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

RSPB/LINK Deer Group

Dear Brodie,

Thank you for your email of 18^th May, consulting Scottish Environment LINK in relation to proposed secondary legislation on deer management to be brought forward by Scottish Government. I am responding on behalf of the LINK Deer Group comprising of all of the main eNGO landowning bodies in Scotland. We are all involved in managing deer populations on our land .

We strongly support the measures that are being proposed, all of which are recommendations of the independent Deer Working Group Report published in 2020, and which were accepted by Scottish Government in their Response to this report published in 2021.

We support increased flexibility for sustainable deer management in the context of the climate and nature emergencies and where high and increasing deer populations across Scotland are acting as a significant impediment to delivering a wide variety of public outcomes. These outcomes include protection of existing native woodlands; new native woodland expansion; protection of peatlands and associated public investment in peatland restoration; and damage to wildlife and their habitats. The success of many Scottish Biodiversity Strategy outcomes, and therefore meeting statutory nature targets to be set out in the Natural Environment Bill in 2024, depend on reducing deer populations to sustainable levels. We recognise that deer are an important part of the natural heritage, however we also understand that in the absence of natural predators ‐ and for the enhanced welfare of deer themselves ‐ their populations need to be managed by humans. We are satisfied that these additional measures, including the use of night shooting equipment, will be carried out in a skilled and humane way by Scotland’s experienced deer managers.

We are disappointed that measures have not been brought forward at this stage to extend the seasons for female deer on the basis that is the female deer that are the main drivers of the overall population. However, we fully understand that this is a sensitive welfare issue that requires careful consideration. We agree that it is sensible to seek further advice from the Animal Welfare Commission, and trust that thereafter new humane measures to enhance the management of female deer can be brought forward via secondary legislation and at an early stage.

Lead ammunition is toxic to wildlife, as well as humans, and we support an early and complete phase out of all non‐ lead ammunition used for the purposes of deer and other wildlife management. This secondary legislation to improve the accessibility of alternative non‐lead ammunition is therefore a welcome step in the right direction, however we will continue to press the case for a complete ban on lead ammunition as proposed by the EU REACH process (also applicable in the UK).

We hope that this feedback is helpful.