Deer (Scotland) Act 1996 - proposed amendments: consultation analysis

Forestry and Land Scotland

Official Sensitive

For the attention of:

Brodie Wilson and Robyn McCormack Wildlife Management Unit

Scottish Government Via Email

12^th June 2023

With reference to the Minister for Green Skills, Circular Economy and Biodiversity’s letter dated 17 May 2023, Forestry and Land Scotland (FLS) fully supports the Scottish Government’s proposed amendments to the Deer (Scotland) Act 1996 via Secondary Legislation:-

Permit the use of light intensifying, heat sensitive or other special sighting devices to shoot deer at night (DWG recommendation 7).

Justification: There is no public interest case for continuing to deny landowners, occupiers or those with their permission the option of using light intensifying, heat sensitive or other special sighting devices to shoot deer at night in order to prevent damage to crops, peatlands and natural habitats in order to help improve Climate Change mitigation and enhance biodiversity. FLS currently uses artificial light (spot-lamp and thermal imaging) regularly as part of its night shooting operation. FLS has safely carried out effective and efficient night shooting activities on Scotland’s National Forests and Land for 40 years, including in the urban/peri-urban environment, and would view night sights as a very useful addition to its culling ‘toolbox’. The wider use of night sights across Scotland should help facilitate the anticipated, significant reduction in the Scottish deer population.

Amend the minimum bullet weight so as to make non-lead ammunition more accessible (DWG recommendation 4).

Justification: The DWG’s concern with the use of lead ammunition is its implications for human health and the impact on the market for Scotland’s wild venison. Venison dealer retail customers are increasingly insisting on a move towards non-lead ammunition as supermarkets become less tolerant of lead ammunition within carcasses or venison (which has a unique selling point as a healthy lean meat product, compared with red meat). Both FLS and NatureScot currently use non-lead ammunition across the majority of their culling operation and therefore the great majority of deer shot on public land in Scotland are already killed safely and efficiently using non-lead bullets. Given that an increase in venison processor capacity (and retail/consumer demand and confidence), will be absolutely crucial to a successful uptake of the anticipated rise in future deer cull/carcasses/venison products, an increase in the use of non-lead ammunition will be very beneficial.

Remove close seasons for male deer to lengthen the time during which wild male deer can be taken or killed across the year (DWG recommendation 8).

Justification: There are no animal welfare or biological reasons to have close seasons for male deer of any species and there is also no public interest case for restricting the right of the owners and occupiers of a range of land types from shooting male deer all year round (owners and occupiers can choose if they want to maintain their own seasons for when they shoot stags and bucks). It is likely that the cull of male deer will become more widespread during the year and this will potentially benefit the supply of wild venison by reducing its seasonality, particularly during the close season for females over the summer months. Deer need to feed 365 days of the year and, during severe weather conditions, can do considerable damage to crops, habitats and efforts to mitigate Climate Change and improve biodiversity, in a short space of time, therefore the enabling of culling for an increased period of the year, where necessary, is welcome. Trained, competent and experienced deer cullers are able to deliver a well-targeted, clean shot to each deer culled, whichever time of year the culling takes place, whether before, during or after the rut.

Yours sincerely,

[Redacted]

Graeme Prest

Director of Land Management & Regions Forestry and Land Scotland