The following observations by ADMG relate to the April 2017 Report to the Cabinet Secretary by the ECCLR Committee and are presented in the context of the debate on deer management in the Scottish Parliament on 2 May 2017.
The ECCLR Committee report recognised that:
- Notable progress has been made by most upland deer management groups (DMGs) since the 2013 RACCE Committee review.
- Deer management across Scotland – four species, many different environments and land uses – is varied and complex.
- Deer impacts are more important than numbers, and should be considered in a local context.
- All herbivore impacts should be considered – deer, sheep, etc
- Incentives as well as penalties are necessary to promote effective deer management in the public interest.
1. Deer Management Planning
ADMG acknowledges that more work is required to achieve improvements to some habitats, as well as other aspects of the public interest. ADMG coordinates and supports the deer management sector in this regard.
With regard to the status of deer management plans:
- 42 out of 44 DMGs now have plans that take into account the public as well as the private interest.
- 37 plans are publicly available online at www.deer-management.co.uk
- Next steps should be directed towards delivery of deer management plans. This work is already underway.
- New DMGs in new areas will require support through the deer management planning phase.
2. Section 7 Areas
The ECCLR Committee, we think wrongly, took a negative view in respect of S7 Control Agreements and native woodlands affected by herbivore impacts. For example the Mar Lodge S7 Agreement was concluded last week, 3 years early, having achieved its habitat objectives. Other than on designated sites, the countryside is a working environment and deer management makes an important contribution to Scotland’s rural economy.
3. Protected sites/native woodland
While there is room for further progress, ADMG regards this as a positive area (1606 natural features are affected by herbivores; 75 per cent are in favourable, or recovering condition), and in the case of native woodlands two thirds. Time is a crucial factor and any measurable habitat response to management will take several growing seasons at exposed upland locations.
4. Deer sector progress
The Committee concluded in respect of DMGs “it would be reasonable to have expected a greater rate of progress in terms of implementation and delivery of outcomes.” ADMG disagrees. Why? Principally the timeframe for delivery.
No detailed definition of ‘the public interest’ was provided by SNH until August 2014, and the baseline DMG assessments not done until November 2014. Funding support for DMGs to create/revise Plans to take account of the public interest was not available until January 2015. The Plans were reassessed for the Review less than 18 months later. While it was reasonable to assess progress on the planning process in June 2016, assessing DMGs on delivery and implementation, was simply not possible within that timeframe. The implementation stage has now commenced and can reasonably be assessed in 2019.
5. ADMG immediate priorities
ADMG has a forward work programme including:
- Developing Habitat Impact Assessment (HIA) frameworks across all DMGs, supported by a training video.
- Re-launch of Wild Deer Best Practice
- Taking forward the SWARD project – finalisation of software to assist DMGs in processing and analysing deer population and habitat data.
- Supporting the formation of new DMGs.
6. Economic impact of deer management
The SNH report to the Committee overlooked the secondary economic impacts of deer management in its use of figures for deer related economic activity. The overall contribution of deer management to the economy, including downstream activity, was estimated by PACEC in 2016 as £141m/annum and 2520 FT equivalent jobs.
Further substantial reductions in deer numbers could make many stalking businesses unviable and lead to loss of jobs. It would will also mean a short-term glut in the venison supply chain followed by reduced supply to an expanding UK market, a particular Scottish food sector success story.
7. Lowland deer management
It is noted that the Committee is disappointed that there has been “so little progress” in this area, as well as lack of information on numbers and impacts.
However, it is wrong to assume that where there is no deer group then no deer management is taking place. There are over 6000 DSC 1 qualified deer managers in Scotland. A reasonable assumption would be that over half of these vocational deer managers are active, or available, in the lowlands.
LDNS, set up in 2011, is playing an active role in promoting voluntary collaborative management and encouraging engagement from farming and land owning sectors and from local authorities.
8. Statutory powers
ADMG agrees that SNH should use its untested statutory powers where necessary but asserts that there is no requirement for more powers until those existing have been tried and shown to be inadequate.
9. ECCLR Committee proposals
The Committee has suggested that the voluntary basis for deer management is maintained alongside a more regulated approach. This would involve SNH determining annual culls for all landholdings (reported to number 55,000); mandatory cull returns; 5 yearly compulsory counts by DMGs; also a statutory Duty to manage deer sustainably.
In upland areas, working with all the individual DMGs, SNH is already involved in population modeling and cull setting through the deer management planning process.
Such a regulated system could no longer be described as voluntary.
10. Working group
ADMG supports the establishment of a working group but would wish this to focus, at least in part, on the future development programme.
11. Additional resources
There are significant cost implications to the ECCLR Committee’s recommendations, and, as suggested by the Committee, a full public cost assessment should be a priority. SNH is under-resourced and would require a significant increase in funding if the Committee proposals (9 above) were implemented. In particular additional funding and support would be required for significant change to be made in lowland and near urban areas.
12. Policy context
ADMG supports the Committee’s desire to identify “societal objectives … for our different landscapes”. A better understanding of what the nation wants will allow deer managers to better contribute, while maintaining the environmental, economic, social and cultural values of wild deer.
13. Next steps
ADMG considers that:
- The voluntary basis of deer management should be maintained, subject to the Deer Code, and the existing statutory framework.
- SNH, where circumstances demand, should use its statutory powers.
- The deer management plan process should continue and be reviewed on a 3 yearly basis as provided in the land Reform (Scotland) Act 2016.
- The ADMG development programme (5. above) should be supported by all relevant interests.
Association of Deer Management Groups
April 2017