Call for views – Wildlife Management and Muirburn (Scotland) Bill
Scotland’s Rural Affairs and Islands Committee has issued a ‘call for views’ on the Wildlife Management and Muirburn (Scotland) Bill.
- - Features
- - Features
Why the Scottish Natural Environment Bill must be fixed
The Natural Environment (Scotland) Bill, published last week, proposes substantial changes to deer management. However, as Peter Clark, BASC Scotland director, highlights, the Bill proposes increased regulatory intervention with little detail on financial incentives for deer managers.
From the outset, BASC is urging the Scottish Government to engage with deer managers and stalkers to ensure that new legislation introduced as a result of the Natural Environment (Scotland) Bill is both effective and practical for the thousands of BASC members affected.
What's in the Bill?
The Bill covers key issues such as:
- Deer management
- National parks
- Legally binding nature restoration targets
- Changes to environmental impact assessments and habitat regulations
Among these proposals, BASC has serious concerns regarding the lack of clarity around regulatory interventions – particularly concerning new powers granted to NatureScot over deer management control.
Previously, BASC raised alarms over Deer Management Nature Restoration Orders (DMNROs), which would have subjected deer managers to strict state intervention. While these have been dropped, it appears that similar powers have resurfaced as amendments to sections 7 and 8 of the Deer (Scotland) Act 1996.
BASC remains deeply concerned that these powers have been repackaged rather than removed. Proposed changes could allow state intervention if deer are perceived as a barrier to nature restoration.
The need for transparency on financial incentives
The Scottish Government must be transparent about when and why intervention would take place. ‘Nature restoration’ must be clearly defined and consulted upon with BASC members. Any government intervention in private deer management must be based on clear, objective, and measurable criteria.
Additionally, there is a major gap in the Bill – the government has not outlined how it will differentiate between damage caused by deer versus other herbivores across Scotland’s landscapes. Without this clarity, regulatory actions risk being arbitrary and unfair.
Unjustified mandatory training
Beyond additional regulation, the Bill proposes introducing mandatory training for all deer stalkers in Scotland.
BASC is the only Scottish organisation actively opposing this requirement, as there is no evidence to justify it. No welfare concerns have been identified in legitimate deer management. Such a drastic measure requires clear justification, yet none has been provided.
The Bill also proposes a new register of authorised deer stalkers (under section 17A of the Act) and that providing information on cull returns will be a requirement of their ability to retain their registration. However, the baseline competence standard has not been specified, raising further concerns about vague regulation.
For those involved in night shooting, additional competence requirements will apply, with evidence needed via a specific qualification or certificate.
BASC supports high standards in deer management and training, but we firmly believe that self-regulation is effective. Mandatory testing would increase bureaucracy, deter newcomers, and reduce the number of active deer stalkers.
Projections indicate that the proposed measures could halve the number of active deer stalkers in Scotland, reducing them to fewer than 7,500. Over time, this will further shrink the workforce needed to meet increased cull targets – a deeply concerning prospect.
Adding to this, there is no mention of grandfather rights for existing stalkers, which would unfairly impact long-standing professionals in the sector.
Within the Bill there is no mention of lowland deer or community-integrated deer management either, which are both two significant opportunities missed, and both which BASC has raised with the Rural Affairs and Islands Committee.
Standing up for BASC members
While this is a weighty piece of legislation, we have already commenced the process of engaging with MSPs and policymakers to shape the outcome of this legislation so that it benefits our members’ interests.Â
Agriculture Minister, Jim Fairlie, will be attending our Gamekeeping and Wildlife Management Day in March. This event will provide a crucial opportunity for him to hear directly from those managing Scotland’s deer populations and understand the real issues at stake.Â
From substantial written evidence provided to the Rural Affairs and Islands Committee, to a meeting with the First Minister’s Rural Special Adviser, we have hit the ground running on demonstrating why this Bill cannot pass in its current form.
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Peter Clark
Peter is the public affairs manager for Scotland. Prior to joining BASC, he was the rural policy advisor to the Scottish Shadow Cabinet Secretary for Rural Affairs in Holyrood. Originally from Aberdeenshire, he has a keen interest in clay and game shooting. He is currently working towards his DSC1 certificate, with a view to managing lowland deer numbers on the family farm.
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