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by Linda Mellor
Prior to scrutiny by the Rural Affairs and Islands committee, the SGA and partners such as GWT made a robust case against changes to female deer seasons; a well-researched campaign which led to Scottish Government dropping the proposal (to their credit). See: https://www.scottishgamekeepers.co.uk/latest-news/2024/2025-01-28-sga-campaign-sees-female-deer-seasons-retained.php
There remains, however, many issues and concerns with the Bill, which the SGA will advance at Stage 2, principally the unchecked new powers for NatureScot to intervene in deer management on poorly defined ‘nature restoration’ grounds, rather than acting where damage, or likely damage, is evidenced.
These changes carry a threat to employment and the goodwill inherent in the voluntary system which is responsible for the vast majority of deer management in Scotland.
You can watch today’s debate on Parliament TV. It has been timetabled to follow Portfolio questions which begin at 2pm.
To watch on Parliament TV, visit: https://www.scottishparliament.tv
Ahead of the debate, The SGA sent all parliamentarians a briefing paper, outlining some key concerns (although we will be engaging with MSPs on a number of potential Bill changes).
Dear MSP,
For the purpose of this briefing, we will limit our key concerns regarding Part 4 of the Bill: Deer Management, to the following, although we have further concerns, see: https://www.scottishgamekeepers.co.uk/latest-news/2024/2025-05-09-bill-doesnt-answer-jobs-concerns.php
Whilst our members have played a significant role in helping to bring deer densities down to the Deer Working Group’s recommended density of 10 per sq km across the majority of the upland red deer range (voluntarily), specific new measures contained in the Bill such as the introduction of 6ZB control schemes, pose a real danger to the voluntary deer management system but, more specifically, to full-time deer management jobs.
The SGA notes that the Committee recognises that 80% of the annual cull is carried out privately, largely through voluntary deer management arrangements. It is the organisation’s view that the very marginal nature of this endeavour (which is critical) has not been adequately presented in deliberations thus far, largely because the financial information presented alongside the Bill does not provide a suitably nuanced picture of how fragile this is.
For example, most figures presented around the costs of deer management are from public bodies such as FLS and NatureScot. Whilst the Memorandum and BRIA point to a cost of Deer Management to FLS of £21.7m annually, it does not consider that this is undertaken to protect a crop (timber) which in 2023/2024 generated an income of £82.1m in sales and, according to Audit Scotland, still left a resource in standing timber and seed worth £3.1 billion across the FLS estate.
FLS, therefore, are not, in any way, like most land holdings carrying out deer management in Scotland where that activity is undertaken with minimal economic gain.
Indeed, to retain trained full-time deer managers in economically fragile areas of Scotland’s uplands, many estates must subsidise this activity across other areas of their business or accept losses.
This is extremely concerning for the SGA, a representative body aiming to protect skilled jobs in rural Scotland and we have seen members lose employment already. This will only increase as deer numbers reduce further and the margins simply become too slim to justify the retention of full-time jobs.
For this reason, and if Scottish Government wishes to achieve nature and biodiversity targets, NatureScot should be empowered to use the adequate powers it currently has rather than introducing new punitive measures (6ZB) which are likely to end up in damaging dispute, a destabilisation of the very system responsible for the heavy lifting and further reductions in jobs.
It is the SGA’s view that 6ZB should be removed from the Bill as it is unnecessary and will hamper the cause of nature restoration rather than enhancing it by damaging the goodwill the targets depend upon, which is the goodwill of the trained deer managers on the ground without whom they will not be delivered.
Alongside the 6ZB clause, the Bill -as stands- gives NatureScot and Scottish Ministers the power to appoint a panel, enable NatureScot to make decisions on a panel, order a deer management plan and then approve it, when its conclusions are of its liking. This is a wide-ranging, unchecked power and, while the SGA considers there to be a role for panels in addressing the likely disputes that will arise from 6ZB there is nothing in the Bill to add detail or comfort as to how panels will be appointed and which personnel may be involved.
Given that the Deer Working Group did not contain any individuals involved in daily management of deer at practitioner level, the SGA would recommend that panels must contain a balancing quota of practitioners who can provide essential truthing on how any decisions will impact, on the ground.
The SGA commends the Scottish Government for rejecting moves to change female deer seasons. This ill-judged proposal failed to consider the mental well-being of deer managers who were opposed to having to remove calves from mothers, close to full-term.
The SGA is not opposed to the aims of the Natural Environment Bill but harbours concern regarding the Deer Management element.
Prepared by the SGA Committee, October 2025.
