Managing Deer for Climate and Nature: Analysis of consultation responses

9 Other issues raised by respondents

9.1 Chapters 3 to 8 have presented an analysis of the responses provided to the questions set out in the consultation paper. However, a range of other (related) issues were raised repeatedly across the questionnaire and are discussed briefly below.

Lack of clarity in the proposals

9.2 There was widespread comment about a perceived lack of clarity in the proposals and in definitions. These comments were made both by those who generally supported the proposals and those who did not. Such views were expressed in a range of contexts. For example:

• Respondents wanted clarification about the evidence that would be used to implement DMNROs, and how the new powers associated with DMNROs would relate to existing legislative provisions (including existing Control Agreements, established under Section 7 of the current Deer (Scotland) Act 1996).
• Respondents were unclear about the circumstances in which a Section 10 order (involving emergency intervention) could be imposed on a landholding, and its relationship to other provisions in the Deer (Scotland) Act 1996.
• Respondents wanted clarity about how incentives would be used to support landowners/land managers in deer management activities – and what conditions would be attached to these incentives.
• Some respondents found the questions difficult to answer because they thought the proposals were ‘vague’. For example, there was a view that the consultation was unclear (at Question 9) on what additional information might be required from landowners. Similarly, respondents wanted further detail about live-capture scenarios (which Question 18 proposed should be individually authorised by NatureScot) and wanted to know whether these related to capture-for-culling, or other purposes.
• There were many instances across the consultation questions where respondents asked for clarification about terminology, or thought the terms being used were highly subjective and/or lacked proper definition (e.g. ‘indirect damage’, ‘nature restoration’, ‘natural heritage’, ‘emergency’, ‘kept’ versus ‘captive’ deer).

Alternative approaches to deer management

9.3 Across the questionnaire, respondents referred to or suggested a range of alternative approaches to deer management which did not feature in the proposals. They sometimes described these as ‘other tools in the toolbox’ of deer management. These included, for example:

• The use of financial and other incentives: These included a detailed proposal for operating a ‘bounty’ system (i.e. paying a ‘bounty’ for every female deer culled), and a suggestion that financial support should be given to farmers and crofters to obtain the necessary deer shooting qualifications. (However, as mentioned above, there was also a view that financial incentives and other payment should be used carefully and should not be paid to those who are not demonstrably pursuing good deer management practices.)
• The (re-)introduction of predators such as lynx, wolves and bears: It was noted that these types of approaches were being used in parts of Europe to address overpopulation of various species, with some success.
• The use of sterilisation and immunocontraception as a humane method of reducing the deer population: This approach was suggested by animal welfare organisations.
• Making deer management the responsibility of communities, rather than of landowners: It was noted that this was a common practice elsewhere in Europe and North America and had been successful in controlling deer populations.
• Reducing the regulation of deer hunting in Scotland: Some respondents said that deer hunting in Scotland is over-regulated – and more heavily regulated than in Europe and North America. These respondents thought less regulation would improve deer management and open up opportunities for a wide range of competent individuals to shoot deer.

Deer Working Group recommendations

9.4 The recommendations of the DWG were referred to repeatedly across the consultation. In general, respondents wished to be reassured that the Scottish Government would be addressing all the DWG recommendations – not just those that were the subject of the current consultation. More specifically, conservation organisations and individual respondents emphasised the importance of implementing a compulsory cull approval system (DWG recommendation 97) and queried why the DWG recommendation in relation to the control of non-native species (DWG recommendation 38) had not been implemented.

9.5 In addition, respondents noted that the consultation questionnaire did not invite views on all the recommendations – recommendations 66, 67 and 72 in Part 2 of the consultation were, for example, highlighted in this respect.