What are DMNROs and what is our position?


The Scottish Gamekeepers Association (SGA) strongly rejects the introduction of Deer Management Nature Restoration Orders (DMNROs) in Scotland

We urge Scottish Government to drop this proposal immediately 


What are DMNROs? See: 



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.

The SGA was advocating for a central belt pilot scheme back in 2019, see our Deer Vision: https://www.scottishgamekeepers.co.uk/pdfs/SGA-Deer-Vision-Booklet.pdf


Female deer season change: Our Position


The SGA rejects proposed changes to the female deer seasons and is open to discussion with Scottish Government on season start and end points, taking into account the welfare of the animal and the mental welfare of the professional undertaking humane culling in Scotland, see: https://www.scottishgamekeepers.co.uk/latest-news/2024/2024-04-29-drop-the-female-deer-season-change.php


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.
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