away from
the activity of hunting (ie: a trophy or souvenir/memento of a hunting trip) is of secondary concern
to the the way in which that hunting activity is carried out. The focus should be on the
sustainability of the hunting itself- and the welfare of the animals being hunted- and less on the
Most countries devise their own laws regarding how hunting operates and it is the
responsibility of each nation to ensure the sustainability of hunting- and welfare standards- within
its own borders and in accordance with its own priorities. The agreed definition of what is a
'trophy', for the purpose of international regulation and enforcement, is currently
In our view, the greater spotlight on 'trophy hunting' as being a derogatory
activity, or an activity worthy of societal scorn, could actually do more to endanger threatened
species and communities than any organised hunting activity. As we see it, the debate on this has
narrowed to emotional viewpoints, often advanced by celebrities or influencers, and there is now a
real danger that hunting becomes synonymous ( in the view of the public) with poor moral values
when, in fact, well organised hunting can be as much a part of a sustainable future for threatened
species as mainstream state aided conservation efforts, and in some cases even more so.
We know, from our own experience, that the way to ensure rare species receive
the appropriate level of awareness and funding, is to attach some form of connection or value to
people. Some may find this slightly sad (that we cannot conserve without 'gain') and
there is some sympathy for this viewpoint, but it tallies with human nature and we should not be
overly surprised that there is less poaching, often more conservation funding and greater
awareness of species' plights in areas where people have a financial incentive to keep
animals at a sustainable number and in prime health ie: for the provision of controlled hunting
and the accrual of accompanying financial gain.
While it is laudable that the UK is considering 'taking a lead' in this debate, there is a
real danger that - in doing so- the UK becomes silently responsible for worsening the lives and
living conditions of people in resource-poor communities, whose fates we do not have full cognisance
Hunting can provide a way for people to live in remote areas and provide for their
families when other alternatives for meaningful employment or trade are few or virtually
non-existent. When people live in these communities, the environments tend to be looked after and
invested in. The hunting 'issue', therefore, is multi-factorial, with many shades of grey,
and the current debate, often played out on Twitter, does not begin to scratch the surface of what
is at stake for species or communities.
For this reason, The Scottish Gamekeepers Association ,
which represents 5300 members in Scotland, feels that interfering in this complex area, would be
best left to situations where there is a necessity to do so ie: if cross-border enforcement is
demonstrably not working. As far as we are aware, this is not the case.
Given the complexities and, in order to respect the right of individual countries to determine
their own laws on sustainable hunting and animal welfare, we propose no change to present proposals.
Hasty law, on the basis of emotion or an impression that there is a 'need to do
something', could very well lead to a chain of unintended consequences which could be much
worse for both animals and fragile peoples.
There is an argument to say that conservation funding
can be sourced from hunting alternatives such as eco tourism and photo journalism. We do not hold
the view that it is one or the other.
The reality, from those who have trialled both models, is
that a mix- and some pragmatism- is often best. In areas where there are large densities of visible
animals, photo tourism can attract visitors and funds. However, this is not everywhere and, in other
circumstances, having smaller parties or hunters paying higher prices can be better for habitat
preservation, can mean less disturbance and less requirement to provide built tourist infrastructure
in fragile habitats.
In Africa, for example, 70 percent of wildlife occurs outside of full
protected areas and nature tourism can be unviable in these areas because of remoteness and lack of
accommodation. Again, this debate is not about the secondary 'trophy', it is about how a
balance is struck, in regulation and other ways, by people on the ground in the countries directly
Where we have acute concern with this consultation is with Option 3. We refer to our
own situation, here, in Scotland.
We are very fortunate, as a nation, to have a visible presence
of native wild herbivores. Deer are important aspects of our culture and identity, they help support
2520 jobs in remote areas and are regularly voted the favourite animal of the Scottish
Skilled deer management is necessary to regulate populations and ensure the overall
health of wild deer and their habitats. This management provides employment, healthy food and
A percentage of the annual cull of deer is undertaken by visitors, often from
overseas, who pay a lot of money to shoot deer under the expert guidance of a deer stalker or other
trained deer manager. This money then circulates through communities (often in sparsely populated
areas), providing crucial business whilst essentially providing a service which is necessary anyway
(the management of deer populations to be in balance with their environments).
Many visitors who
travel a long way to Scotland will want to take a memento of their trip back home with them so they
can talk about it to their friends or simply cherish the memory. Often antlers will be taken back to
other parts of the world.
"Deer are important aspects of our culture and identity, they help support 2520 jobs in
remote areas and are regularly voted the favourite animal of the Scottish people."
As an organisation supporting the lives and interests of professional deer stalkers and managers, we
cannot support any regulation which could act as a disincentive to others to travel to our country
and take part in sustainable deer stalking experiences.
Strict firearms laws as well as the
personal decisions of some carriers not to carry hunting arms into the UK has already led to
headaches for legitimate sporting businesses in Scotland and further moves which could reduce
visiting hunters could impact on employment in rural areas.
At a time when the climate is in the
spotlight internationally and there are moves to increase mitigations such as tree planting, the
ability to manage wild deer populations increases rather than diminishes and moves which could
restrict such management in Scotland will provide a net loss for conservation.
We do not believe
that this outcome is what is intended by this consultation but, should option 3 proceed, we fear
that this is what will happen.
As there is a requirement to select a second choice, we have opted
for Option 2 although, ideally, we would not have answered anything other than Option 4. While
option 2 sounds good in theory (everyone wants benefits to be ensured) it will be extremely
difficult to police in reality and adds a further layer of difficulty likely to outweigh any