Scottish Government's response to the recommendations of the Deer Working Group
Whilst sustainable and effective deer management has long been recognised as a vital contributor to land management, twin biodiversity and climate crises mean our actions to mitigate and prevent damage by deer on our environment are now more important than ever. Herbivores such as deer cause damage by overgrazing and trampling vulnerable habitats and preventing young trees from growing. It is vital we protect tree-planting, woodland regeneration and peatland restoration from further damage if we are to meet our climate change and biodiversity commitments and protect our environment.
NatureScot, as Scotland's deer authority, have a significant role to take here in leading the sector in stepping up to this important task and we recognise the great deal of consideration given by the Deer Working Group to how these challenges can be tackled.
The recommendations made by the Group can broadly be arranged into the following aims:
- To improve consistency in legislation and remove restrictions on where, when and how deer can be taken/killed;
- To provide a clearer vision for deer management based on public interest within the context of the climate emergency and biodiversity crisis with clearer actions to deliver these aims;
- To set clearer thresholds for acceptable impacts on public interests;
- To encourage greater use of regulation, as a means of promoting wider compliance, and more focus on individual responsibility;
- Greater equity in addressing the range of public interests impacted by deer; and
- Access to better information.
Whilst we are clear that there is work to be done on modernising Scotland's arrangements for deer management in the context of these crises, we are not overlooking the significant progress which has been made in managing wild deer which includes:
- Over £21m invested by Peatland ACTION between 2012 and 2019 to deliver restoration activities to 19,000ha of degraded peatland, with DMG led projects being regarded as highly successful;
- Higher culls of all deer species over recent years recorded through statutory cull returns, with the highest recorded cull of 136,000 deer in 2017-18;
- Many organisations and partnerships are leading the way in habitat impact assessment (HIA) monitoring, which is essential in understanding deer impacts and informing cull planning. Monitoring has been widely adopted in the uplands and NatureScot are working with the sector to develop woodland HIA guides, the next priority habitat for assessment; NatureScot established the Lowland Deer Panel to address localised issues in the Lowlands with new work being taken forward with Transport Scotland to identify further areas for action to reduce deer vehicle collisions; and
- The use of incentive schemes, such as Peatland ACTION and the Biodiversity Challenge Fund, alongside regulatory action, field trials and research into new technologies are being utilised by NatureScot to meet climate change and biodiversity priorities through deer management.
Deer densities: We recognise that measuring deer densities can be challenging, and that deer damage is more often utilised in deer management decision making. However, we do believe deer population and density monitoring has a role alongside damage levels in monitoring progress. There are signs of progress in parts of Scotland, NatureScot Commissioned Research (2019) on national deer densities shows that there are areas of Scotland in which deer numbers are more sustainable than others, with a decrease in population densities between 2016 and 2019 as a result of increased levels of culling. We also recognise that this is simply a snapshot and that the DWG's findings of deer population levels of over one million show there is still a great deal of work to be done to ensure deer numbers are manageable and protect Scotland's important natural habitats. Our response below includes consideration of broad averages for deer populations but where necessary targeted strategies for further action will be required.
In forming this response to the recommendations made in the Deer Working Group report, the Scottish Government considered the progress that has been made, alongside all of the available evidence, including expert advice from the Scottish Animal Welfare Commission (SAWC) whose report can be viewed here: SAWC response to deer working group report.
Consideration has also been given to the views of those with a range of interests involved in the management of wild deer including executive agencies of the Scottish Government; public bodies including NatureScot; National Park Authorities; those representing private deer management; and environmental Non-Government Organisations. Many of the recommendations require legislative change, a process which will involve wider consultation and engagement with those who would potentially be affected.
Note: The Group's report and recommendations refer throughout to Scottish Natural Heritage (SNH). In August 2020 SNH was re-branded as NatureScot but the functions of the organisation remained the same, and this response will refer to NatureScot throughout.
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