The Association of Deer Management Groups have issued their comment on the Wildlife and Natural Environment Bill.

Of 470 responses the Scottish Government received, 359 are now posted on line.

The following areas were discussed by the ADMG in some detail. They also make comment on the direction they feel the WNE Team and the Minister are currently leaning.

1. Competence-it appears highly likely that there will a requirement for all those who shoot deer to demonstrate a degree of competence which will be linked to National Occupational Standards. Those shooting deer under supervision by a competent person will not be required to hold a certificate of competence. It looks likely that the current Level 2 DSC will be the required standard. Grandfather rights may only be available in exceptional circumstances or may not be available at all.
2. Deer Management Planning-it appears unlikely that there will be the introduction of mandatory deer management planning.
3. Seasons-they are unsure as to how the WNE Bill Team are going to determine on the subject of seasons. Theye stressed the importance on the welfare and vulnerability of particularly male deer during winter months and the economic importance to rural communities. They also stressed the venison quality issues in relation to deer shot out of season.
4. Occupiers Rights-are likely to be retained in some format but may be subject to tighter regulation.
5. Dispute resolution and deer panels are key to thinking as could the retention of Sections 7-10 in all but name.
6. Returns appear to be linked to competence and a register of those who are competent. They have stressed the unworkable nature of this proposal but this proposal appears inter linked to competence.
7. Traceability-They stressed the need for a traceability system which is administered and policed adequately.

The responses to the Consultation Document will be subject to external analysis and Stakeholder discussion which will probably take place in early 2010. The Bill must have made its way though the Scottish Parliament by May 2011 at the latest. It is worth remembering that amendments to the Bill could be made at Stages 2 and 3 of the Bill's passage.

Please take every opportunity to lobby your local MSP. ADMG will seek further discussions with the WNE Bill Team.

The responses are available via the following link: http://www.scotland.gov.uk/Topics/Environment/Wildlife-Habitats/WildNatEnvBill/ConsultationResponses