We have submitted our response to the Defra consultation on the deer management strategy. We've summarised the response and the key consultation proposals below.
Deer play an important and valued role in the British Countryside, but there are growing concerns about the multitude of negative impacts that the increasing deer population is having, not just on trees but on the wider environment and agriculture.
It is therefore vital that there are sufficient measures and incentives in place to manage deer populations appropriately to ensure they remain healthy and in balance with the environment and a wide range of land uses.
We are disappointed to see a lack of detail throughout the consultation document and a short timeframe to respond.
Changes to deer management legislation and licensing are referenced throughout the consultation and must be consulted on further with the agricultural industry.
The NFU is concerned about the impact these regulatory changes could have and if they will come with added bureaucracy and cost.
Key consultation proposals
We support the proposed introduction of new incentives to help reduce the impact of deer on woodlands.
However, prioritising woodlands and trees in the strategy could have a negative impact on agriculture and food production. The deer management strategy must take a holistic approach addressing all impacts of deer.
Licensing and legislation review
The consultation proposes amendments and reviews of existing licenses and legislation.
The government is proposing to review licenses to allow the shooting of male deer during the existing closed season, and to permit the shooting of deer at night. We would welcome changes that reduce bureaucracy in the licensing process and enable appropriate, safe, and effective control.
We are concerned about the potential impacts the removal of the licensing process could have on management but also with regards to human and animal welfare, especially if licenses were removed all together. We are worried that this change could enable an increase in deer poaching, the management of which would present its own challenges.
We welcome the enabling of landowners/land managers to help them proactively and effectively manage deer.
Recognising that the wider impacts deer have is vital and must be reflected in the strategy. We are seeking clarity on what legalisation would be reviewed to enable landowners and managers to reduce deer damage.
We agree in principle with the proposal to enable occupiers (tenants or owners) of land to control deer, where the deer rights are retained by the landlord or previous owner. However full NFU support for this proposal would be subject to seeing more detail and clarity about what exactly the government is proposing.
We have concerns about the potential tenant/owner/deer right conflicts this proposal could cause and therefore ask the government to carefully consider and consult on the approach it takes.
In general, we support the proposed clarity on the legal status of wild deer as the current legal status and legislative regime on deer (and other wildlife species) is complex and spread over multiple pieces of legislation.
We would welcome any changes that aim to reduce the spread of diseases amongst wildlife, such as bovine Tuberculosis (bTB). Clarity is needed to understand what the change in legal status would be
We would support a change that could result in the landowner being responsible for the impact that deer residing on their land especially on neighbouring land or tenants of the landowner concerned.
However, before such change is made, the government should carefully consider the issues surrounding this proposal and must consult the agricultural industry when developing this approach further.
Deer health, welfare and safety
We are concerned that the impact of a statutory minimum standard for all who cull deer in England would add cost and bureaucracy.
There are already existing firearm requirements and deer stalking certificates that promote high standards in the humane and safe culling of wild deer.
The government should explore if a voluntary standard, which recognises grandfather rights, would be a more effective approach.
Wild Venison Market
We agree that there are presently barriers to the development of a commercially successful wild venison market and would like to see Government support a British venison market that includes and recognises the differences in wild, farmed and parkland venison.
NFU members can download our full consultation response to the deer management strategy here: NFU response – Deer management strategy