Managing Deer for Nature and Climate Change consultation response

Cairngorms Nation­al Park Author­ity 14 The Square Grant­own on Spey PH26 3HG

T: 01479 873 535

27 March 2024

Wild­life Legis­la­tion Team The Scot­tish Gov­ern­ment Area 3H‑S Vic­tor­ia Quay Edin­burgh EH6 6QQ

RE: Cairngorms Nation­al Park Author­ity response to Man­aging Deer for Nature and Cli­mate Change consultation

Man­aging Deer for Nature and Cli­mate is fun­da­ment­al to deliv­ery of Nation­al Park Part­ner­ship Plan object­ives for wood­land expan­sion, peat­land res­tor­a­tion, redu­cing deer and herb­i­vore impacts, and improv­ing eco­sys­tem resi­li­ence and functionality.

Deer are an import­ant spe­cies in the Nation­al Park, provid­ing income, employ­ment, and enjoy­ment. How­ever, we need to reduce the impact of deer and oth­er herb­i­vores in key areas of the Nation­al Park to meet our cli­mate and nature com­mit­ments. This includes the man­age­ment of red deer in the open range and with­in expand­ing wood­lands, the man­age­ment of roe deer in agri­cul­tur­al land and wood­land and the abil­ity to con­trol non-nat­ive sika and fal­low deer.

Enhan­cing the nat­ur­al environment

The Park Author­ity sup­ports the prin­ciple of Deer Man­age­ment Nature Res­tor­a­tion Orders (DMNROs) that would provide NatureScot with a power to require nature enhance­ment in addi­tion to their exist­ing powers to pre­vent dam­age. This additionality

is cru­cial to tack­ling the twin nature and cli­mate crisis and rec­ti­fies some of the inad­equa­cies of the cur­rent reg­u­lat­ory approach.

The Park Author­ity would wish to be a stat­utory con­sul­tee on the intro­duc­tion of any DMNRO with­in the Nation­al Park and would expect DMNROs in the Nation­al Park to be dir­ectly linked to the deliv­ery of Nation­al Park Part­ner­ship Plan object­ives and targets.

The Park Author­ity con­siders there needs to be more inform­a­tion and fur­ther detail regard­ing where DMNROs would be applied, what the cri­ter­ia would be for select­ing areas, how DMNROs would be applied in areas with a sig­ni­fic­ant mix of herb­i­vores e.g. sheep, sika and roe deer, and how DMNROs tie in with exist­ing stat­utory meas­ures for deer man­age­ment and oth­er powers such as Land Man­age­ment Orders.

We would also like to see more emphas­is on the effect­ive man­age­ment of roe deer pop­u­la­tions, which can be a sig­ni­fic­ant con­straint on wood­land expan­sion and enhancement.

The Park Author­ity feels the devel­op­ment of DMNROs should be linked with the devel­op­ment of long-term deer man­age­ment incent­ives. This is to ensure that where a reduc­tion in deer num­bers res­ults in a reduc­tion in sport­ing income, there is sup­port for main­tain­ing deer man­age­ment to deliv­er pub­lic policy out­comes for wood­land expan­sion, peat­land res­tor­a­tion and biod­iversity recovery.

Changes to close seasons

The Park Author­ity sup­ports the date for the close sea­son for hinds being moved from 16 Feb­ru­ary to the 31 March but does not sup­port the move­ment of the date from the 20 Octo­ber to the 30 September.

In con­sid­er­ing a change to the close sea­son for female deer, the Park Author­ity recog­nises the bal­ance of being able to reduce deer dam­age with the need to pro­tect depend­ent deer calves. Any change still leaves the decision of when to shoot at the dis­cre­tion of the landown­er. Extend­ing the open sea­son for all spe­cies of female deer up to end March will enable those who wish to shoot females, to do so without increased wel­fare con­cerns. It will not com­pel those who do not wish to cull female deer with well- developed foetuses to do so.

The Park Author­ity con­siders that shoot­ing female deer with depend­ent calves in Octo­ber can cre­ate deer wel­fare prob­lems. A calf orphaned in Octo­ber will almost

cer­tainly die from expos­ure, inad­equate nutri­tion and / or lack of know­ledge on how to cope with severe weath­er events. Cull­ing large num­bers of female deer on the open hill or in wood­land will almost cer­tainly orphan calves, as it’s not always obvi­ous which hind is the moth­er of which calf, and calves are not always vis­ible with their moth­ers in thick wood­land vegetation.

The Park Author­ity also con­siders that many deer pop­u­la­tions through­out the Cairngorms and Scot­land have been reduced with­in the cur­rent close sea­son dates, sug­gest­ing that the cur­rent close sea­son is not a major con­straint on achiev­ing targets.

As such we there­fore feel there are reas­on­able argu­ments based on wel­fare and effic­acy for retain­ing the date for the end of the cur­rent close sea­son for all female deer as the 20 Octo­ber and not redu­cing the close sea­son near­er to the date of birth than current.

Ven­ison

The Park Author­ity would like to see fur­ther work car­ried out in Scot­land to pro­mote and expand the use of ven­ison, espe­cially with the pro­posed increase in cull­ing, to max­im­ise oppor­tun­it­ies for brand­ing and mar­ket­ing of the product in Scotland.

Abol­ish­ing the Ven­ison Deal­ers Licences (VDL) and treat­ing deer sim­il­arly to oth­er game could have pos­it­ive out­comes. Cur­rently the emphas­is is placed on those who buy ven­ison to hold a VDL, switch­ing that emphas­is onto deer man­agers who sell ven­ison could res­ult in more com­pre­hens­ive cull report­ing. Over­all, there is a need to ensure the sys­tem provides good levels of trace­ab­il­ity and safe­guards the ven­ison sector.

Yours sin­cerely

Grant Moir Chief Exec­ut­ive Officer