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BASC has expressed serious concerns at the current state of the Natural Environment (Scotland) Bill, following yesterday’s Stage 2 debate.
The debate confirmed several major flaws in the Bill that risk undermining practical deer management across Scotland.
Concerns include the failure to prevent the introduction of mandatory training for all deer stalkers, unresolved issues around the impact on UK-wide firearms licensing and the retention of overly broad nature restoration powers.
BASC drafted and lodged a series of amendments through MSPs to ensure the Bill remains proportionate, evidence-based and workable for the thousands of practitioners who deliver the majority of Scotland’s deer management and conservation. However, key amendments aimed at preventing the introduction of mandatory training or baseline competency requirements for all deer stalkers were not voted through.
The minister did point to the need for further consultation on the training issue, but BASC’s view is that primary legislation should address these concerns. Leaving this to secondary legislation, which follows once the Bill is passed, offers little certainty for those affected.
We strongly oppose the mandatory training proposal, which lacks scientific or peer-reviewed evidence and threatens to reduce the number of active deer stalkers in Scotland by half to fewer than 7,500, at a time when higher culls are required by government.
We are also concerned that the committee rejected amendments that would have addressed the Bill’s impact on UK-wide firearms licensing. As drafted, lawful deer management in Scotland would depend on entry to a ‘Register of Authorised Persons’. This creates a direct link with the “good reason” test under the Firearms Act 1968 and introduces the risk of regulatory deadlock for applicants across the UK.
The Bill’s new nature restoration intervention powers also remain too broad and unamended; they are vague, subjective and open to overreach. Without clearer limits or safeguards, these will cause problems for deer managers.
We will continue to advocate for evidence-based, practical regulation and urges MSPs to address these concerns around mandatory training and nature restoration as the Bill progresses to Stage 3.
BASC Scotland director Peter Clark said: “We made sensible and well-evidenced solutions to the issues flagged up by the Bill. The Bill in its current form is a missed opportunity to deliver clear, proportionate and workable legislation.
“Mandatory training has no evidential basis. It risks halving the number of active stalkers and threatens both self-regulation and the practical delivery of Scotland’s climate and biodiversity objectives. It also could have real implications for those travelling from England to Scotland to manager deer.
“The Bill, as it stands, introduces serious regulatory risks, insufficient safeguards and unnecessary burdens on those who already contribute enormously to voluntary deer management and conservation. We urge MSPs and Ministers to reconsider these issues at Stage 3 to ensure the final legislation supports rather than undermines the very people who deliver Scotland’s deer management.”
For more news from BASC Scotland, visit our dedicated pages here.

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