The Association of Deer Management Groups (ADMG) welcomes the opportunity for stakeholder engagement and always insists that deer welfare is at the forefront of any changes to deer management legislation. We therefore have reservations about elements of the proposed changes.
The recommendation that light intensifying and heat sensitive devices for the night shooting of deer be permitted raises concerns, particularly in relation to the identification of deer sex and age as well as the ability to identify whether there is a safe backstop for bullets or ‘in line of sight’ vegetation which could lead to bullet deflection. There may also be risk of misidentification particularly in areas of regular human activity. Weather conditions can alter the performance of these devices and could lead to an increased chance of mishap. If the Scottish Government is to proceed with this recommendation ADMG would strongly recommend that Best Practice Guidance is in place for the use of this technology prior to any implementation.
The proposed adjustment to approved ammunition regulation for deer would be welcome in view of the steadily increasing take-up of non-lead ammunition on food safety and environmental grounds as the present restrictions have acted as a constraint on the conversion process, particularly at some calibres. However, ADMG is aware that some of our members have concerns about the efficacy of non-lead ammunition and have raised welfare concerns. We are also aware of a heightened risk of bullet ricochet with non-lead ammunition and therefore health and safety issues when using it. It is for the person responsible for the culling to ensure calibre size and bullet weight is appropriate for conditions and species.
ADMG welcomes the decision not to extend the season for female deer but we do have apprehensions about the removal of the stag seasons. Many deer managers will continue to stick to the same traditional seasons and choose not to shoot deer further into the winter when stags in particular are in depleted condition post rut leading to welfare concerns about disturbance due to culling. We feel therefore that this change has negative welfare implications while being unlikely to greatly increase the cull of deer in Scotland. It will also be likely to be a divisive issue within some Deer Management Groups and undermine effective landscape scale collaboration.
The advantage of the current requirement to have an authorisation to shoot deer out of season means that there are checks and balances as to who is culling deer and a valuable record of out of season culls. To obtain an authorisation it is currently necessary to be on the Fit and Competent Persons register and be aware therefore of Best Practice Guidance. Removing this necessity means that NatureScot has less control of who is shooting deer and when, and deer welfare is potentially compromised. ADMG feels strongly that any downgrading of the use and status of the Fit and Competent provision will be a significant retrograde step, and indeed a surprising one when the general trend in respect of deer management and other upland land use is for increased regulatory intervention.
Tom Turnbull
Chairman, ADMG
May 2023