BASC’s response to Defra’s call for evidence

BASC have responded to Defra’s call for evidence on the scale and impacts of the import and export of hunting trophies.

The British Association for Shooting and Conservation (BASC) is the largest shooting organisation in the UK, serving a growing membership of around 155,000. It acts as a representative body for responsible and sustainable shooting – encouraging opportunity, high standards and wildlife conservation.

BASC is concerned that Option 3 (A ban on all hunting trophies entering or leaving the UK) would have a major impact on the economics of deer management in the UK and thus the overall sustainable management of the UK deer population.

BASC supports the sustainable harvest of wildlife in the UK and overseas and the import and export of trophies arising from such harvesting where they are clearly proven to be from a sustainable source; noting that well-regulated trophy hunting programmes play an important role in delivering benefits for both nature and people.

BASC believes that the current system regulated by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and which follows rules established by the International Union for Conservation of Nature (IUCN) provides enough protection to threatened species across the world.

The IUCN[1], amongst others, have provided ample scientific evidence[2] of the value of trophy hunting to the conservation of threatened species and ecosystems across the world and it is not the aim of this paper to repeat this, but to explore trophy hunting in the context of UK deer management. However, some of the principles apply no matter what country you are in:

  • If wildlife has a value, then it will be conserved.
  • If the local community has no vested interest in wildlife, then they will not look after it and in the worst cases they will destroy it, particularly if it is a threat to their livelihoods.
  • Much hunting tourism takes place in very rural locations which makes the areas unsuitable for other forms of tourism / development.
  • Many populations of animals have to be culled to maintain them at an ecologically sustainable level.
  • Hunting trophies are the non-edible byproduct of this annual cull.
  • Most hunting trophies are usually from old males who will already have passed their genes on into the population.

There are six species of deer which are found in the wild in the UK. Only two are native – red and roe. Fallow were introduced in the 11th century and are considered naturalised whereas sika, muntjac and Chinese water deer (CWD) are all classed as non-native species[3]. The distribution of each species has been mapped by the British Deer Society every five years and each species is showing an increase in range across the UK[4].

The UK deer population is reported to be more abundant and widespread than at any time in the past 1,000 years, with a current estimate of more than two million deer.

Shooting using high powered rifles is the primary means of deer control in the UK, with an estimated 350,000 deer being culled in the UK annually[5].

Deer have evolved as a prey species whose population is either kept in check by predators or through disease and starvation. As we no longer have any natural predators of deer in the UK if their population was left unchecked then they would eventually get to a density where high mortalities were caused by disease and/or starvation.

If left unmanaged and conditions are favourable, then there is the potential for the UK deer population to grow by approximately 15 – 30% annually[6].

There is therefore a moral responsibility to undertake an annual cull of deer so that their population is maintained at around the sustainable carrying capacity for that area. Before disease/starvation affects a deer population it will achieve a density that is causing significant damage to its environment. This can result in major impacts on agricultural and forestry crops, but also on natural ecosystems.

The impacts of deer vary depending on the species involved and their local densities. Invariably the impacts tend to be greater for the larger species (red, fallow & sika) that also tend to have a herding behavior, with some groups numbering several hundred animals. Consequently, impacts can be very localised and it is difficult to obtain accurate estimates of damage on a national scale.

Deer can have an economic impact on farms through the browsing, grazing and trampling of crops, and damage to fencing. However, damage to agriculture tends to be significant only in localised areas. In 2003, Defra estimated the cost of deer to agriculture in England as ~£4.3 million, with the greatest damage inflicted on cereal crops in East and SW England[7]

Deer can cause significant damage to forestry by reducing tree regeneration, browsing saplings, and bark stripping. Economic losses in forestry due to deer are hard to quantify, but their management costs are more readily assessed. Forest and Land Scotland alone pay contractors £10 million per year to cull over 35,000 deer on their properties. The economic cost of deer to forestry is likely to remain high or to rise in future due to a range of factors including:

  • increased tree planting and expansion of broad-leaved woodland to offset carbon emissions.
  • increasing desire to avoid deer fencing or plastic tubes as the prime deer protection method.
  • increasing use of lower impact silvicultural systems as a potential climate change adaptation measure with a greater reliance on natural regeneration.

Red and roe deer are natural components of the British landscape, and fallow are a long-standing naturalised species. However, many habitats prized for their conservation value today developed over the past thousand years in the presence of lower numbers of deer. The Joint Nature Conservation Committee (JNCC), Natural England (NE), and Scottish Natural Heritage (SNH) all regard excessive deer densities as a serious threat to a significant portion of National Nature Reserves (NNRs) and Sites of Special Scientific Interest (SSSIs).

Indeed, the BASC and NE have a partnership agreement that recognises that browsing by deer can have a negative impact on the condition and biodiversity of many woodland habitats. Furthermore, BASC and NE have agreed to investigate ways in which recreational stalking schemes might contribute to delivery of a sustainable and well-managed wild deer population in England.

Lowland ancient woodland, upland heath and blanket bog can suffer particularly from deer over-grazing, excessive browsing and trampling. These include priority habitats, which the government is committed to protect under the Convention on Biological Diversity. Impacts of over-grazing and browsing in ancient woodland[8] can include:

  • decline and loss of characteristic plant species including oxlip and bluebell;
  • declines in characteristic woodland bird species such as nightingales due to the loss of plant structural diversity and food supply;
  • declines in invertebrate abundance and diversity;
  • prevention of adequate levels of tree regeneration and traditional coppicing management

Whilst wild deer in the UK, are considered relatively disease free, increased movement does increase the potential for the spread of disease which can be found in deer (e.g. bovine tb, foot & mouth, ticks), to be passed on to livestock[9]. Increased movement can also result in deer crossing busy roads increasing the risk of road traffic accidents (RTAs), which can be detrimental to both deer and humans. Annually there are up to 74,000 deer/vehicle collisions resulting in 10-20 human fatalities and 700 human injuries[10].

The management of deer in the UK is the responsibility of the landowner. Private landowners invariably look to offset the costs that this involves against any income that can be derived from selling the sporting rights to the deer stalking and/or selling the venison. A deer ‘herd’ can be managed to increase the value of the sporting rights by ensuring that the males grow antlers of a quality that will make them desirable as trophies. This is largely achieved by keeping the population below the ecological carrying capacity of the ground so that they have sufficient natural food and are generally healthy.

Thus, the sale of trophy hunting for UK deer species is an important aspect of the economic management of our national deer herd. Much of this income is derived from overseas sportsmen/women who value not only the quality of British deer trophies but also the beautiful and iconic landscapes that these experiences take part in. This can be from the highlands of Scotland in pursuit of the majestic red stag, to a bluebell littered woodland in Southern England looking for an elusive roe buck.

Without this income then deer management may not be economically viable to landowners who may seek government compensation for the loss of their income. It is estimated that it costs about £300 per deer culled. So, at a minimum annual cull of 350,000 deer this would cost the taxpayer £105 million.

[1] https://www.iucn.org/commissions/commission-environmental-economic-and-social-policy/our-work/sustainable-use-and-livelihoods/resources-and-publications/suli-briefing-paper-informing-decisions-trophy-hunting

[2] https://www.conservationfrontlines.org/2019/10/trophy-hunting-bans-imperil-biodiversity/

[3] http://www.nonnativespecies.org/home/index.cfm

[4] https://www.bds.org.uk/index.php/research/deer-distribution-survey

[5] British Deer Society Why manage deer

[6] Deer Initiative document Management Population Dynamics

[7] Current and Future Deer Management Options Defra (2003)

[8] R.J. Fuller, R.M.A. Gill, Ecological impacts of increasing numbers of deer in British woodland, Forestry: An International Journal of Forest Research, Volume 74, Issue 3, 2001, Pages 193–199

[9] Deer Initiative What we do – Promoting animal health

[10] Deer Initiative About Us

Most hunting trophies leaving the UK will be antlers and skulls from the main six species of deer plus wild goats. The trophies will either be a cleaned and bleached skull, or a head/shoulder mount prepared by a taxidermist. There are no figures on how many are exported.

The BASC has a head measuring service for its members and the table below indicates how many medal category trophies were measured in 2019. Some of these will have been exported, but we have no way of determining how many.

SpeciesPlatinumGoldSilverBronzeGrand Total
Roe10326490196
Muntjac131202476
CWD2193125
Wild Goat 19414
Fallow 52310
Red 3137
Sika 1113
Grand Total1392100126331


Note many deer that are culled as part of sporting stalking will not achieve the size required to be classified as a medal nevertheless the head will be prepared as a trophy and given to the hunter as a memento of their stalk.

There are no overall figures for the value of trophy hunting in the UK. However, most rural land holdings throughout the UK will have a population of deer on them and one way to help to finance the management of these deer is to sell the rights to shoot them to sporting clients. A great deal of these clients will come to the UK from Scandinavia, Europe and the USA. They will pay to shoot the larger males as the antlers that they produce make good trophies as a memento of their stalking experiences.

The latest Home Office statistics on firearm and shotgun certificates[11] indicate that in the year ending 31 March 2019, a total of 2,016 people had been issued a visitors’ permit to bring Firearms into England and Wales. Most of these visitors would have used their firearms for hunting.

The PACEC report on The Contribution of Deer Management to the Scottish Economy (2016[12]) revealed a total annual expenditure on deer management in Scotland of £43.1m. This results in a total employment across Scotland of 2,532 people and estimates the total employment required to carry out deer management in Scotland as the equivalent of 845 full-time jobs. The total direct income received from deer stalking was £12.4m of which £6.9m was from sporting clients, many of whom would have been overseas visitors wanting to take their Scottish stag trophy home with them. Another PACEC study on country sports tourists (2015[13]) found that 15% of all participants were from overseas, many from Europe and North America.

Therefore, a ban on the export of hunting trophies from the UK will have a serious impact on the economic viability of deer management throughout the British countryside.

[11] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/812296/statistics-firearm-shotgun-certificates-england-wales-2018-2019-hosb0919.pdf

[12] PACEC (2016) The Contribution of Deer Management to the Scottish Economy. Cambridge

[13] PACEC (2015) The Benefits and Volume and Value of Country Sports Tourism in Scotland. Cambridge

Please provide evidence of the impacts of restrictions on trade, import or export of hunting trophies, or impacts of domestic restrictions on the practice of trophy hunting on:

A reduction in income as a result of a ban on trophy exports will potentially reduce the level of active deer management across the UK resulting in an increase in the density and distribution of the UK deer herd. This would result in further destruction, through browsing and fraying, of natural habitats, but particularly woodland communities.

The PACEC report on country sports tourism in Scotland (201512) estimates that shooting and stalking attract 130,000 visitor trips per year resulting in 280,000 visitor nights accommodation worth an estimated £69m to the local economy. With a further direct Gross Value Added (GVA) attributable to the activities of shooting and stalking visitors of £21m. Most of this expenditure takes place within 10-15 miles of the country sports site.

Unfortunately, there are no similar figures for England and Wales, but it is likely that they are at least equivalent to those of Scotland.

If trophy exports were banned from the UK then a significant proportion of this additional income would be lost to rural communities who rely on this often at times of year when other tourist activities have declined.

As stated above shooting and stalking in Scotland contribute over £90m to the economy. It is expected that this is a similar figure for England & Wales.

The PACEC report on country sports tourism in Scotland (201513) estimates that shooting and stalking attract 130,000 visitor trips per year resulting in 280,000 visitor nights accommodation worth an estimated £69m to the local economy. With a further direct Gross Value Added (GVA) attributable to the activities of shooting and stalking visitors of £21m. Most of this expenditure takes place within 10-15 miles of the country sports site.

Unfortunately, there are no similar figures for England and Wales but it is likely that they are at least equivalent to those of Scotland.

If trophy exports were banned from the UK then a significant proportion of this additional income would be lost to rural communities who rely on this often at times of year when other tourist activities have declined.

We believe that there are no alternative practices that could replace deer stalking in the UK. As mentioned already the UK deer herd needs active culling to maintain it at a sustainable carrying capacity and keep their impact to a minimum.

The fact that people are prepared to pay to undertake some of this culling and retain the non-edible byproduct (i.e. antlers) as a memento of their experience helps fund the deer management that is undertaken throughout the rest of the year, but particularly the female cull.

So even if the export of trophies was banned the UK deer herd will still need to be culled but somehow funds will have to found to make good the shortfall in income which is currently received from overseas hunters.

The PACEC report on The Contribution of Deer Management to the Scottish Economy (2016[14]) revealed a total annual expenditure on deer management in Scotland of £43.1m. This results in a total employment across Scotland of 2,532 people and estimates the total employment required to carry out deer management in Scotland as the equivalent of 845 full-time jobs. The total direct income received from deer stalking was £12.4m of which £6.9m was from sporting clients, many of whom would have been overseas visitors wanting to take their Scottish stag trophy home with them. Another PACEC study on country sports tourists (2015[15]) found that 15% of all participants were from overseas, many from Europe and North America.

[14] PACEC (2016) The Contribution of Deer Management to the Scottish Economy. Cambridge

[15] PACEC (2015) The Benefits and Volume and Value of Country Sports Tourism in Scotland. Cambridge

We have no concerns about the standard of welfare of animals hunted as trophies in the UK. The deer stalking community is very well self-regulated, we have an excellent training scheme[16] which a high proportion of UK based and some overseas stalkers have achieved. There are also detailed Best Practice[17] guides for most aspects of deer management. In most cases sporting clients are accompanied by an experienced deer stalker to ensure safety and animal welfare are of the highest standard.

[16] Deer Management Qualifications https://www.dmq.org.uk/

[17] http://www.thedeerinitiative.co.uk/best_practice/

What can you do?

We need you to respond individually to the consultation and share your experience. Here are the two things you can do:

  1. Contact Defra as an individual stating your opposition to option three: A ban on all hunting trophies entering or leaving the UK. You can do this by emailing Defra here: huntingtrophyconsultation@defra.gov.uk 
     
  2. Fill in this template document providing your own personal experience and send it to Defra

Deadline extended until 25th February

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