Response by The Mammal Society to the joint DEFRA and Forestry Commission consultation.
The Mammal Society welcomes this review of the problems concerning the management of deer in England, but notes that this is a Great Britain-wide problem, and the management of deer needs to be properly coordinated and executed within a UK-wide policy.
The Mammal Society supports the specific recommendations made in the consultative documents:
- to extend the use of smaller calibre (0.22) centre-fire rifles for the control of smaller deer;
- to approve the use of smooth-bore guns and all rifles (not air-rifles) in the specific circumstances of “mercy killing” injured or distressed deer;
- to extend the close season provisions for other deer to Chinese Water Deer does;
- to remove the close season from Sika stags, in the interests of limiting their further spread and hybridisation with Red Deer;
- to extend the current provisions so deer may be killed outwith the current open seasons for public safety (e.g. incursion on motorways and airfields);
- to extend the current provisions so that killing at night might also be licensed, but only for reasons of public safety.
It is not clear that licensing the culling of deer which present a public hazard is appropriate, if this occasions delays when instant action might be required. Perhaps the local Police Wildlife Liaison Officer should be empowered to give quick approval in cases where the public is at risk, and where deer require “mercy killing”.
However, these are minor legislative issues, and the wider problem of managing the deer populations in the countryside requires much broader action.
Deer Management Groups
The consultation document leans strongly on the notion of voluntary Deer Management Groups (DMGs). These can work well when all concerned have agreed objectives and are generally sympathetic to them. They work best where a few larger landowners own land on which a discrete deer population occurs, and where those landowners can readily agree a management plan. They fail miserably in areas with many small landowners who have disparate objectives, and they seem totally unsuited to dealing with the problems of suburban deer. They seem unlikely to be able to manage Muntjac, in particular, because of its ability to live in small patches of suburban habitat. Because wild mammals belong to no-one while alive, though to the landowner on whose land they are killed, it is difficult to see how else deer populations could be efficiently managed than by DMGs, unless and until the law is changed.
A Deer Commission for England
The Deer Commission for Scotland does seem to be a model that might be emulated in England, in that it has responsibility for collating and collecting data on deer numbers and deer culling, has powers to set culling levels, employ stalkers and counters, and to advise landowners. At present, responsibility for deer management seems to fall between Forest Enterprise for woodland deer, DEFRA for farmland deer, English Nature specifically on NNRs and SSSIs, and no-one for the wider countryside.
The Mammal Society would urge the establishment of a Deer Commission for England, within an appropriate legal framework.
Training for Deer Stalkers
The recommendations for better training of stalkers, not only for their shooting skills and legal knowledge, but also for their awareness of diseases and parasites, seems wise, but it is not clear who will provide this training, nor how it will be approved. Qualifications in Deer Management Ltd are aligning the Deer Stalking Certificate syllabus and exams with NVQ; formal integration in the Agricultural/Technical College framework for accreditation would seem appropriate. The culled deer should be regarded as a valuable source of venison, free-range meat that ought to be highly valued. Its marketing should be improved, and game dealers should be encouraged, as is already the case, to provide the required facilities for handling it. Meat inspection, as at present, would remain the responsibility of the food inspectorate.
With regard to Road Traffic Accidents
The management of deer in respect of Road Traffic Accidents has been woefully inadequate, not least because of the failure to gather appropriate statistics. Even the data offered in COST 341 and at the recent Highways Agency/Mammal Society symposium were extrapolations from very small samples. A first step must be better collation of data by police, highways managers, insurance companies and others. The Deer Initiative has begun this, and its support must be continued. The specific problem of managing highway/deer interactions, ranging from highway design through habitat to deer management, has been thoroughly discussed in those fora. Legislation to assist this data collection, to cover wild as well as domestic animals in the requirement to record causes of accidents, might be needed. Provision for deer to cross over or under new roads should be a design standard. Dealing retrospectively with all current highways is clearly impracticable, logistically and financially, but better collation of statistics should help with deciding priorities in this regard.
The Mammal Society notes the stricture that wild deer, in the absence of natural predators in Britain, have to be culled by humans. This is a strong argument that reintroduction of Lynx, native here until Roman times, and known to feed preferentially on smaller deer, should be considered for at least part of the deer range to establish whether natural predation could assist in deer management.