Deer Management: Proposals for Improvement
April 2004
Introduction
The National Gamekeepers' Organisation (NGO) was pleased to be consulted by Defra officials working on the current review of sustainable deer management in England. Deer populations continue to rise and it is encouraging that the Government recognises that a rethink on deer management is now necessary.
For the record, the NGO was founded in 1997 and now has over 8,000 members. It represents the gamekeeping profession in England and Wales. More details about the organisation can be found on our website: http://www.nationalgamekeepers.org.uk/
General Points
The NGO agrees with Defra that deer numbers are increasing and that the ranges of all species are spreading. We also broadly accept the conclusions of the Defra paper, ‘Current and Future Deer Management Options' in relation to the many problems this increase is causing.
We firmly believe that properly conducted culling is the key to sustainable deer management and there is no evidence that non-lethal ‘solutions' could ever work on the scale required.
Furthermore, stalking provides economic benefits and highly valued meat, neither of which would apply to a non-lethal approach.
We believe the Defra paper underrates the importance of stalking carried out by professional gamekeepers and stalkers, and overestimates the contribution that well-trained amateur stalkers can make. We have no objection to ‘hobby stalking', indeed it is essential to ensure a big enough cull overall but we would point out the following benefits of culling by professional gamekeepers and stalkers:
- Gamekeepers/stalkers probably shoot about half the deer culled in the UK at present[i].
- Because professionals shoot more deer, their experience is extensive.
- They are permanently on the ground and are able to take immediate advantage of any stalking opportunities. Culling by gamekeepers/stalkers is therefore efficient.
- Knowing the ground so well, they have a high appreciation of all the safety factors.
- By virtue of their employment as ‘keepers they have been deemed safe and responsible in relation to the use of firearms. If they get it wrong, their jobs are at stake.
Further to the above, whilst the summary of damage issues in the Defra paper is broadly correct, we would like to emphasise the sensitivity of Ancient Semi Natural Woodlands to deer grazing pressure[ii]. Also, whilst the damage to agriculture in general is covered in the paper, there is no mention of game crops planted especially to help game and shoot management. Often these small plots have a palatable food content for the game and they are especially vulnerable to deer damage, which can have a significant effect on economically important shooting sports.
The economic value of stalking (leases and/or daily lettings) should also be considered within this review. National statistics are hard to come by but the value of let stalking is substantial and is an important income stream to the game departments on many estates[iii].
The regional approach to deer management embodied in the Deer Management Groups is excellent in principal but sometimes imperfect in practice. One reason is that different elements within a DMG have differing vested interests (eg those renting the stalking and the estates letting it out). This can sometimes lead to falsifying of statistics and in turn to a cull based on inadequate returns.
Detailed Comments
The following comments relate to the ‘Issues to Consider' section of the Defra consultation document and the numbering used is the same.
(a) We agree that .22 centre fire rounds should be allowed for the smaller deer species, as is now the case in Scotland.
We would support a change to allow the use of any smooth bore gun or rifle for mercy killing of deer. This will make dispatch of deer wounded in road accidents much swifter and often safer too. In Scotland, the legislation permits any humane means of dispatch, which may be a sensible way forward for English legislation.
(b) We support the concept of licensed shooting during the close seasons for the purpose of preserving public health and safety. However, we feel that Section 10 (a) of the Deer Act currently works well in relation to prevention of damage to crops and we would not want to see that changed or affected by this suggestion for licensed control.
Licences for this, or indeed any other purpose, must be available very quickly and without undue paperwork.
Consideration should be given to legalising an ‘act now/apply retrospectively' procedure for cases of particular and immediate need.
(c) We agree with legalising night shooting under licence for the purposes specified but must include strict provisions to prevent exploitation of the new law by poachers. Licences must list specific individuals (eg: landowners and employees only). For safety reasons we believe there could be some justification for limiting night shooting licences to those who know the ground best.
(d) We disagree that the end of the close season for females should be brought forward to 20 October. We suggest it would be better to allow culling of females in March when the cover is lower and it will be much more effective.
(e) We are unconvinced that Chinese Water Deer should have a close season. They are non-native and must be contained. Under existing law they are containable. We believe that with a close season their numbers might get out of hand.
(f) We disagree with the idea of a close season for red/sika hybrid hinds. Again these are non-natives, do the red deer no good, are extremely good at bark-stripping trees and should be removed. Introducing a close season would be counter-productive and runs against the basic premise in the consultation that more deer need to be culled.
(g) For the same reasons we agree with the removal of the close season for sika stags, certainly for hybrids, although landowners with pure herds of sika may prefer to exercise their own close season in the interests of good herd management.
All these issues to do with close seasons would be better dealt with following proper assessment under the ongoing Defra Non-native Species Policy consultation. The Government needs to decide whether it wants eradication, containment or control of each species before decisions can be made about close seasons for non-native deer.
(h) We agree to adding the Chinese Water Deer to schedule 9 to prevent further release.
We strongly support a change to allow the shooting of deer from stationary motor vehicles during daylight hours (or at night under licence as above). This would make stalking much more efficient and the use of rifle rests attached to the vehicle provides an excellent platform for a certain shot. The ability to dive up to deer and shoot would add hugely to the efficiency of the national cull.
(i) We agree that the provision of deer management advice should be maximised. We suggest building on the good start made by the Deer Initiative but feel that the divisive system of the DI having some voting and some non-voting members should be terminated. (If there is to be voting it is ludicrous that the National Gamekeepers' Association is excluded when gamekeepers kill about half the deer culled in the UK). Deer management issues should be decided by a full partnership of all those involved and the Government should pay for its administration.
(j) We agree that the deer management advice should be comprehensive but we do not think it should always come from a single source.
(k) We agree that the DMG's should be developed, concentrating on areas of greatest need, but doing this successfully will require more honesty, more control and clearer authorisation in relation to stalking than is often currently the case.
Furthermore, it is vital for the achievement of an adequate cull that stalking is not restricted only to those who hold a deer management qualification. We have no objection to such qualifications being available on a voluntary basis and indeed they do much to raise standards, but some qualifications are time-consuming to acquire and making them mandatory would therefore meet with strong resistance. There is no sound case for it. Indeed, imposing these qualifications as a mandatory requirement could cut the number of available stalkers by around 50% overnight. In this context we are concerned that some land management bodies (eg Forestry Commission) and certain Chief Constables issuing firearms certificates, are starting to impose such qualifications as a mandatory system by the back door.
(l) We agree that monitoring of TB is essential but the Government should ensure that the free collection service for abnormal carcasses/RTA victims is fully operative and properly funded, otherwise they will simply be disposed of (perhaps unsafely) and the monitoring information with them[iv].
(m) We agree that advice on how to look for TB should be part of stalker-training on food hygiene. It is important that Defra links in with the work being done on this by the FSA, with assistance from the various field sports organisations.
(n) We agree that testing and sampling is an important part of monitoring disease but the Government must expect to pay for it. It will not happen voluntarily.
(o) We disagree that all supplementary feeding should be discouraged. Used carefully, for example the use of salt licks in rotation, it can be a useful means of feeding deer into shootable positions and it can therefore increase stalking efficiency and safety.
(p) We agree that information on Lyme disease should be collated. It is also important that the public is kept informed of what is learned.
(q) We are strongly in favour of voluntary training for stalkers, but not the mandatory approach (see above).
(r) We agree to DMQ standards being brought in to line with European requirements provided they remain voluntary. Indeed, other voluntary deer management qualifications would also be welcome.
(s) We agree that non-lethal methods of deer management should continue to be reviewed but we have little confidence that they will ever contribute much to sustainable deer management in England.
(t) We agree that forestry design and management must aid, not hinder, deer management. In this context we are concerned at the likely impact on road traffic accidents of so much roadside woodland planting. We believe there should be higher grants for planting woods in which deer can easily be managed (wide rides, high seats, fencing, etc), whilst poor plantings should be penalised
Other Comments
The consultation papers make little reference to venison as a product of deer management, beyond recognising that it is good meat and that stalkers and game dealers need to ensure that it reaches the consumer in good order.
One key factor in deer management, however, is the price paid for venison. If venison is scarce, as it was in the immediate aftermath of foot and mouth, when no stalking could take place, the price rises and this is an additional incentive for estates and individual stalkers to get the necessary culling done. Conversely, if the price falls - as it currently has due to imports of venison culled overseas, some people hold back from culling waiting for the price to rise. This it may or may not do, but in the meantime another breeding season has passed and numbers have risen still further. If deer populations race away, the venison price could fall dramatically even from today's low level, leaving even less incentive for the required culling to take place.
The solution is to ensure a stronger consumer market for the meat. Initiatives such as Game-to Eat, originally part-funded by Defra, need to be given every encouragement.
Finally, we believe it may be appropriate within this consultation to re-open the debate about using shotguns with heavy loads for the control of small deer species in confined areas such as gardens. Deer are becoming more and more difficult to manage safely in such places and the well-regulated use of shotguns may be a solution. It should certainly be considered.
The National Gamekeepers' Organisation can be a key player in the future sustainable management of deer populations in England. We would be happy to meet with Defra or to help in any other way to make this important consultation a success.
April 2004
[i] "Professionals shot 8 times more deer than recreational stalkers but due to their numerical superiority the non professionals still accounted for 47% of the total cull". McCormick and Cordery ‘Standards in Deer Management' in English Nature report 548, Proceedings of the Future for Deer Conference , March 2003, page 62).
[ii] Woodland SSSI conservation is one of a number of Government PSA Target habitats.
[iii] Griffith estimates the total maximum sustainable direct revenue from stalking at £5.93 per hectare per annum (‘Economics of Deer Management' in English Nature report 548, Proceedings of the Future for Deer Conference , March 2003, page 71).
[iv] Our members have been told by some District Veterinary Officers that they have no proper facilities for the disposal of diseased carcasses.