The NGO response to DEFRA consultation on the proposed deer management strategy
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The NGO welcomes the opportunity to reply to the DEFRA consultation on the deer management strategy. However the NGO would like DEFRA, when reviewing our responses, to understand that we do not consider deer to be a national problem.
Introduction
The National Gamekeepers’ Organisation (NGO) is the representative body for professional deer managers and gamekeepers in England and Wales. The organisation currently has a membership of over 13,000 with more than 5,500 of those members part of the organisations deer branch.
After a recent survey the NGO estimate that around 540,000 deer are culled annually in the UK most of this culling takes place on private estates under the supervision of professional deer managers and gamekeepers.
The NGO welcome the opportunity to reply to the DEFRA consultation on the deer management strategy. The NGO would like DEFRA, when reviewing our responses, to understand that we do not consider deer to be a national problem. There are areas in England where deer do cause significant damage and environmental impact and other areas where the deer population is so low as to be negligible and many areas where deer are managed properly with measurable outcomes. In response to some of the consultation questions the NGO refer to the successful badger cull in terms of a localised response to a wildlife problem that was well managed and operated and that model should be considered to be replicated in areas where deer are proven to be a significant problem. We also feel that a holistic approach to tree protection needs to be undertaken, we need to manage not just deer but pest species such as grey squirrels and parasites and be mindful that certain commercial forestry practices and machines can be many times more destructive than deer.
Our Overview of the consultation proposals
The deer strategy consultation document asks some very interesting questions, but it is light on detail and government stance. The NGO would have liked government to have outlined what they see as the future of deer management in England but it seems other than one specific idea (removing seasons for male deer) it simply asks if DEFRA / FC should look to review existing legislation.
There is a lot of emphasis of a national deer problem, but as we have stated the NGO do not except that deer are a national problem and the consultation paper or the Forestry Commission blog that is linked to the consultation offers no evidence that they are. Targeted approaches are key to managing wild deer in and around the areas that they are causing provable and significant damage to flora as well as targeting the specific species that cause the most problems which are fallow and muntjac deer.
We also need to consider that promoting the use of wild venison as a sustainable food source and generating more markets for it has some problems to overcome, but in the now this promotion is necessary. The current capacity of Approved Game Meat Handling Establishments for one is a massive bottle neck. The seasonality of wild venison can also be an issue with continuity of supply. By creating markets for wild venison, a further problem could be created if the numbers of wild deer are to be reduced dramatically. Businesses who have been built on the sale of venison would no longer be able to source a reliable supply from the UK market.
The NGO would like to see more detail in the government's proposals for incentives, legislation and mandatory training which should have been outlined in this document. We would also like to see a targeted local approach to deer management in England working with private landowners not legislating against them.
Consultation questions
Sustainable management (page 4)
6. To what extent do you support the introduction of incentives for reducing deer impacts to protect woodland?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
Although incentives already exist to protect woodlands under various schemes, it appears that they are not working. The answer to this question depends largely on what the proposed incentives are, who they are paid to and how they will be measured. Any incentives must go directly to deer managers or their employers, especially if they are operating as vocational individuals or syndicates / tenants. With rising costs and lower carcass prices, any incentive should be attractive and paid on a results-based system.
We know that incentivised per unit systems, for example, work. A group of private estates in the South East have set up such a system with all its deer managers specifically targeting female fallow deer. The group pays the stalkers a rebate on their stalking rental of £100 per mature female deer that is culled and delivered into the estate larder in addition to the per kg price the approved game handling establishment is paying. This has incentivised the deer managers to increase the deer cull on the estate dramatically and has had an immediate effect on female fallow deer numbers.
It is important that all incentives are targeted at specific locations and species where deer are causing a problem. This will make any government money have a real impact on areas where it is needed and will avoid wasting money in areas where it’s not.
The NGO do not accept that there is a national deer problem, we do acknowledge that localised problems with certain species of deer do need to be prioritised.
Improving the laws and regulations on deer (page 5)
7. We propose to review and amend existing legislation to allow shooting of male deer during the existing close season. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
All deer managers understand that to control populations of deer, it is the females that need to be reduced in number. We accept that male deer can cause localised problems, but there is sufficient time in England to cull male deer to agreed plans. Where male deer are out of season and causing significant damage, there is a mechanism to cull them under the 1991 Deer Act, which does not need reviewing at this time.
There are other factors to consider, Approved Game Meat Handling Establishments (AGHEs) do not necessarily want to take large numbers of male deer during the summer months, so the question of where the carcasses of these male deer would go to would be an issue. Secondly, to distort the populations of deer by encouraging eradication of one sex will impact on normal behaviour (a right) and may well create more problems by changing deer behaviours to compensate. The risk of perturbation and actual population increase long term are just two of those problems.
8. We propose to review existing legislation to either reduce or remove the licencing process to permit shooting of deer at night to enable appropriate, proportionate, and effective control. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
We disagree that there should be any removal of a night shooting licence, but we do agree that the application process for night shooting licences does need to be re-visited. The successful badger cull is a good example of localised and well-managed night shooting run by DEFRA with measurable outcomes. A similar system could be considered for managing deer in areas where there is an exceptional problem.
Removing the requirement for applying for a night-shooting licence has the potential to increase poaching instances and indiscriminate shooting of deer.
There are already good examples of where large landscape-scale night-shooting licences are being trialled in areas where deer populations have been shown to be causing significant environmental damage and these programmes - such as one which is currently being undertaken by Natural England - should be looked into as a way of modelling any system going forward.
9. We propose to review deer legislation to enable landowners and managers to reduce deer damage to woodlands or to other public interests, preventing the further spread of non-native species and preventing serious damage to any form of property as well as to the natural environment and public safety. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
The 1991 Deer Act Section 7 already allows landowners to protect growing crops and timber and we feel it is currently sufficient to deal with almost all instances of deer damage. We do also feel that this review should have been undertaken before this consultation was released so more detailed proposals could have been brought to the table. This consultation should have suggested proposals to alter legislation and not have produced a paper asking if more reviews and consultations are needed. This seems like a waste of tax payers’ time and money.
10. We propose to enable occupiers (tenants or owners) of land to control deer, where the deer rights are retained by the landlord or previous owner (and where serious damage is occurring to trees crops or property), particularly where these are publicly funded. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
There are already provisions under section 20 of the Agricultural Holdings Act 1986 that allow tenant farmers to claim compensation from landlords from damage to crops from wild animals and game.
Any further change to the law is simply unworkable and would need to be fully looked at in terms of the legal status of tenancies and other land uses that are retained. There are so many potential conflicts from farm tenancies, sporting lets and landowners that different options will need to be considered.
There are also possible problems with firearms laws with regards to certificates and need to prove a lawful authority and a reasonable excuse to carry a firearm.
11. We propose to clarify the legal status of wild deer particularly in relation to enclosed deer in parks or private collections, thereby reducing the likelihood of negative deer welfare or public health issues. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
We don’t feel that this will have any impact at all on reducing the wild deer population or and risk to deer welfare or public health. Deer parks already have legal obligations with regards to animal welfare as well as public safety and providing safe food.
12. We propose a more statutory approach to landowner responsibilities for deer where they are causing significant negative impacts to neighbouring land where these are impacting upon publicly funded woodlands, biodiversity and public interests. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
This will not help reduce the deer population. It is more likely to cause distrust among land owners and their neighbours when landscape-scale control is needed. Potentially creating a statutory approach will have the counter effect and landowners will disengage with government bodies. Proving where deer are harbouring, and living can difficult. And indeed, many wildlife reserves won’t cull due to public perception and the needs to raise funds from those members of the public.
There is also a large possibility of negative press with “nature reserves” being forced to cull deer to protect private landowners’ estates (possibly their neighbours). That alone could potentially set back deer management at a local level.
We suggest that all deer management strategies are put in place working with private landowners and the private sector / vocational stalkers instead of legislative burdens that will create resentment and distrust with government bodies.
Minimising the spread and impacts of non-native deer species (page 5)
13. Which actions would you consider, to allow more effective means of controlling muntjac to prevent them damaging woodlands and biodiversity and expanding their range into areas they are not currently present?
We feel that the best way to incentivise all deer managers to cull muntjac will be through a measurable payment system. A per-carcass payment system has been successfully implemented in the DEFRA badger cull, with animals being collected or taken to a central collection point with the cull lasting for a limited time period.
We propose a similar approach to managing muntjac deer in England, with deer managers being paid for each muntjac deer they cull. We suggest that all the carcasses should be collected or delivered to the nearest Forestry England larder to ensure that the animals have actually been culled. This would have the advantage of Forestry England having 100% accurate records of locations and numbers of muntjac that have been entered into the payment scheme and FE will also have an income from those carcasses when they sell them into their markets.
Using current AGHE’s would probably not be a suitable option because of the capacity issues they have and in some cases the unwillingness to purchase or handle muntjac carcasses. We feel that if the government would like to see significant increases in the national muntjac cull then the government needs to help with placing of the carcasses into the food chain in addition to incentives paid to undertake the cull.
Deer Health, Welfare and Safety (page 6)
14. We propose that everyone who culls deer in England has to reach the same standard. To what extent do you support this proposal?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
Standards are really important, but we have to be careful that more barriers are not put in the way of new entrants to deer management in England and those older deer managers / stalkers who may not have undertaken formal training other than wild game meat hygiene courses. There is no evidence that deer management in England is a) dangerous to the public or the practitioner, b) not humane, c) doesn’t follow best practice.
The National Gamekeepers’ Organisation has not had any insurance claims in the past three years from our membership of circa 13,000 that directly relates to deer management or associated activities so we can only say that it is safe.
We already have a requirement for all game meat including venison that goes through an AGHE to have been inspected by a trained hunter, and the FSA is currently standardising that training.
The NGO is fully committed to improving the standards and to training in all forms of wildlife management, but to make training mandatory would not help reduce the deer population or improve safety.
15. What would you consider the most effective means of developing a consistent national approach to responding to deer collisions and deer welfare incidents?
We would like to see some changes to primary legislation would be needed to make any scheme effective. We feel that making it a legal requirement drivers who have an incident with a deer or any other animal to report any RTAs and for insurance companies to do the same. This would create a national picture of where there are problems and where targeted responses are needed, which would need to be done working with highways agency and local authorities who own the roads.
We would also support a voluntary Home Office-approved humane animal dispatch course that all those who attend RTAs must have undertaken. This would include police officers, highways agency enforcement officers, volunteers, RSPCA vets, etc.
Thirdly, all volunteers who attend RTA’s involving animals should be fully insured by the body responsible for calling them to the scene. It should not be for private individuals to carry their own insurance for humane animal dispatch on the road side.
Wild Venison Market (page 6)
16. Do you consider there are presently barriers to the development of a commercially successful wild venison market?
• Yes
• No
• Unsure
There are barriers to the venison market both nationally and locally. The main concern for our members is the capacity available at AGHEs, which is limited compared to the annual deer cull in the UK already. The bulk of the deer cull is conducted from 1st November to 31st March in England when it is open season for culling the female deer. There are often times when game dealers are unable to take deer from estates operating in the private sector, frequently due to priority being given to Forestry England larders and those being collected from first. Several large estates have reported that they have had to cease culling until the AGHE had processed the Forestry England carcasses. This has taken up to 14 days. A solution to this would be for Forestry England to become an AGHE in its own right to reduce this backlog. This would take very little investment with the publicly-funded larders already up to an excellent standard and would have a real impact on reducing deer numbers in areas where needed. AGHEs are still able to trade between themselves so it should not affect the bottom line.
There are also significant planning problems for new entrants to the venison processing markets that will need to be looked at in order to increase the capacity of AGHEs in England. Water regulations and local planning restrictions are all barriers to creating more capacity. Using existing premises such as Forestry England larders could be a short-term solution.
17. To what extent do you agree that Government should support development of the wild venison sector?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
We agree that every effort should be made to support the development of the wild venison sector, but markets should be free and supply and demand should be the main driver. Creating demand for the product (wild venison meat) is key. We would like to see a level playing field with Forestry England not having restrictive contracts with AGHEs that limit the supply of carcasses from the private sector even if it is only on a local level.
The other issue with promoting the wild venison sector is that increasing a market for a resource that is not finite can be problematic with businesses being asked to build markets with the ultimate goal of reducing the availability of the raw materials needed. Provisions will need to be put in place for the longevity of the market.
Developing and improving the Evidence Base (page 7)
18. To what extent do you support the development of a National Deer Data Dashboard?
• Strongly Agree
• Agree
• Disagree
• Strongly Disagree
• Do not know
This depends on what this will look like. Vocational stalkers will probably be unwilling to report complex cull records. It also depends on what data DEFRA / Forestry Commission are looking for and how it will be used?
Cull data already exists through the Game & Wildlife Conservation Trust’s game bag census as well as grant scheme cull records. Deer populations can be analysed through the British Deer Society’s data and mapping.
Financial implications of proposed strategy actions.
19. Do you believe any of the proposed actions will have any positive or negative financial implications for the woodland/land management sector?
• Yes
• No
• Do not know
The paper has asked questions about looking into various legislative options, but has not come up with many definite ideas or any solutions. So, until we can see what the final outcomes and ideas are, this question is difficult to answer.
However, it if there are incentives to cull more deer we would like to see that awarded to the practitioners, not just the landowners, to make sure the monies are used to facilitate the management of deer.
There is the possibility that financial incentives could have a negative effect on the private sector who can currently sell or rent stalking rights for considerable sums. If there is a more legislative approach this could be devalued and less investment would be put into trees, the environment and deer management.
20. Do you believe any of the proposed actions will have any positive or negative financial implications for those involved in deer management?
• Yes
• No
• Do not know
This depends entirely on how any incentives are paid and who they are paid too. If they are paid to landowners who lease or sells their sporting rights or stalking rights then this money will not filter down and it will be business as usual for both the landowner and the deer manager. As we have shown in the answer to question 6, properly funded and administered incentive schemes will and do work but the money has to go to the right place for it to have any impact.
21. Do you believe any of the proposed actions will have any positive or negative financial implications for wild venison production?
• Yes
• No
• Do not know
There is no evidence in this document that there will be any support for the wild venison market. We have suggested that Forestry England become an AGHE, which would increase the capacity of the wild venison market and would alleviate some of the problems with bottle necking at the current AGHEs. The government could support FE becoming an AGHE by using its own institutions as a vehicle for promoting the consumption of wild venison such as the Ministry of Defence, The DVLA, the NHS, etc.
The NGO believes that the best way to increase the deer cull in areas where it is needed is to increase the value of the carcass for the deer manager directly.
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