The SGA considers DMNROs to be unnecessary and divisive. The SGA
considers that DMNROs are likely to prove illegal
If introduced, the SGA will support any of its members impacted by DMNROs, against their will
Key points
DMNROs will anger and demotivate professionals required to meet future Net Zero and environmental
targets. NatureScot can already achieve what DMNROs set out to do, by using, fully, the existing
powers it has, with Sections 7,8 and 10. They are, therefore, an unnecessary fight that will set a
hostile tone for the journey towards a Just Transition
DMNROs will end up in the courts, if applied. Ordering someone to cull deer, against their will
-should it impact their right to conduct legitimate business, for example- will breach Human Rights
legislation. The likelihood of this going to court is compounded by the very low evidential basis
required for government agencies to expedite an order
DMNROs are unjust and inconsistent. You can’t send someone to jail while allowing others to
side-step similar deer management responsibility, as is currently the case in large parts of Scotland.
This is inequitable and selective - see our FILM, below
DMNROs can be applied without the need for evidence of ‘damage’ by deer. This gives NatureScot an
unprecedented intervention power. NatureScot will be able to wield this power, and order deer culls,
if it deems that doing so ‘may bring about a benefit’. This is disproportionate, subjective and offers
the individual very little protection from interference by the state. There will be few areas of law
where decisions with such potential repercussions can be taken on such a low evidential bar and we
would invite Scotland’s legal minds to consider these proposals and to also make comment to Scottish
Government
Newly announced government pilot schemes/ financial incentives - Our
Position
It was recently announced that Scottish Government intends to provide some funding for deer management
pilot schemes and venison. Whilst the SGA welcomes much needed investment, it feels sums
should be solely focused in the lowlands, with a scheme introduced into the heart of the
industrialised central belt, as a priority
Deer numbers and impacts are high in these areas. There is a plentiful supply of under-utilised,
trained recreational deer managers (circa 2000), who could be managing more deer- with Government
support. Siting a new deer larder/processing facility strategically, in this geographic, high population
heartland, will have the greatest impact and through-put, per public spend
The area has suffered from lack of attention for decades, when it comes to deer management. This is no
longer sustainable and should now be classed as a government priority.
Charity, Gamkeepers’ Welfare Trust, supports us on this issue, sharing our concern for the mental
wellbeing of deer management professionals, having to cull and gralloch heavily pregnant deer for the
food chain
*The SGA represents the largest number of professional deer managers in Scotland. It
trains deer managers through its SGA Training Centre. Its members have humanely managed more deer,
for biodiversity, than any other group in Scotland.
