BDS Response to the Defra Consultation on Proposed Deer Management Strategy

BDS Response to the Defra Consultation on Proposed Deer Management Strategy

The British Deer Society (BDS) has reviewed in detail the consultation on proposed deer management published by Defra on the 4^th of August 2022. Whilst we welcome the consultation in general terms, and in particular the intent to develop a wider market for venison, we have serious concerns about some of the proposals.

We must also note that we have not, to date, been approached as part of Defra’s planning process.

We have the following concerns:

• Deer species. The UK’s six deer species have widely differing ecologies and impacts. While there is some reference to this in the consultation, on the whole deer are considered under a simplistic blanket heading. It is vital that the deer strategy shows a greater recognition of the varying approaches required to the management of these different species.
  
  
• Suggestions that the legal protection currently afforded to the males of all deer species may be removed.
  • Among the smaller deer, roe and water deer populations are already generally held in balance by existing culling practices, while muntjac have no close seasons for either sex so may be shot at any time of year. There is currently no evidence to support changes to the current legal protections for these species.
  • Male deer of the larger species can already be shot during nine months of the year, a fact that already distracts attention from controlling females. As it is the females that produce more deer, controlling their numbers in vitally important. During the short winter season allowed for shooting females, male deer frequently offer better culling opportunities and we believe that permitting them to be culled at such times already adversely affects the female cull. To remove the male deer close season entirely will be counter-productive and the BDS strongly feels that, if anything, it should be extended.
  • In many localities the populations of large male deer are already seriously imbalanced because of excessive shooting focus; this move can only exacerbate the situation.
    
    
• Enabling an increase in night shooting. Increased levels of night shooting, if not conducted by appropriately experienced individuals, can carry serious safety and deer welfare issues. We anticipate such a move will also enable more widespread poaching activity. Furthermore, the implication that it would facilitate the culling of some species such as muntjac is misleading given the practicalities involved. As such we cannot support such measures and we are surprised and concerned that this has been suggested.
  
  
• Non-native species. While the impacts of muntjac deer are fully recognised, there is no recognition of the fact that water deer are geographically restricted in relatively low numbers. Water deer are already well controlled and have minimal ecological and financial impacts. Furthermore, as a species classified as Vulnerable by the International Union for Conservation of Nature, the UK population has a wider international significance and any move towards a policy of eradication is deeply concerning.
  
  
• Mandatory minimum standards for culling deer. Landowners already have an implicit duty of care and existing law demands that current deer management practice is humane, efficient, and appropriately conducted. Furthermore, any venison passing into the food chain is already subject to stringent game meat handling regulations. The imposition of further national standards may be inappropriate and could have an adverse effect on those practitioners who already conduct culling.
  
  
• National Deer Dashboard. The BDS welcomes the possibility of a National Deer Dashboard to collate a wider picture of deer populations and their impacts but is anxious to ensure that it is effective, simple to engage with, comes at no cost to practitioners, and does not involve unnecessary levels of bureaucracy which might distract from practical efforts.

  The BDS has extensive experience in surveys and data collection related to deer and understands both the complexities and difficulties involved. More information is needed to fully assess this as a proposal.

• Consultation. 75% of the UK annual deer cull is conducted within the private sector and we are alarmed that, prior to this consultation, the latter appears not to have been involved in any planning or decision making. The publication of this consultation during a significant holiday period is of concern; the BDS fears that the period allowed for responses is so short, and that it may result in inadequate levels of consideration and response.

The BDS remains ready to engage with Defra to provide advice and guidance throughout the coming months to ensure a considered and intelligent national approach to deer management.