NGO Responds to Defra's Deer Impacts Policy Statement

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Following Defra’s publication of the Deer Impacts Policy Statement: Managing the Impacts of Wild Deer in England published on 20 February, the National Gamekeepers' Organisation calls for practical deer management, not expanded regulation.

The National Gamekeepers’ Organisation (NGO) recognises the importance of addressing deer impacts in England and welcomes the fact that the Government, through the Department for Environment, Food & Rural Affairs (Defra), has placed the issue firmly on the national agenda. We agree that in some areas, deer densities are exceeding environmental capacity and that targeted, professional management is essential to protect woodland creation, biodiversity recovery and agricultural interests. The NGO also supports improved data collection, landscape-scale collaboration and strong public sector leadership on publicly owned land.

However, there are fundamental differences between Defra’s proposed direction and the practical, outcome-led solutions set out in the NGO’s Deer Management Strategy 2024. While Defra focuses heavily on regulatory reform and expanded powers, our strategy is built on delivery, incentives and strengthening the proven capacity of the private sector - which already undertakes most of the deer management across England.

The NGO has serious concerns regarding Defra’s proposals under sections 1.4 and 1.5, which seek to enable tenants, owners or occupiers to gain legal rights to shoot deer under certain circumstances, and to ensure that where inaction is deemed to be causing negative impacts, those responsible carry out management. While accountability is important, these measures risk creating conflict over private sporting and land management rights that have long been clearly defined and contractually agreed.

Granting additional shooting rights beyond existing agreements has the potential to override established property rights, disrupt lease arrangements and undermine employer–employee responsibilities on rural estates. It risks transferring practical control of deer management from private landholders into a framework of public intervention. Such an approach may create operational confusion, increase safety risks to staff and contractors working on the land, and damage animals and habitats through poorly coordinated or duplicated activity.

The NGO firmly believes that conflict-driven enforcement mechanisms are less effective than cooperative, incentive-led solutions. The private sector already demonstrates that where deer management is embedded within estate plans and linked to clear objectives, impacts are reduced without the need to alter land rights or impose external authority.

We also remain opposed to any expansion or normalisation of out-of-season licensing. Section 7 of the Deer Act 1991 already provides appropriate safeguards, allowing action during the close season where it is “necessary for the purpose of preventing serious damage to property, or for the purpose of preserving public health or public safety.” The current legislation is workable and proportionate. Expanding regulatory tools risks eroding long-standing principles of welfare and responsible management without addressing root causes.

By contrast, the NGO's strategy (NGO Deer Strategy for England 2024) strengthens what already works. We propose outcome-based incentives paid per carcass, targeted by species, sex and geography, ensuring measurable reductions where impacts are highest. We call for meaningful reform of the venison market to remove bottlenecks and make increased culling economically viable. We advocate supporting Forestry England with additional capacity while also replicating successful private-sector delivery models.

The private sector consistently culls more deer per hectare than the public estate and does so at no cost to the taxpayer. Expanding public enforcement powers without first scaling proven private-sector solutions risks increasing expenditure while generating unnecessary tension across the countryside.

We share the Government’s objective of reducing unacceptable deer impacts. Where we differ is in the method. A strategy built on partnership, incentives and respect for established land rights will deliver sustainable results. A strategy built on regulatory expansion risks conflict, uncertainty and diminished cooperation at precisely the moment when unity is required.