'Fundamental opposition' sees deer professionals side-step Government plans

Professional deer managers in Scotland are opposing the Scottish Government's plans

The Scottish Gamekeepers Association has this week informed Ministers Lorna Slater and Mairi Gougeon, and all MSPs, that it will not put its name to a Scottish Government consultation on new deer proposals because of ‘fundamental and collective opposition’.


The consultation: Managing Deer for Climate and Nature closes next Friday (29th March).


The details of the Govt's proposals can be found, here: https://www.gov.scot/publications/managing-deer-climate-nature-consultation/


Not only does the SGA have significant concerns with proposed new measures, the most recent Government consultation on major changes, including the historic removal of male deer seasons, was widely regarded as a fait accompli, with practitioners (who almost unilaterally disagreed) being ignored.


The SGA will therefore side-step this process and choose other mechanisms which better reflect practitioner views.


The SGA is the largest body in Scotland representing professional deer managers. It trains professionals, is involved in environmental deer schemes and has managed more deer humanely than any other single body in Scotland. Its new training centre, opened in 2021, has already trained around 500 DSC1 and nearly 100 DSC2 level deer managers.


Key concerns include: 


  • the mental health toll that new Scottish Government proposals could have on deer managers, having to cull heavily pregnant hinds due to proposed changes to the female deer season


  • proposals to force people to carry out culls, on a lowered evidence bar, may be illegal under European law 


  • the recent abolition of male deer seasons by Scottish Govt may already be backfiring on its own target to cull more females
Scottish Government could force landowners to kill deer if new environment proposals become law
Individuals could be fined up to £40k if they fail to kill deer under a new Government Order

Below the SGA outlines (in full) its position on the consultation


Members of the SGA Deer Group, comprising deer stalkers and deer managers from across upland and lowland Scotland, met in-person and online, on March 14th, to discuss a response to the Scottish Government consultation: Managing Deer for Climate and Nature.


Upon debating each point, it became apparent, unanimously, that the Deer Group were fundamentally and collectively opposed to key issues posed by the consultation.


Given this, and the experience of the most recent Government consultation on deer, where it was felt the key decisions had been taken and practitioner views were treated like a tick-box exercise, the Deer Group is not willing to put the name of the SGA to the consultation process, or any official response to said process.


Instead, the SGA Deer Group will choose to make its case on these issues through mechanisms other than the Scottish Government consultation; mechanisms which it feels will be more responsive to practitioner views.


The SGA Deer Group and its wider membership has been responsible for the humane management of more deer in Scotland, for biodiversity, than any other body in Scotland and supports national deer management through its Training Centre, which trains new deer managers.

Members are involved in control schemes and environmental programmes across Scotland.

The SGA is currently proposing lowland pilot schemes to Scottish Ministers to help meet higher culls and biodiversity targets.


Having examined the issues, it cannot, with conscience, support measures contained within the consultation, or the process behind it.

Female deer could be killed around full pregnancy under Scottish Government plans to change the deer season
Female deer could be killed around full pregnancy under Scottish Government plans to change the deer season

Why this Position? A summary


Deer Management Nature Restoration Orders 


  • These orders are unnecessary
  • Decisions can be made by NatureScot without evidence
  • They may be illegal


1/ NatureScot already has ample powers through Section 7, 8 and 10 to resolve these issues, if they have the will to use them. The power is therefore, unnecessary, as this can already be achieved by existing law.


2/ Clear rationale, clear objectives and evidence-based decision-making are all important in deer management. These Orders lack all of these.

Culls can be ordered by virtue of NatureScot ‘assessing’ (without any baseline- or need for independent assessment) that killing deer would be one key factor (how many other factors could there be and who would assess these?) in bringing about social, economic or environmental benefits from nature restoration in a given area. 


This is a very wide additional power, with very wide parameters, and very narrow scrutiny. A requirement to consult is only that: it doesn’t prevent something being imposed against a party’s will. This is on top of it being unnecessary.


3/ These Orders may be illegal under ECHR legislation. 

Ordering someone to shoot deer, without an evidential baseline or independent assessment of the rationale, and with no clearer projection of an end result (other than shooting deer would be one key factor in bringing about a benefit) is not a proportionate response to a perceived problem. It is also unnecessary because it can be achieved by existing legal means. 

It is therefore open to legal challenge under ECHR, principally Article 8.


Additional Note (ECHR): Such an Order could have dire consequences such as the loss of, or enjoyment of, a right to carry out a business or practice. It could potentially mean the loss of a deer manager job and tied home, for example. To be legally compliant, therefore, these Orders must be necessary, be clearly evidenced and there must be no other way to bring them about. 


Given the SGA Deer Group’s unanimous position against the introduction of these Orders, it considers questions about incentives/cost recovery and the extent to which NatureScot can intervene, to be irrelevant.

Roe deer population in the lowlands and around towns and cities is now Scotland's biggest deer problem
Peri-urban roe deer are exacting a heavy toll on nature reserves and local authority green spaces

Compulsory Powers


  • Given the wide-reaching powers being given to NatureScot, this should be afforded the scrutiny of primary legislation, not secondary legislation.


  • Most DMG areas have five year cull plans already, which they adjust according to mortality, recruitment and actual culls delivered, and to any significant change in objectives within their area. Nature Scot should support this work, and take part in the discussion when setting culls from an agency perspective, based on information available.  They don’t. For the past ten years or so, SNH/ Nature Scot have attended deer meetings, but are obviously under instruction not to participate, or give credence to any decisions being made. The current voluntary system, with its checks and balances, would be much stronger with their proper participation. What is being suggested is statutory cull setting, based on opinion, not evidence, and this puts front-line Nature Scot staff in an impossible situation, not least because most stalkers can analyse and interpret information after two decades of Best Practice training and experience.


  • The ability of NatureScot to enter land to use Emergency powers should only be done as a last resort where there is good evidence and a proper assessment of necessity. If any change is to happen, it must be done by primary legislation.


  • 3 months for a Deer Management Plan, instead of 12 months, is virtually impossible to deliver, judging by the experience of those who have developed them.
By removing male deer seasons Scottish Government may be impacting their own hind cull targets
By removing male deer seasons Scottish Government may be impacting their own hind cull targets

Fit and Competence Register


  • The SGA Deer Group agrees with competency and professional standards, both in (unaccompanied) shooting and in handling animals going into the human food chain. Any demonstration of competency, whether pitched at Level 1 or 2, should include carcass handling/larder skills.
  • Given the recent legalisation of night shooting equipment for shooting deer and issues around public safety, the SGA Deer Group believes training tests should be required for all Night shooting activity and that this should still require to be licensed by NatureScot. The industry’s present record for safety is excellent but diluting the authorisation process- and communication- at this time, will endanger this.
  • If further training/certification is to be required for competency, there should be a Government incentive for enhanced professionalism.
  • The Government must take into account that some recreational deer managers may not be  able to manage deer until they have brought their certification level up to an agreed competency. This is an important consideration because, without these deer managers operating, particularly around the Central Belt, Scottish Government will not be able to stem the ever increasing roe deer population.


Deer Welfare: Use of Shotguns


The SGA Deer Group does not agree with the use of shotguns for deer management at all. The only place where this may be come into play is for humane despatch but existing practice around humane despatch would already allow for this eventuality.

Changing the female deer season


  • The SGA Deer Group fundamentally disagrees with the change from 31st March to 30th September. Furthermore, the group believes the mistake, through secondary legislation, of removing the Stag season is already backfiring against the Government’s objective of increasing the hind cull.


  • The SGA Deer Group strongly believes culling and then gralloching heavily pregnant hinds with big calves represents a welfare and mental health issue for the deer manager. One of our deer managers still recoils, 25 years on, from culling a hind in the first week of March (through authorisation) and having to kill the calf inside. The SGA Deer Group believes that, if MSPs are to approve this, they should have to participate in the gralloching of a heavily pregnant hind themselves - that is how strongly this issue resonates. Deer managers describe end of season culling, as it is, as ‘horrendous’ and contractors frequently express the view that they can only carry out such culls for so long before exiting the industry.


  • There are wide geographical/topographical variations in when hinds will calf. Everyone has seen late and early calves so changes cannot be brought in as ‘across the board’ measures. This has not been adequately considered.


  • Orphaned calves, when mothers are killed, become social outcasts and will die. There is no respect for family units in these measures, which is also a welfare issue.


  • The quality of Scottish venison is being downgraded by season changes. Game dealers are now having to deal with a bottleneck of ‘run’, poor quality Stags and poor condition hinds, all at the same time, with a higher than usual percentage being condemned by vets. This eats into game dealer margins and venison price. No one wins from that. If this is to continue, Scottish Government should consider financing a carcass disposal scheme.


  • If forestry bodies can shoot outwith the season, under licence, and most upland areas are managing to meet their hind cull within the season, who is this change for, and why can’t targets be met without it? This needs to be more adequately explained if it is deemed to be necessary. Who are the beneficiaries?


  • For red deer, the Stag season and hind season should not overlap. By removing the Stag season, some upland estates are seeing a demand for (beyond season) Stag stalking from international visitors, deer managers, paid per carcass, are still taking the easiest animals (often the males) when they should be focusing on hinds and game dealers are suffering a backlog of poorer quality animals, male and female, at once. If you want people to focus on hinds, don’t allow them to shoot Stags all year. We’ve imbalanced the whole thing.


  • Example: We are aware of one area of the west highlands where, since the removal of the Stag season and relaxation of the authorisation requirements, the Stag cull has gone up but with a proportionate reduction in the hind cull. This is counter-productive if population management is the goal, and a hugely retrograde step.


  • Higher hind cull can be achieved by collaboration and communication, clear objectives, a proven need and competent people. 


  • For roe deer in the lowlands, recreational deer managers should be incentivised to manage females, by priority, and should be supported with facilities in order to process the venison, thereby increasing the doe cull in these areas and reducing populations in the medium to longer term.
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