Section 21 Information - Cull Returns
7 The Deer (Scotland) Act 1996 contains three sections that empower Scottish Natural Heritage (SNH), as the deer authority under the Act, to require information from owners and occupiers (ss.6A, 40 and 40A). Until the Land Reform (Scotland) Act 2016, the only power to obtain information was s.40 ‘Power of Commission to require return of number of deer killed’. The 2016 Act then added s.40A ‘Power of SNH to require return on number of deer planned to be killed’ and s.6A ‘Deer management plans’.
8 This Section of the Report is about the development and current use of s.40 Cull Returns. The following Section considers SNH’s use of s.40A and s.6, together with SNH’s powers under s.15 to enter on land to gather information related to its functions under the Deer (Scotland) Act 1996.
21.1 Cull Returns: Legislative History
9 The power to serve notice on a land owner requiring them to complete a return showing the number of deer killed on their land during a set period, is one of the oldest and least altered powers in Scotland’s deer legislation. This authority to obtain information on the numbers of deer killed is also considered one of the most essential powers for the statutory authority responsible for regulating deer management.
10 The power to require a return of the number of deer killed on land was introduced by s.46 of the Agriculture (Scotland) Act 1948. A land owner served with a notice under s.46 was required to report the number of deer of each sex killed on their land during a specified period not exceeding five years, with deer defined as deer of any species. Failure to submit a return within the 36 day time limit was an offence and could result in a fine.
11 The power to require a return was continued in the Deer (Scotland) Act 1959, except that the ‘number of deer’ was narrowed to the “number of red deer”. The fact that the power was included as s.5 of the 1959 Act, immediately after the four sections dealing with the operation of the Red Deer Commission (RDC), might be considered to reflect the significance attached to the cull return system as part of the new statutory regime for deer management being introduced.
12 The only amendments to s.5 of the 1959 Act before the 1996 Act were made by the Deer (Amendment) (Scotland) Act 1982. This added “or sika deer” after “number of red deer” and increased the fine for failing to make a return or giving false information in a return.
13 The terms of s.5 of the 1959 Act were continued in the 1996 Act, except that “red deer or sika deer” was replaced by “deer” and the section was re-structured to give it four rather than two sub-sections. The cull return power was, however, moved from the start of the 1959 Act to near the end of the 1996 Act, as s.40 under the cross-heading ‘Further Powers of the Commission’.
14 In 2006, s.40 was modified by the insertion of sub-sections 2A and 2B to allow for electronic communication. In 2010, when SNH replaced the Deer Commission for Scotland (DCS), s.40 was amended to replace references to the Commission in the text of the section with SNH. The terms of s.40 have not been amended further since then.
15 It might also be noted that Scotland’s deer legislation from 1948 until 2016 only referred to a ‘return’ rather than a ‘cull return’, as they are generally known. However, the Land Reform (Scotland) Act 2016, while it did not amend s.40, inserted s.17A ‘Persons competent to shoot deer’ into the 1996 Act. That new section includes several references to ‘a cull return’ and ‘cull returns’.
21.2 Numbers of Cull Returns
16 The RDC was, following its establishment by the Deer (Scotland) Act 1959, principally focused on the large estates culling red deer on the open hill. The number of returns obtained by the RDC had increased to around 450 by 1980 and then to around 650 by 1990 due to red deer expanding their range. While the RDC’s aim was to obtain cull returns from those regularly culling 10-20 red deer per year, analysis of the returns for the 10 years between 1985/86 and 1994/95 showed that around half the total recorded annual red deer cull was carried out by less than 100 estates.
17 During the 10 years after the Deer (Scotland) Act 1996 replaced the RDC with the Deer Commission for Scotland (DCS), there was a significant increase in the number of cull returns obtained, because the DCS expanded the geographic distribution of the properties on which the DCS served notices requiring returns. In 2005/06, the total number of returns received was 2,549, recording 103,837 culled deer. The DCS estimated that collecting this information took 24 staff days.
18 Figure 45 shows that during the next 10 years, 2006/07-2015/16, the number of notices sent out stayed broadly similar with an average of around 3,000 annually. Figure 45 also shows that the number of returns received also stayed at a broadly similar level with an average response rate to the notices sent out of 90%. However, there was some reduction in the response rate to the notices over the period.
19 In the first five years to 2010/11 when SNH replaced the DCS, the response rate to notices was 90% or more (peaking at 98% in 2007/08). The rate was then below 90% in the next five years to 2015/16 (the lowest being 85% in 2014/15). The following year, 2016/17, continued this pattern with 2,718 returns from 3,126 notices, representing a response rate of 87%. Figure 46 shows for that year, the geographic distribution of the number of notices served and returns received by Local Authority area.
|Season||Notices served||Returns received||Response rate|
Source: SNH Information Response 8
|Local Authority||Notices served||Returns received||Response rate|
|Argyll & Bute||448||405||90%|
|Dumfries & Galloway||410||343||84%|
|Perth & Kinross||255||239||94%|
Source: SNH Information Response 42
20 In addition to the reduced response rate to notices, the number of returns that are received within the 36 days allowed for submitting returns in s.40 of the 1996 Act, is relatively low. The percentage of returns received by SNH within that time limit was, for example, 64% in 2014/15 and 56% in 2015/16. As a result, SNH has to spend time following up the failure of land owners and occupiers to submit returns after they have been served with a notice. For example, in 2016/17 SNH sent out around 400 letters in November 2017 warning of the risk of prosecution for failing to submit a return. The letters are then followed up with a phone call where necessary.
21 If a return is still not submitted to SNH after the various reminders, the next stage would be for SNH to initiate proceedings against the person involved. Section 40(4) of the 1996 Act provides that any person on whom a notice has been served who “fails without reasonable cause to make the required return within thirty-six days after the service of the notice...shall be guilty of an offence”. The penalty for this offence is given in Schedule 3 of the 1996 Act as “a fine of level 3 on the standard scale or three months imprisonment or both”. Level 3 fines can be up to £1,000.
22 SNH has never instigated proceedings against an owner or occupier over the failure to submit a return. The process would involve SNH, if it is satisfied that the person did not have ‘reasonable cause’ and that it has adequate documentary evidence of the approach it had followed, submitting the case to Police Scotland. If Police Scotland formed the view that an offence had been committed, they would submit the papers to the Procurator Fiscal.
23 The Crown Office and Procurator Fiscal Service (COPFS) would then assess the material to see whether the available and admissible evidence is sufficient to prove the offence has been committed by the person beyond reasonable doubt. If so, a case would then be taken to the Sheriff Court if it was judged in the public interest to do so, to be brought on a summary basis (i.e. has a notice been served in accordance with s.40(1) and if so, has the notice been responded to in accordance with s.40(4)(a)?). If it is established that an offence has been committed, the Sheriff has discretion over the penalty to be imposed in accordance with Schedule 3 of the 1996 Act.
24 This legal process might appear a relatively costly use of public funds to obtain some cull figures. However, the Group considers that the gradually declining cull return response rate and high percentage not submitted within the legal time limit, indicate that SNH should be taking a more robust approach. The Group considers that the proportion of properties in a Deer Management Group (DMG) submitting their cull returns within the 36 day period, should have been one of the criteria in SNH’s current assessment of the performance of DMGs.
25 At present, SNH spends significant resources chasing up cull returns and cannot produce complete data tables based on cull returns for a given year for most of the following year, due to the many months of delays before SNH receives a significant number of late returns. The lack of any prosecutions provides little incentive to those not complying with the terms of the Act.
26 The Group considers that a cull return system that functions effectively is a key component of deer management and that SNH should be discussing the position with COPFS with a view to bringing an initial case or two. While some successful prosecutions might help improve the current position, the Group also considers further proposals to make the cull return system more effective below and in Part Six of the Report.
27 One aspect of these improvements is developing the cull return system online. SNH introduced an online system (Deerline) for submitting returns in 2010/11 after a two season trial period started by the DCS. In 2010/11, 24% of returns were submitted online and five years later in 2015/16, the figure was 37.5%. In both 2016/17 and 2017/18, 36% of returns were submitted online.
28 The Group considers that SNH should be planning for the cull return system to go fully online. A number of other public bodies in Scotland have already made the transition to having their systems fully online. The Group recognises that this poses challenges for SNH given the nature of their current online cull return system. However, SNH is due to replace its current deer database and Deerline system, as discussed further below.
29 The Working Group recommends that Scottish Natural Heritage should be planning to move its cull return system entirely online as soon as practically possible.
21.3 Information Required in Cull Returns
30 The information that can be required with statutory authority in a cull return is limited to “the number of deer of each species and of each sex... taken or killed on the land”. This has been the case for the last 60 years since the original 1959 Act, subject to the change in the species covered from only red deer to all four species.
31 The legislation provides in s.40(1) of the 1996 Act that the return can be “in such form as SNH may require” and a copy of SNH’s cull return form for 2017/18 is included in Annex 9. The form, while it does not distinguish between deer that are ‘taken or killed’, includes additional questions beyond the terms of s.40. Currently, these are in/out of season totals, natural mortality totals and a yes/no question on whether the owner needs to control female deer in April or September. SNH’s online system also includes a question on deer-related traffic accidents.
32 The form does not distinguish between the information required by statute and that which would be supplied on a voluntary basis. Also, the form simply states “Please return this form within 36 days of receipt”. The form does not mention that returning the completed form within that period is a legal requirement. While that is mentioned in the notice requiring a return, the Group considers it might also be included on the form for emphasis given the large number of returns not received within this legal time limit.
33 There are also comments that might be made about the nature of the additional information requested by SNH on the forms. In addition, while the form distinguishes between deer killed in or out of season, SNH also issues separate, non-statutory return forms with each out of season and night shooting authorisation. It has been long recognised that these additional forms, while increasing administration, also increase the risk of double counting or under-counting in the statutory cull returns.
34 The Group considers the design and content of SNH’s cull return form could be reviewed and improved. However, the main issue is the restricted information that can be required under the current terms of s.40. Increasing the scope of the specific information that can be required with statutory authority would not preclude including voluntary questions. The Group considers that an important addition to the form should be the voluntary option for those completing returns, to say whether they have experienced damage by deer in the year covered and the type of interest(s) damaged. This would provide SNH as the regulator with valuable information.
35 The Working Group recommends that Scottish Natural Heritage should provide the option for land owners and occupiers completing cull returns to report whether they have experienced damage by deer in the year being reported and the nature of that damage.
36 An example of a question that should be given statutory force is the fate of the carcases of the deer reported as having been killed. The Group recommended this in Section 11 on Wild Venison and Food Safety, and suggested the types of options that would cover the uses of carcases. In addition to the value of the information discussed in Section 11, the information would also be particularly useful in improving the scope to assess, when necessary, whether the cull figures given in a return are accurate.
37 Section 40(4) of the 1996 Act makes it an offence for a person, in making a return, to “knowingly or recklessly furnishes any information which is false in a material particular”. The Group is not aware that anyone has ever been prosecuted under this provision, although there have long been anecdotal stories of some incidences of false figures being given by some land owners.
38 The Group considers, for example, in situations where SNH is encouraging land owners to take large culls, that SNH should be able to verify the cull figures being supplied. At present, there is no way of cross-checking the figures. However, including information on the fate of carcases on the cull return form and combining that with the information that SNH can require from venison dealers, would at least make cross-checking possible.
39 The Group considers that there should be scope to require additional information on a statutory basis through cull returns. However, the Group considers that this should not be done through adding particular requirements to s.40 in the primary legislation, other than on the use of carcases. Instead, the Group considers that “and such other information as may be prescribed by order” should be added at the end of s.40(1). This would enable a list of required information to be updated more readily from time to time through secondary legislation as priorities evolve.
40 The Working Group recommends that section 40 of the Deer (Scotland) Act 1996 should be amended to enable secondary legislation to be used to add to the types of information that can be required on a statutory basis under the section.
41 The 1996 Act already recognises the principle of the information to be included in cull returns being set out in secondary legislation. Scottish Ministers have the power to make regulations under s.17A ‘Register of persons competent to shoot deer’ that include in sub-paragraph (2)(a)(x) “the information to be included in cull returns;”.
42 Regulations have never been made under s.17A. However, the references to cull returns in s.17A are set within the context of the option of making persons registered as competent to shoot deer responsible for cull returns rather than the owners of land. As discussed earlier in Section 8, the Group considers that it remains important that cull numbers relate to an area of land and that the owner who holds the deer hunting rights on their land remains the person legally responsible for a cull return over that land when a notice is served.
21.4 Extent of Cull Return Coverage
43 The relatively limited coverage of the cull return system across Scotland at present was raised earlier in Section 2, including the fact that this means that the national cull statistics reported by SNH are significantly less than the actual cull of deer in Scotland each year.
44 Figure 9 in Section 2 of the distribution of cull returns across Scotland in 2015/16 showed that approximately 44% of Scotland’s land area is covered by the returns, with the actual figure possibly a percentage point or two higher due to some data in the lowlands that SNH had difficulty linking into the map.
45 Figure 47 gives the percentage of each Local Authority’s land area covered by cull returns in 2015/16 and shows that only six areas have over 30% coverage (Angus 33%, Stirling 46%, Argyll & Bute 46%, Western Isles 52%, Perth & Kinross 53%, Highland 68%). Figure 48 uses Perth and Kinross to show the distribution of returns at a more detailed scale.
46 Figures 47 and 48 reflect that SNH’s use of the cull return system is very largely focused on the upland areas involving open hill red deer and DMGs. The total area of the 44 DMGs assessed by SNH in 2014, 2016 and 2019 is equivalent to c.39% of Scotland’s land area. In these areas SNH aims to achieve 80-90% coverage.
47 This position reflects that SNH’s current policy is to largely limit its use of the cull return system to these upland areas, rather than expanding the coverage to other areas. This policy was set out by Cabinet Secretary Roseanna Cunningham in a written response to a Parliamentary Question in 2016:
“Scottish Natural Heritage (SNH) selects the owners from whom it requests statutory cull returns using their property database, which is largely comprised of properties within upland Deer Management Group areas where collaboration between ownerships is required; properties which apply for out of season or night shooting authorisations; or properties where SNH has identified a need to better understand cull levels in assessing impacts to public interest.”
|Local Authority||Total area (ha)||Known area of properties covered by SNH cull return data (ha)||Local Authority area covered by cull returns|
|Argyll & Bute||690,833||317,610||46%|
|Dumfries & Galloway||642,596||168,090||26%|
|Na h-Eileanan an Iar||305,617||158,321||52%|
|Perth & Kinross||528,541||281,615||53%|
Source: SNH Information Response 15
Source: SNH Information Response 29
48 This statement implies that there may be some additions each year to the coverage outside the DMG areas. However, the extent of additions through properties making returns for the first time after applying for an authorisation will be very limited due to factors such as General Authorisations and the significant proportion of repeat applications for authorisations. Similarly, while SNH becomes involved in some new areas due to issues with deer damage, such as the red deer damage to agricultural crops in the Howe of Alford area of Aberdeenshire in 2017/18, these new involvements appear fairly limited year to year due to SNH focus on the DMG areas.
49 The Group considers that SNH should change its policy of making limited use of the cull return system, and start expanding its coverage over an increasing proportion of the 50+% of Scotland’s land area outwith the DMG areas and not currently covered by cull returns.
50 The high degree of SNH’s focus on open hill red deer and DMGs in its use of cull returns is also matched by the high proportion of SNH’s total annual expenditure on deer management that is focused on open hill red deer and DMGs. However, the increase in deer populations and expansions in their ranges over the decades mean that there is one or more species of deer now established across most of mainland Scotland.
Similarly, as described in Part Three of this Report, damage caused by deer or the risk of it, is widely distributed in Scotland. This includes deer vehicle collisions and damage to agriculture, forestry, the natural heritage and other public interests.
51 The Group considers that SNH, as the regulator under the Deer (Scotland) Act 1996, needs a sufficiently clear picture of deer management in all areas. This should include information on which land owners and occupiers are or are not shooting deer and how many they might be shooting. Developing a fuller coverage of cull returns would enable SNH to address aspects such as gaps in culling and particular incidences of damage. The Lowland Deer Panel has also recently commented on the limitations imposed by the lack of such information.
52 Importantly, expanding the cull return coverage would mean that SNH started to build up information on existing cull patterns across an increasing proportion of deer range in Scotland. As a result, SNH would be much more readily positioned to respond to any issues that may arise over damage or the risk of it.
53 The Group considers that SNH is not going to deliver effective deer management in Scotland, when it is paying such limited attention to deer in half or more of the country. The Group considers that expanding the use of the cull return system is an essential component of providing the information required to promote effective deer management.
54 The coverage by returns could be expanded relatively straightforwardly from the existing pattern of returns by using the existing power of serving notices. The ways that expansion might be developed to best effect through a locality based approach are discussed in Part Six of the Report.
55 In Scotland, the submission of a return by a land owner reporting the details of deer killed in the previous year to the regulator is only a legal requirement on receipt of a notice, while “in the vast majority of European countries some statistic return is compulsory”. Removing the need to send out notices in Scotland by making the submission of a cull return compulsory for the owners of land where deer have been killed or taken, would be a direct approach towards achieving full geographic coverage of cull returns.
56 The Group considers that, given the current limited coverage by cull returns, the introduction of compulsory returns would not be realistic at this stage. However, if the coverage by returns is substantially expanded in coming years using notices as recommended, the introduction of mandatory cull returns should be considered as a measure to complete the process. This is discussed further in Part Six.
57 Expanding the coverage of the cull return system requires identifying the owners of additional properties where deer are or might be being shot, for example, targeting properties of a few hundred hectares or more with or near deer habitat (i.e. woodland). There are a range of sources for identifying properties and their owners, including local knowledge or information from other public sector bodies (e.g. the Land Register of Scotland and Scottish Assessors Valuation Rolls).
58 One of the challenges that SNH identifies with the cull return system is keeping its property ownership database up to date. However, the Land Register will increasingly solve this problem. The percentage of Scotland’s land area covered by the Register was only 32% or just over 2.5 million hectares in April 2018. Figure 49 shows the areas already registered. However, the extent of coverage is due to rise rapidly over the next few years as the Registers of Scotland work towards complete coverage of Scotland by 2024.
59 Registers of Scotland also makes the information on the Land Register available through ScotLIS, a “map-based online land and information service that will ultimately allow citizens, communities, professionals and businesses to discover comprehensive information about any piece of land or property in Scotland”.
60 Figure 49 reflects that much of the land yet to be registered in the Land Register is in the Highlands, where SNH’s existing cull return coverage is greatest. The extent of Scotland covered by the Land Register will increase substantially when major public landholdings (including National Forest Estate land) and more of Scotland’s larger private estates complete registration. A key factor in achieving full coverage will be the use of compulsory registration (‘Keeper Induced Registration’), which started in 2016/17 and will increase significantly in the coming years.
61 SNH’s administration of increasing numbers of cull returns would, as discussed above, be greatly improved if SNH pursued a transition to requiring all returns to be made online and also took a more robust approach to requiring returns to be submitted within the time limit of 36 days in the legislation.
62 A major improvement in the efficiency of SNH’s handling of cull returns would also be achieved by replacing the increasingly aged database that SNH uses, as discussed further below. The Group considers that changes such as these would enable SNH to develop the expanded cull return coverage at relatively little administrative cost, particularly compared to the benefits that fuller coverage would provide.
63 The core benefits of much fuller coverage are, as mentioned above, the value of the information provided in enabling SNH to understand local deer management as part of acting to safeguard public interests from damage by deer. The Group considers that SNH needs to have that information much more widely across Scotland if it is going perform its role under the legislation competently, given the widespread distribution of Scotland’s deer populations and corresponding risks of deer damage to a range of public interests.
Source: Registers of Scotland
64 The Working Group recommends that Scottish Natural Heritage should, as an essential step, start to increase substantially the extent of Scotland covered by the cull return system, taking a targeted and prioritised approach to the areas where the coverage is to be increased.
21.5 National Cull Database
65 SNH currently enters its cull return data into Deerline, an online database that can be accessed by some SNH staff and people submitting cull returns. The system was introduced by SNH for all cull returns from 2010/11 and is relatively complicated to use.
66 Deerline was designed by an external contractor, which now hosts the site and provides ongoing annual support. SNH has access to very basic reporting functions, mostly related to tracking the submission of cull returns and authorisation reports. When more advanced reporting is required (i.e. asking questions of the data), SNH submits a chargeable request to the external contractor who provides the data for use by SNH staff in both numerical and spatial formats as required. SNH can then use this data for GIS and other analysis. This approach is currently SNH’s preferred option when either extracting the required data is not possible with the current SNH access rights or the external contractor would complete the work much more quickly (albeit at a cost).
67 Data collected online via Deerline (and inputted manually by SNH from returns received by post/email) is not available publicly. Registered users can also only access the data they have submitted for their own property or properties. The users can, in addition to their cull returns, submit authorisation applications and returns. There is also the option to report information on deer road traffic accidents and deer counts. The Group consider the system quite basic and not particularly clear for users entering their data, with repeated use generally needed to become familiar with the locations of the various functions.
68 The lack of public access to the cull return data on Deerline contrasts with the situation in some European countries where cull data is both collected and shared publicly online. In Norway, for example, the ‘Cervid Register’ and the ‘Set and Shot’ data entry tool allow the reporting of the number and sex of animals shot, as well as natural mortality, numbers of animals killed in road traffic accidents and, in some cases, an estimate of losses to predation. Carcase attributes are also recorded. All of the aggregated data from different areas and regions is available publicly and it is possible to search the data by county, municipality and specific hunting ground, and to generate tables and/or graphs. The Register can also be used to examine hunting licences and reports.
69 Wild deer in Scotland are a national asset in the public domain and the Group considers that there should be a publicly accessible National Cull Database (NCD) to provide transparency and accountability over cull levels, so that the information is available to public bodies and other interests, including researchers and local land owners.
70 At present, a land owner or occupier is only likely to know local cull levels on a regular basis if they are a member of a DMG that shares its cull data. Making this information accessible and transparent to local owners through a NCD would, of itself, be likely to encourage local discussion of deer management between neighbours and to open up the scope for cooperation where it was in their interest.
71 The Group considers that SNH’s current Deerline system should be replaced with a more user-friendly NCD. This new system should enable the data it collects to be shared publicly as much as possible in both numerical and map-based formats (where applicable), recognising that there would be a level of information that cannot be shared due to the need for data protection.
72 The Group considers that the new system, while being easy to use, should provide SNH with advanced reporting functions and that SNH should know how to use the system so staff can manage it in-house. The new system should also provide improved opportunities for two-way communication between SNH and registered users, for example about local damage or other information relevant to the local area.
73 The Group is aware that SNH recognises that its relatively old Deerline system is no longer fit for purpose and is giving consideration to its replacement. The Group considers that a new system is an essential investment. The Group considers that the development of a fully online cull return system and a publicly accessible NCD should be important components in improving deer management in Scotland due to the information that they would provide to SNH, land owners and others.
74 The Working Group recommends that Scottish Natural Heritage should replace its current online deer database with a new system and establish a publicly accessible National Cull Database.
1 See Section 1.
2 Agriculture (Scotland) Act 1948, s.54.
3 Electronic Communications (Scotland) Order 2006.
4 Public Services Reform (Scotland) Act 2010.
5 Section 17A is discussed in Section 8 of this Report.
6 Callander, R. and MacKenzie, N. (1991). The Management of Wild Red Deer in Scotland. Rural Forum, Scotland, pp. 37-38.
The table on page 38 was extended to 1995 by a further Parliamentary Question in 1995.
7 Daniels, M. (2008). ‘Limitations of data currently collected’. Internal DCS Report.
8 Daniels (2008) Op cit.
9 SNH Information Response 42.
10 SNH Information Response 16.
11 SNH Information Response 16.
12 Adequate documentary evidence may require some changes to SNH’s administrative procedures. At present, for example, SNH records the date on which a cull return is entered into its deer database and this might be some days after the return is received (SNH Information Response 37). The Group considers SNH should record the date on which a return is received.
13 As the Group found in requesting statistics from SNH.
14 SNH Information Response 16. Those returns submitted in hard copy are inputted manually to Deerline by a member of SNH staff.
15 Including, for example, Forestry and Land Scotland.
16 Deer (Scotland) Act 1996, s.40(1).
18 There are no provisions in the 1996 Act to require a return of the number of deer shot under an authorisation, but SNH requires as a condition of their authorisation that their form with the authorisation should be returned to SNH within seven days of the expiry of the authorisation.
19 For example, Daniels (2008) Op cit.
20 See Section 2.
21 SNH Information Response 15.
22 SNH Information Response 15.
23 SNH (2016). Deer Management in Scotland: Report to the Scottish Government from SNH, October 2016.
24 SNH Information Response 15. This level of coverage is also reflected in the figures and map given in Box 3 ‘Cull Data’ in Albon, S. et al. (2017), Estimating national trends and regional differences in red deer density on open-hill ground in Scotland: identifying the causes of change and consequences for upland habitats. Scottish Natural Heritage Commissioned Report No. 981, p.11.
25 Scottish Parliament, Written Answer S5W-00707, 29 June 2016.
27 See Section 26.
29 Lowland Deer Panel (2019). Report to Scottish Natural Heritage, February 2019.
30 The Group disagrees with SNH’s apparent view that the benefits of expanding cull return coverage would not be worth the effort. SNH correspondence with DWG 19 June 2019.
31 Putman, R. (2012). A review of the various legal and administrative systems governing management of large herbivores in Europe. In: R. Putman, M. Apollonio and R. Andersen (Eds.), Ungulate Management in Europe: Problems and Practices. Cambridge University Press, pp. 54-79.
32 The cull return system, and indeed the link between land ownership and deer hunting rights, might be considered to become increasingly unsuitable in and around peri-urban and urban environments with particularly fragmented ownership patterns.
33 Other public sources include data from Forestry and Land Scotland, the Scottish Environmental Protection Agency, and the Scottish Government Integrated Administration and Control System (IACS) Business References.
34 Registers of Scotland Annual Report, 2017/18.
35 Registers of Scotland Annual Report, 2016/17.
36 While SNH current serves around 3,000 notices, it was calculated in 2008 by the DCS that 2,500 returns took 24 staff days
(Daniels 2008 Op cit).
37 Approximately 20 people at SNH have access to the system (ex-DCS staff and some wildlife licensing officers).
38 SNH has an annual budget of £7,500 to cover hosting fees, IT support, any required changes, and data requests. There is no separate budget for data requests.
39 While land owners have more than one property, ‘a handful’ of large private estates make multiple returns either for different ‘beats’ on their estate or because they own land in more than one DMG area (SNH Information Response 24).
40 See https://hjorteviltregisteret.no/.
41 See https://settogskutt.no/.
42 Putman (2012) Op cit.
43 The availability of the information would, for example, enable researchers other than SNH or those working through SNH to analyse the data.
44 The RDC traditionally considered the sharing of cull information as the first step in local cooperation that might lead to the formation of a DMG.