Cunningham Roseanna
Scotland’s Environment Minister Roseanna Cunningham

Strict new rules should be introduced to curb the damage done by deer to the natural environment, according to a major report submitted to the Scottish Government.

The report by a team of experts, commissioned to look at deer management in Scotland, heavily criticises the government wildlife agency, Scottish Natural Heritage (SNH), for failing for years to do enough to reduce deer numbers.

It says a “planned cull approval system” should be developed with legislation to enforce it, instead of the voluntary approach preferred by SNH. This is likely to mean SNH routinely setting targets for the number of deer estates must shoot.

An upper limit of 10 red deer per square kilometre in their main highland range is recommended, which would likely require a significant reduction of the deer population in some areas. Conservation groups see setting this target as a significant step forward – and further reductions are possible as climate policy develops.

The report was welcomed for its “courage and clarity” by environmentalists, who warned that deer were “the biggest threat to Scotland’s existing native woodland”. They have long argued compulsory cull levels were required to stop deer from eating saplings and damaging carbon-rich peatland.

But a group representing landowners warned that the report’s recommendations would have a “devastating effect” on the sport shooting industry. The Scottish Gamekeepers’ Association described the report as a “hammer blow” and said it would seek urgent talks with the Scottish Government on the issue.

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The Ferret reported on 13 January that a powerful coalition of environmental groups had made a plea for tougher regulation of red deer. We also produced a podcast documentary on the debate over deer management.

The new 374-page report by the Deer Working Group, set up in 2017, has censured much of SNH’s work on deer management, with 52 of 99 recommendations for change mentioning the agency. The group was chaired by the respected conservationist, Simon Pepper, before he died in September 2018.

The report concluded that the amount of damage done by deer was unacceptable. “While the apparent levels of damage by wild deer in Scotland might not be described as out of control, the levels cannot be described as under control,” it said.

It accepted that limited funds had hampered SNH’s work, but it urged the agency to make far more use of its existing powers over deer management. SNH should be ready and willing to convert voluntary deer control agreements under section seven of the existing law into compulsory ones under section eight, it said.

“The scope for persuasion as part of an effective system of regulation relies on a credible expectation that SNH will use its powers to prevent damage or further damage when necessary,” the report added.

“The group is not convinced that SNH passes that test, despite Scottish Government instructions to SNH to ensure that it uses ‘the full range of enforcement powers at its disposal’ where necessary.”

The working group disclosed that some within SNH were concerned that the agency put so much emphasis on collaboration with landowners that “the use of regulatory powers would seem like a betrayal”.  It concluded that “SNH needs to re-balance the focus its work”.

SNH’s emphasis on working through formal structures such as deer management groups should be scrapped in favour of a more flexible approach, the report said.

Rules around hunting with night sights should be relaxed, the close season for male deer should be abandoned, and the open season for hinds should be extended until April, it urged. This may concern animal welfare groups as hinds could be heavily pregnant in early spring.

Welfare experts will, however, be pleased that the report says “levels of annual winter mortality amongst red deer on open hill range in the highlands are unacceptable and need to be reduced.”

As well as Pepper the working group included Andrew Barbour, a former deer commissioner for Scotland, Dr Jayne Glass, a land use policy researcher at Scotland’s Rural College, and Robin Callander, a land manager and government policy adviser.

The debate around deer management focuses largely on red deer, Scotland’s largest species, whose home range is mainly across the highlands.

But growing numbers of roe deer, which inhabit woodlands and are common in the central belt, are also a major problem. The report said SNH should “allocate a significantly greater share of its resources to the management of deer outwith the open-hill red deer range.”

Scottish Environment Link – a coalition of Scottish environmental and wildlife organisations including the Royal Society for the Protection of Birds (RSPB), the Woodland Trust and the John Muir Trust – welcomed the report. It would go “a long way to improving the ecology of Scotland’s uplands by changing the culture of deer management,” the group said.

The Woodland Trust described deer as the “the biggest threat to Scotland’s existing native woodland” and demanded tough action. “If we are to fight back against the climate crisis we must free our forests from the unsustainable pressure they are under from deer,” said Scotland director, Carol Evans . The Trust has a presence in and around Dumbarton, Vale of Leven and Helensburgh.

“It is clear voluntary approaches are still not maintaining deer at sustainable levels. We must create a management system, for the public good, which has healthy countryside at its heart. For the sake of the next generation and our ability to combat climate change, we must do it quickly.”

Mike Daniels, head of land management at the John Muir Trust said: “We welcome the courage and clarity of the report which confirms that Scotland’s existing deer management procedures and practices need major reform.

“If we were designing a new system of deer management today in the context of climate change, biodiversity loss and the depopulation of fragile rural areas it would bear little resemblance to the traditional sporting estate model found in large parts of the highlands.”

Duncan Orr-Ewing, the senior RSPB Scotland expert who chairs Link’s deer task force, argued that deer management laws needed to be urgently transformed. “We note and support proposals to update deer legislation to ensure modern and transparent systems of deer management, and proposed improvements to SNH powers to enable changes in practice on the ground.”


But the Association of Deer Management Groups (ADMG), which brings together landowners, was alarmed by the Deer Working Group’s recommendations. “Fundamentally this report is about further heavy reductions in deer numbers which would have a devastating effect on an important rural industry in the remoter parts of Scotland,” said the association’s chair, Richard Cooke.

“There is a real danger if we continue to demonise deer that we overlook the multiple other impacts on our environment.”

Cooke said sheep still outnumbered deer by two to one in northern Scotland. He questioned the need for a “drastic cull” of deer, claiming numbers were already down to an average of 9.3 per square kilometre.

“The report also recommends a much higher level of government intervention which will come at considerable public cost – and a great deal more engagement from SNH than there is at present,” he added.

“Our view is that across the upland deer range the collaborative deer management group system under the voluntary principle is proven and working increasingly well. Whilst there is always room for improvement the deer management group system is rising to the challenge and delivering against ambitious climate change targets.”

The Scottish Gamekeepers’ Association also condemned the report, warning ministers they could lose the “goodwill” of the sporting industry. “Our members have killed close to a million deer in Scotland in the last 10 years,” said the association’s chairman, Alex Hogg.

“This sector is getting tired of being kicked from pillar to post and this report, which basically signals a free-for-all on an iconic Scottish species, is a further hammer blow. We will be gauging the temperature within our membership over the coming days and seeking urgent talks with government.”

The Scottish Government’s Environment Secretary, Roseanna Cunningham, promised to give “careful consideration” to the report’s recommendations. “We will consider this report, alongside other evidence, and respond in due course. An important part of this will involve meeting and engaging with key stakeholders to discuss the findings of the review,” she said.

A SNH spokesperson said: “We are currently considering the recommendations in the Deer Working Group’s report. We appreciate all the hard work behind this significant report, and look forward to working with the Scottish Government and other stakeholders to improve the way deer are managed in Scotland.”

This story was repeatedly updated on 29 January 2019 to include new comments.

Cover photo thanks to iStock/Danielle Kerwick, and photo of large deer herd thanks to iStock/Paul Carpenter.


  • Richard Baynes

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