DEER
MANAGEMENT IN IRELAND
Draft
Deer Management Policy Vision
A RESPONSE
to the
Inter-Agency
Deer Policy Group
Draft
Discussion Document (Second Draft)
issued
September 2012
Compiled by
Liam M. Nolan
on behalf of
Irish Deer Society
Wild Deer Association of Ireland
Wicklow Deer Management & Conservation Group
Countryside Alliance Ireland
Deer Alliance HCAP
12 October 2012
1: INTRODUCTION
1.1: This response to the Draft Discussion Document (Second Draft)
issued by the Inter-Agency Deer Policy Group in September 2012 is compiled on
behalf of those organisations listed on the title page and seeks to incorporate
all those common concerns shared by the different organisations representing
the views of licensed deer hunters in Ireland.
1.2: There are numerous points of concern, including a view that the
Second Draft appears to incorporate a great many specific proposals which were
not mentioned, even obliquely, in the Inter-Agency Deer Policy Group’s First
Draft (2011) and which did not feature to any identifiable extent in the
submissions received from stakeholders in November 2011, as published on the
website of the Department of Agriculture, Food and the Marine. Arising from
this analysis, stakeholders are concerned that they are being presented with a fait accompli which renders null and
void any purported consultation process. In particular, licensed deer hunters
(so-called “recreational” hunters) are concerned that they are being side-lined
and relegated to a subservient position in the deer management chain, whereas
in reality they are the front-line soldiers in the matter of practical
management and culling of wild deer.
1.3: That said, all stakeholders welcome, and will support, the
underlying principle which unites all stakeholders, viz. that wild deer in Ireland are deserving of a national
management policy which draws on all available human resources and which
protects the long-term interests of wild deer while balancing human economic
needs, including the particular economic needs of the farming and forestry
communities.
2: SPECIFIC OBSERVATIONS ON THE
SECOND DRAFT DISCUSSION DOCUMENT
2.1: As a general observation on the
Document, the Wild Deer Association of Ireland (WDAI)
point out that the document references “basic
data on deer density levels across a range of different habitats” is being required
to develop a sustainable deer management policy. However such comments as “growing problem of increasing deer populations in
Ireland”, where evidence of deer populations actually shows widely divergent
levels are of great concern and unhelpful, and contrary to the overwhelming
view of WDAI members in all regions, and to NPWS staff and respected academics
regarding current deer numbers.
WDAI note that the
document makes little if no reference to the Wildlife Acts under which deer are
a protected species. Elements of the document are considered to be very
ambitious, even aspirational and likely to prove exhaustive of resources,
whereas a more simplistic approach might prove more productive.
2.2: Countryside Alliance Ireland (CAI) has further concerns, recommendations and comments
and hold the view that one overriding factor which must be given priority
consideration throughout, is the impact the Draft Policy will have on the
recreational deer hunter. It will not be acceptable for recreational deer
hunters to be unduly penalised through increased costs; whether from licensing
fees or the costs associated with accredited training schemes/certification as
this would severely prohibit this activity for many. The policy while
meeting the needs of the framework ‘for sustainable wild deer management in
Ireland’, needs to be balanced and mindful in this regard.
2.2: In commenting
on the Document, the paragraph numbering system set out in the Document is
followed for purposes of identifying specific points of concern, as follows:
(Paragraph number)
1.6 Accurate, quantitative data regarding deer
population densities and spatial distribution within and between land
catchments is a critical component of any successful deer management programme.
An assessment of deer population distribution and densities must be carried out
as an essential prerequisite to any deer management strategy in the field. It
will provide an indication of the required scale, extent and likely costs of
such measures. A national deer population assessment programme will provide the
baseline against which the dynamics of current populations can be observed, and
by which policy performance can be evaluated over time.
Wicklow Deer Group
(WDG) Response
·
WDG,
together with all other deer organisations, has consistently and repeatedly
called for a national deer census as a first step, and the cornerstone of a
national deer policy. This call has been put out to the relevant authorities on
countless occasions over the last thirty years. The identification now of a
national census as a crucial factor in policy-making and implementation by the
Review Group is therefore to be welcomed. However the question must be asked –
by whom is a census to be conducted? And if not reliant on the corps of
4000-plus licensed “recreational” deer hunters, then how is to be achieved?
1.7 Typically, deer population assessment
should be carried out over a 3-5 year timeframe. There is an initial need to
identify broad habitat categories in areas of interest. An initial sampling
exercise will produce
basic data on deer density levels across a range of different habitats. It will
be enhanced by more intensive sampling in high density areas, or in areas where
conflict with land management interests may exist. Population density survey
data would be further refined by correlating detailed biometric data from
culled animals against density estimates.
CAI Response
·
To develop a sustainable
deer management policy, an accurate account of the deer population must be
swiftly evaluated. Using valuable
voluntary/professional time and department funds, these resources must be used
efficiently to assess deer population in a timeframe period of 3-5 years. Small sample exercises will provide no
accurate information that will help in a long term deer management setup.
2.5 Deer Management policy
should recognise and appreciate the critical difference between native,
naturalised and exotic species, and their role in Irish ecology
&
2.6 The conservation
requirements of our native red deer populations and the need to protect their
genetic integrity must be balanced with the need to protect priority habitats
and species in areas where these populations exist
&
2.7 Deer management policy
must strongly recognise the risk posed to native Irish red deer through
hybridisation with Sika Deer and miscegenation with imported European red deer.
A National survey in relation to hybridisation with emphasis on red deer in Co.
Kerry is currently being prepared for NPWS and may guide future policy
development in this area.
WDG Response
·
The
Review Group should be aware that recent research has shown that the existence
of a native species of Red deer may be a myth, not meriting an untoward
discrimination against other species, including Fallow and Sika.
3.3 Deer management policy measures shall aim to
maximise the financial contribution of deer related products and services to
both rural and national economies. The deer stalking and hunting sector already
makes a significant contribution to the rural economy through the sale of
hunting concessions, the sale of clothing, equipment, firearms, vehicles, food,
drink, training courses and accommodation etc. The non-shooting recreational
sector (photography, eco-tourism) also has potential for development.
CAI Response
·
CAI
is pleased that the deer policy group has recognised the financial benefit that
deer stalking and the hunting sector has to the rural economy.
3.5
Policy must also recognise that current strong market values for venison have
led to an upsurge in both illegal deer hunting and illegal trade in
venison. Strong measures are required at all levels to prevent the
introduction of illegally sourced venison to markets.
WDAI Response
·
We support this
reference along with increased measures by the DAFF & DAHG staff in
addressing this illegal activity, inspection measures would also be required
for those granted a commercial licence. The absence of game handling
establishments in the submission process to date is noted.
CAI Response
·
CAI
is delighted that the policy has recognised that illegal trade is taking place
due to a strong market value of venison and the (current) minor penalties
applied to poaching. By increasing the
penalties of poaching and traceability between the hunter and game dealer per
each purchased game, this will help lower illegal trade and also poaching for personal
consumption.
4.2 In developing and implementing deer management
measures, the welfare and humane treatment of deer populations shall be
paramount. Policy should support training and education measures necessary to
ensure that management measures and their implementation conform to
international best practice and standards, and comply with existing national and
EU legislation regarding animal welfare, food standards and human safety.
Deer Alliance HCAP Response
·
The word “training” appears on several occasions in the
Document, notably at paragraphs 3.6, 4.2 (above) 5.3, 5.4, 6.7, 6.10, 6.11 and 7.3.18.
Deer Alliance HCAP considers it unfortunate that no recognition whatsoever is
given to the fact that fully a quarter of all licensed deer hunters in Ireland
have completed the Hunter Competence Assessment Programme since its inception
in 2005, following four years of cooperative development.
·
This is
particularly concerning in circumstances where three out of four State entities
comprising the Inter Agency Deer Policy Group were not merely represented in
the development of HCAP, but have actively participated in the implementation
of the programme from 2001 to date, and play a full role in the management of
the programme.
·
As a matter of policy, Deer Alliance HCAP have consistently
called for mandatory certification (HCAP or equivalent) as a prerequisite to
the granting of a licence to hunt wild deer. Deer Alliance HCAP submits, as it
did in the first stage of public consultation, that the adoption of mandatory
assessment and certification has profound implications for practical management
of wild deer. It is the licensed deer hunter who will in the final analysis be
responsible for practical implementation of policy, which to be successful in
terms of implementation must include the humane and efficient culling of deer
in order to achieve policy objectives as identified in the Draft Deer
Management Policy Vision document.
·
Deer Alliance HCAP therefore formally proposes that mandatory
assessment and certification based on the HCAP model be included as an
essential part of any final policy for the management of wild deer.
·
Deer Alliance HCAP confirms its wish and intention to remain
fully involved in and committed to the development of a national policy on the
management of wild deer, including but not limited to the adoption and
inclusion of mandatory assessment and certification as an essential element in
wild deer management.
4.4.1 There is a requirement for greatly improved
education and awareness concerning deer management among land use
professionals, and among the general public, which will in turn enable the implementation
of deer management measures in the field. Long term development of deer
management capacity in Ireland will require an appropriate accredited
educational framework. This can be integrated with existing 3rd level and
Continuous Professional Development programmes.
CAI Response
·
CAI agrees with the policy that an appropriate educational
framework for all DHL holders must be undertaken for long term deer management,
however, CAI would like more clarification in what this would involve and how
this would be tasked.
·
It is also important to note that many deer hunters have
years of practical experience although may not have accredited qualifications
such as HCAP and this experience must be taken into account.
4.4.3 Landowners/Shooting rights – A number of
instances have been identified where land management interests experiencing
issues with deer populations have been unable to implement suitable controls
due to land title issues involving sporting rights. Policy should support
measures aimed at exploring this issue in greater detail from a legal
standpoint, towards devising an equitable solution to the issue between
landowners and the holders of sporting rights in areas where deer pose a threat
to land management objective.
Deer Alliance HCAP Response
·
Any
analysis of this statement must lead to a critical assessment of the role of
the farming community in effective deer management. Ultimately it is the
landowner who controls or at least heavily influences, deer control. There are
very few instances where ownership of sporting rights (a defined property) has
seriously interfered with best-practice farming. Conversely, by not exercising
discretion in who shoots what on his land, the farmer contributes to
mismanagement of deer, and often to an escalation of problems.
·
The
most immediate contribution that the farming community can make to effective
deer management and to implementation of a national policy on deer is to
encourage cooperation between adjoining landowners, and the formation of
suitably qualified hunters acting as a coordinated group for deer management
i.e. local Deer Management Groups.
·
What
are euphemistically called “land title issues” in paragraph 4.4.3 are in fact
important property rights, and to allow the farming community to over-ride such
rights in pursuit of short-term individual economic gain is likely to generate
considerable dissension. The logical progression of the proposal implicit in
paragraph 4.4.4 would be the adoption of the American Model, whereby all land
is open for hunting except where expressly reserved (“posted”) and the
landowner has limited control over access to his land.
CAI Response
·
CAI
would like to be given examples where issues have been identified and what
policy support measures are envisaged to reconcile possible conflict areas.
4.4.4 Forestry Issues – Forest practice and design has
a major influence on deer population dynamics and behaviour. As such, the
forestry sector has a critical role to play in the implementation of deer
management through habitat manipulation. There is a requirement for greatly
improved education and awareness regarding forest management issues where deer
populations exist. Pre-planting design is a critical issue, and appropriately
designed forest developments should incorporate an integrated approach to deer
management. Features such as fencing, open space reserves, deer lawns, and
appropriately sited control infrastructure such as access tracks, hides, and
high seats must be incorporated into site design. As in 4.3 above, codes of
best practice aimed specifically at the forest sector should be developed.
CAI Response
·
Forest
design is the key long term practical method for many of the deer management’s
objectives. Deer lawns will not only
provide more safe areas for culling, but will help in monitoring deer
population. Forest design must be looked
at immediately for long term deer management.
4.7 Recreational Deer Hunting – measures are required
to support and encourage the contribution of recreational hunters in achieving
desired deer management objectives, and towards integrating recreational
hunting activity within a structured deer management environment. This issue is
discussed in greater detail in Section 5.
CAI Response
·
CAI
is again pleased to read that the deer management policy group appreciate and
understand the key benefits of recreational deer hunting.
5.1 Policy should allow for a clear distinction
between deer control activities carried out in support of land management
objectives or public safety; commercial deer management activities carried out
for primarily financial reasons and licensed recreational deer hunting, carried
out for primarily recreational reasons.
CAI Response
·
CAI
is mindful that public safety is of paramount importance. However, the DMU in each area should build in
contingency in this regard. Guidelines
must also be issued to ensure that the policy is fair and that commercial
hunting does not take precedence over recreational hunting purely because it
will secure more income for the government.
5.0
Recreational deer hunting should make a positive contribution to desired deer
management objectives, and take place within a structured, best practice
environment, having due regard for public safety, animal welfare, legal
obligations, and the management objectives of lands where hunting takes place.
WDG
Response
·
So-called “recreational” deer hunting is arguably
the only way is which deer control is ever likely to be achieved nationally,
and where conducted along with membership of one of the organised deer
associations, already takes full cognisance of best-practice requirements,
where the hunters concerned have been assessed and certified as competent
within the parameters of the Deer Alliance Hunter Competence Assessment
Programme (HCAP). To suggest otherwise is an affront to the one-quarter of
licensed deer hunters, and up to one-half of all active hunters, who have been
HCAP-assessed and certified between 2005 and 2012.
5.2 Recreational hunting should not be considered
a substitute for professionally applied deer control. However, policy should fully recognise that
recreational hunting has potentially a very valuable role to play within a
structured deer management environment and objectives in the catchments where
deer hunting takes place.
CAI Response
·
This
statement is somewhat ambiguous and clarification and guidelines must be issued
to outline when professionally applied deer control would be invoked as the
only option.
6.2 A comprehensive revision of current deer
legislation is required in the light of significant changes to land use
practice, conservation requirements, deer hunting practice and deer population
dynamics since the introduction of the Wildlife Act, 1976.
CAI Response
·
The
Policy must address the possible abuse of Section 42 of the Wildlife Act to
extend season for personal gain. This
should only be issued at last resort once legitimate methods have failed. Permits should only be considered to skilled
DAHG staff.
5.6 It is recognised that
there is now considerable competition within the recreational hunting sector
for space and hunting rights or permissions to hunt deer, particularly in
regions close to larger urban centres. There is little regulation in relation
to hunting rights on private lands, which may impact on the ability of hunters
to apply consistent management from year to year. An organisational structure
is required that would permit more consistent management of deer for sporting
use over longer periods of time within a structured deer management environment.
WDG Response
·
Local
Deer Management Groups, comprised of competent licensed hunters working closely
with local farming and forestry interests, has long been recognised as the most
efficient and effective way to control local deer populations. However
cooperation between competing interests often militates against attainment of
objectives, and deer hunters, farmers and foresters must work together much
more closely if all long-term objectives are to be achieved.
6.3 The current Deer Hunting Licence (DHL) system
should be significantly reviewed to incorporate current requirements and to
minimise unnecessary administrative overheads. In particular, given recent
amendments to firearms licensing legislation under the Criminal Justice Act,
2006, there is a need for the issuing and validity of deer hunting licences to
run concurrent with the issuing and validity of firearms certificates.
WDG Response
·
Coordination
of issue and validity dates is a simple, immediate and effective way to cut
down unnecessary administrative work-load and expense. There is no reason why
the Deer Hunting Licence (DHL) should not run for a three-year period as does
the Firearms Certificate.
6.4
Separate licensing systems should be developed to distinguish licensed
recreational hunting from licensed commercial hunting to aid the regulation of
trade in venison and prevent trade in illegally hunted meats. Provision of
a valid tax clearance certificate and declarations should be a requirement
for commercial hunting licences.
WDAI Response
·
All transactions
involving the sale of venison should also require a PPSN number to be supplied.
Revenue should become involved in this cash business. It is concerning to note
the FSAI/DAFF game handling courses been promoted as a free course for the
unemployed or canvassing of Game Handling establishments to promote such
courses, evidence would show the illegal taking of deer is not limited to but
prominent amongst the unemployed, lured by the attraction of easy and
non-traceable cash transactions. Strict regulation & monitoring would be
required for the issuing of a commercial licence to avoid exploitation by those
involved in the illegal taking of deer.
CAI Response
·
Separate
licensing systems would make sense to ensure commercial hunters are complying
with income taxation etc. However, we do
not believe that this separate licensing system will prevent poaching and the
trade of illegally hunted deer.
·
We
suggest that commercial food establishments who buy and sell game should keep a
record of all transactions and the audit trail would be available for
inspection by the relevant authorities.
We would also recommend that commercial food establishments and game
handling establishments can only pay for game via a traceable cheque and not
cash.
6.5
The current system whereby DHL (Deer Hunting Licenses) applicants supply
details of hunting permissions, places an unnecessary burden on the
issuing authority, in terms of administration. It is strongly open to
misuse, and as an annual requirement, is in itself a potential barrier to
consistent year-to –year deer management on lands concerned.
WDAI Response
·
The DHL system should
be strengthened to avoid abuse, currently DHL’s are been issued at
unprecedented levels without any regard of actual requirements or cull targets.
Any relaxing of the current system for issuing DHL’s should be avoided to avoid
unnecessary safety risks & poor deer management practices. The
administration process of DHL’s could be improved through an online application
process.
CAI Response
·
The
current system is not working and needs radically upgraded. The system should
be strengthened to take into account of future kill targets per the amount of
animals in that area, therefore the administration of deer licenses must lie
with the issuing authorities.
6.7 Policy should ensure that there is a strong
requirement for mandatory training and certification regarding firearms
handling safety and proficiency prior to the issue of Deer Hunting Licences. In
this regard, there is a need to establish standardised training and assessment
structures that are fit for purpose. Training and assessment must be
independent, transparent, and subject to accredited certification. Those
providing the training must be suitably qualified and accredited to do so.
CAI Response
·
CAI
stresses the requirement for mandatory completion of the HCAP as the required
standard before issuing a DHL. To help
prevent poaching, this should be top of the criteria to be set in stone as soon
as possible. Completion of a training
certificate to awarded persons’ will also provide the opportunity to educate in
all aspects of the objectives we require the professional/recreational deer
hunter to carry out. From database input
and to on-line log books we must start immediately to use “on the ground”
personnel to achieve our objectives.
6.9 Policy should support and enable the
introduction of a tagging system for culled animals. Carcass tagging would form
a critical element of a set of integrated measures aimed at improving the
overall traceability of venison from field to fork and enable the exclusion of
illegally sourced meat from markets”.
CAI Response
·
CAI
supports the prerequisite for tagging systems.
This can only be achieved once deer densities per DMU is achieved and
can set out the harvest levels for the given area. This is a long term objective that will also
help DAFM trace carcasses. In addition, mandatory tagging may serve as a
deterrent to illegal hunting/ game handling.
These tags should be issued by the Department at the same time the DHL
is issued.
6.12
Policy should address other firearms issues as they relate to deer management,
such as the issue of appropriate firearms calibres for smaller invasive
species, and the use of shotguns, tranquiliser guns, and appropriate
training for personnel using such firearms. This may require amendments to
existing firearms legislation. In this regard, the use of vehicles,
night-shooting, trapping, tranquilisation and other control methods and associated
technique.
WDAI Response
·
In the absence of
appropriate policing of our Wildlife Acts, training, data and resources to
allow any introduction of night shooting, shotguns etc. for managing deer
should be avoided. This practice is only required by a minimal number of NPWS/Coillte
staff nationally in high recreational areas.
CAI Response
·
Many
stakeholders including WDAI and the IDS would be able to educate in best
practice of control methods and techniques.
CAI fully disagrees with any proposal to amend the wildlife act to allow
use of what we believe to be unethical methods and techniques, including night
shooting and other control methods. We
would ask the Department to clarify what is meant by ‘other control methods and
associated techniques’.
WDG Response
·
The
various deer organisations are strongly opposed in principle and in practice to
night-shooting of deer as a wholly inefficient, unselective and potentially
dangerous methods of deer control.
6.14 It is widely recognised
that there has been a major increase in illegal taking of deer and related
unlawful trade in illegally sourced venison in recent years. This phenomenon is
largely due to recent increases in prices being paid for venison. There is also
significant evidence of an increase in the illegal trading of venison through
non-registered individuals and meat handling facilities. Illegal taking of deer
is viewed as a low risk high gain activity by those involved. Such trade and
activity endangers public safety, may endanger the image of Irish meat exports abroad,
and makes legitimate deer management activities more difficult to implement.
WDG Response
·
Poaching
is a large and growing problem everywhere, yet it appears that very little is
being done to curtail it. Local groups often have to take on the primary
responsibility of patrolling ground, and the potentially dangerous task of
dealing with armed trespassers on Coillte forest property as well as on private
land.
·
The
Wildlife Service must be better resourced and better supported in dealing with
this problem working more actively with the Garda Siochana in known poaching
“hot-spots”.
7.3.4
All lands, including forest properties, Coillte deer leases and licensed
deer hunting on private lands within DMUs would be included in the overall
deer management strategy for that DMU. This would be supported in law by a suitable
statutory instrument issued under the aegis of the Forestry Acts, or under
the Wildlife Acts.
WDAI Response
·
We would strongly disagree with this view, there is
no scientific data or other factual evidence to suggest this is required. Where
individual landowners hold a reservoir of an unmanaged & unsustainable deer
population a local solution should be formulated working with the effected
stakeholders. It is noted the submission process to date is predominately
represented by Co Wicklow based landowners with a notable absence from other
regions were deer are present, this could lead one to believe there may not to
be an over population of deer other than some areas of Co Wicklow. The majority
of those involved in deer-stalking/ management do so to the required levels of
maintaining a sustainable deer population, over a life time in many examples.
Any actions that would undermine these management practices should be avoided,
such as DMU’s are suggested in their current format.
7.1 A critical first step must be the establishment of
a full time National Deer Management Unit (NDMU) that will co-ordinate the
implementation of deer management policy at national, regional and local
levels. Any such unit could make use of existing staff and skill sets within
DAFM and NPWS, and other relevant statutory bodies, as may be required. Given
the land management, animal health and food safety issues concerned the
Department of Agriculture, Food and the Marine is viewed by the IADPG as being
the most suitable Department to host such a unit.
CAI Response
·
CAI
would like country sport stakeholders to be included within the NDMU and to
have full involvement within the development of the deer strategy. Stakeholders like CAI, WDAI and IDS represent
many of the recreational hunters who would be affected by this policy.
WDG Response
·
WDG do
not agree that the Department of Agriculture, Food and the Marine are the most
suitable Department to host any such Unit (assuming such a unit, centrally
controlled, is finally deemed to be the appropriate way forward – which should
not be assumed unless and until much clarification is obtained on core issues).
The Minister with statutory responsibility for wildlife is currently not the
Minister for Agriculture, Food and the Marine, and the appropriate Minister,
and downstream, his Department, is the appropriate entity, if indeed a NDMU is
to be brought into being. His absence from the consultation process is noted
and is to be deplored
7.3.4: All lands, including forest properties, Coillte
deer leases and licensed deer hunting on private lands within DMUs would be
included in the overall deer management strategy for that DMU. This would be
supported in law by a suitable statutory instrument issued under the aegis of
the Forestry Acts, or under the Wildlife Acts.
CAI Response
·
CAI
would like to stress the point that not all private landowners would be supportive
of culling on their own land. Alternative
ideas must be considered to educate (where necessary) private landowners the
need for responsible deer management.
7.3.8: Deer Managers could be drawn, but not
exclusively, from existing personnel within DAFM, NPWS and from the DAFM
registered foresters list on a voluntary basis. All personnel would be subject
to an appropriate code of conduct. All such personnel would be trained to a
recognised standard using a curriculum developed jointly by DAFM/NPWS.
WDAI Response
·
Other than the
training requirement this suggestion is of great concern and suggests a
non-inclusive approach, furthermore it demonstrates a lack of understanding of
current practices, knowledge-base and training by excluding current deer
managers, deer-stalkers NGO’s who already provide deer management to a satisfactory
level in most areas. The Deer Alliance made up of the relevant stakeholders in
this policy vision, since 2005 has provided a successful & recognised
training standard for deer management and could be further expanded to include
any additional requirements.
·
The omission of a
representative from deer stalking/management stakeholders in the Inter Agency
group to date, we feel is a lost opportunity, as organisations such as the Wild
Deer Association of Ireland and the Irish Deer Society are at the heart beat of
deer management and related issues in Ireland, containing the knowledge and
experience required in drafting and implementing such a policy vision.
CAI Response
·
CAI
would like relevant stakeholders to be represented for the interest of all
parties.
7.3.12
Recreational hunters operating in DMU’s would be allocated tags
according to target harvest levels. Each hunter would be allowed an agreed
minimum quantity of tags without charge at the beginning of the hunting
season, based on the allocated cull. Unused tags must be returned and
accounted for at the end of the season. Tags would consist of trophy tags,
which would have a fee attached, and hind cull tags which would have no charge attached.
Additional tags over the allocated cull limit would carry a commercial
fee.
WDAI Response
·
A tagging system is
something we have suggested for some time however it is a meaningless exercise
at this point in the absence of any meaningful data to support tag allocations.
There are practical issues such a system would face versus their use in other
countries due to our current deer ranges and culture towards deer management.
Tags should only be used to provide meaningful data & traceability and not
the promotion of any stakeholder interests. In the current economic climate
& due to recent increased costs in providing deer management we would see
any fee for the issuing of tags as unacceptable & only serve to restrict
deer management, other than where commercial interests apply, where trophy tags
may be appropriate.
CAI Response
·
Additional
tags requested over the allocated cull should be assessed by the local Deer Manager
within that DMU before granting. A
commercial fee to obtain more tags could result in over cull for the allocated
area.
7.3.13 Licensed commercial hunters and commercial
operators catering to hunting tourism would be allocated tags under a
commercial fee structure. Tags would only be issued to commercial operators on
receipt of a current tax clearance certificate.
&
7.3.14 All licensed hunters would be allowed access to
the primary tier of the national deer management database for input and
personal recording, and generic local level reporting. Suitable software is
currently available off the shelf to provide the type of software infrastructure
required and would require minimal additional development work. Additional
modules would permit reporting of damage severity and location by land managers
within the catchment. Access and reporting would be available at hunter, land
use manager, Deer Manager and regional and national level. A strong spatial
analysis element should be built in to the IT system and should be
inter-operable with GIS systems used by both departments.
CAI Response
·
On-line
and hard-copy log books should be made an obligation to access a DMU
population, to further develop and sustain a long term deer management
objective.
·
CAI
also asks the question, will licensed commercial hunters/operators be given
first priority of the allocated tags per a DMU as opposed to recreational
hunters?
7.3.17
Recreational deer hunters would operate at DMU level through a
club system, analogous to existing current structures such as district gun
clubs. To obtain a licence and tags to hunt in a particular DMU, hunters
will have to join the club for that particular DMU. Clubs would operate
under the aegis of a suitable national body. DMU hunters will be
responsible for anti-poaching measures within their own catchment, under
the guidance of the DM and in conjunction with the relevant authorities
NPWS/Garda Siochana.
WDAI Response
·
We would have grave
reservations about this suggestion and why it is included in the draft
document. Again this suggests a lack of understanding on how deer management is
undertaken in Ireland. While local deer management is a preferable option. Such
management practices in other countries form part of a culture developed over
generations, whereas Ireland has a varied approach due to a number of factors.
In addition many deer ranges are not in gun club areas. Gun clubs are
increasingly fragmented and closed to members outside their own communities,
which would restrict many deer managers/stalkers & existing deer management
arrangements. Gun clubs manage small game and vermin, not deer. Fishing clubs
manage fish populations, not deer. While there have been suggestions gun club
members have recently taken an interest in deer management, the reality is that
the majority have no interest or knowledge in deer management & this
suggestion may have introduced for other reasons. Small game & deer
management practices are not linked & this is reflected in legislation in
other countries such as the UK where deer are protected under separate
legislation to that of game.
·
A possible suggestion
would be to appoint a regional coordinator to areas where factual data shows a
high population of deer unsustainable to the local habitat & land uses,
such a person would have access and an open line of communication to resources
in that area such as deer managers, NPWS, IFA, DAFF etc. when required, they
would also be responsible for setting cull targets, implementing anti-poaching
measures etc.
CAI Response
- CAI
does not agree that the administration for recreational deer hunters to
apply for a licence should lie with local/district gun clubs. To ensure consistency of approach in
terms of standards, fairness and so on, this must be a responsibility for
the National Deer Management Unit, in conjunction with Coillte and the
other government departments as necessary/
- Local/district
gun clubs vary in their approach and at times may be subjective. To
insist that all recreational deer hunters must join a club within a DMU will
prove prohibitive for many and indeed undemocratic.
·
CAI
also disagrees with the choice of word used within the above text. “Responsible” is a poor word that can be read
and used out of context. Poaching is an
illegal crime that should only be dealt with by NPWS and An Garda Siochana. Responsibility for anti-poaching measures can
be upheld by recreational hunters, but strong support and education must be
provided by NPWS/Garda Siochana. Other
methods to prevent poaching must be considered such as DAGH working to increase
the penalties for poaching, public campaigns of awareness and a poaching
hotline. Deer poaching initiatives such
as WDAI’s “Shine a light on poaching” will help increase public awareness and decrease
the incentive for illegal poaching.
IDS Response
- The DMU by its very
nature would cover a number of different land holdings. The DMU would set
a cull level for the entire. Recreational hunters would have to be members
of a club to obtain a licence to shoot in that area only. The club would
have to be part of a “suitable national body”. Outside the Irish Deer
Society, the Wild Deer Association of Ireland and other dedicated deer
management and conservation groups such as Wicklow Deer Group, no such
“suitable national body exists”. The recreational hunters would be
responsible for anti-poaching measures (under “guidance”). This proposal
tramples on the sporting rights of land owners. It limits hunters’
licences to a particular location.
- In summary a
recreational hunter would need a firearms licence, a proficiency test in
hunting, a hunting licence limited to an area, the requirements necessary
to have membership of a club affiliated to a national body for each area,
land owner’s permission, and the cost of tags as yet unknown. This
suggests a radical and far-reaching departure from the existing scenario,
and an undue interference with the concept of deerstalking as practised
throughout Ireland over a very long period of time and as such, is likely
to be strongly resisted.
7.3.19
The system could be initially funded by the agencies concerned in the
initial start-up-phase. Fees for training, DHL fees, DMU or DMAA
membership fees, and commercial operator fees would generate revenue that
can in turn be used to administer the system. For example, with
5,000 registered hunters, a €100 DHL fee would generate €500,000. This
fund could in turn cover
provision
of deer manager expenses, training and IT infrastructure”.
WDAI Response
·
In the current
economic climate this has the potential to increase the illegal taking of deer.
We would not see the introduction of DHL fee as appropriate at this time,
however with the commitment of funds been allocated to the required resources
such as anti-poaching measures, it is something that deer stalker/managers may
accept in the future.
CAI Response
·
CAI
disagrees with the proposed idea to fund the system with the agencies concerned. The system should be funded by the two inter
agencies until valid evidence confirms that the management system is effective. Also,
it states “fees from DMU or DMAA membership fees”. If a future fee was to be taken, it can’t be
taken as either a DMU or DDMA membership fee, because many DHL holders could be
culling within many different DMU’s or DDMA’s.
A first time DHL fee, must be considered only at last resort. The recreational deer hunter is one of the
major human resources the deer management scheme has. We must encourage numbers to continue with
affordability and currently, no other shot game has an exclusive charge. Therefore, especially in these current
economic times, extra costs will increase the likelihood of more hunters to
poach.
·
CAI
appreciates that all agencies concerned should pay equally for their role in
long term sustainable deer management, but until a working scheme is
functioning financially, an uncalculated figure, especially under the current
economic environment, cannot be estimated.
CONCLUSION
The
various bodies over whose name these submissions have been made share many
concerns, including the following:
·
The fact that a great many proposals set out in the
Second Draft Discussion Document have appeared out of nowhere. They were not
promulgated in the First Draft Document, and they were not proposed in any of
the published submissions arising from the first stage of public consultation.
To some, this suggests an agenda at work. This apprehension must be addressed
if there is to be confidence in the workings of the Review Group going forward.
·
There is a perceived bias against
a) The
“recreational” hunter, and
b) Deer.
·
It appears to many that the proposed policy is
heavily weighted in favour of sectoral interests, notably farming interests.
This perception, right or wrong, must be addressed.
·
There is concern at the apparent limited input of
the statutory authority with responsibility for wildlife. Thus issue too must
be addressed and rectified.
·
There is concern amongst those deer organisations
committed to the promotion of safe, effective and competent management of wild
deer through the HCAP system of training, assessment and certification, that
there is no recognition whatsoever given to the efforts of all those concerned
with the development and implementation of HCAP over the last decade.
·
There is concern too about the potential for
“sidelining” the existing deer organisations, committed to the better management
of wild deer over a great many years, in favour of any other organisation, with
or without a track record in the area. The concept of obligatory membership of
a national organisation, for example, is likely to prove a highly contentious
issue.
Those points having made, the move towards development of a national
deer policy, as first promoted by the Irish Deer Society and the Wild Deer
Association of Ireland, working in conjunction with Wicklow Deer Group, Deer
Alliance HCAP and Countryside Alliance at the National Conference on Wild Deer,
convened and organised by the bodies representing “recreational” deer hunters,
is welcomed, and the different deer organisations look forward to ongoing
involvement and the better development of the concept.
The right to add to these submissions is reserved by the parties
making them.
(Footnotes)
Since its establishment in 1981
the Wild Deer Association of Ireland (WDAI) has grown to become numerically the
largest organisation of its kind in Ireland, representing those involved in
deer management, deer stalking and people with an interest in the conservation
and well-being of Ireland's wild deer herds. The Wild Deer Association of
Ireland is recognised as a leading authority on wild deer in Ireland, hosting
events throughout the year with the aim to develop the knowledge and skills of
our members and the general public. We host numerous events, seminars and
international deer experts on issues relating to deer and deer management. We
work closely with government departments on issues of mutual interest and have
been instrumental in amending legislation to the benefit of deer and those
involved in their management. The Wild Deer Association of Ireland is one of
the founder members of Deer Alliance, the assessment committee set up to
oversee the Hunter Competence Assessment Programme (HCAP), which provides a
first step to developing the knowledge and competence of deer managers and deer
stalkers by providing a recognised qualification. In addition, WDAI is a member
of FACE which is recognised by the European Commission as the main discussion
partner, representing Europe's 7 million hunters, and is consulted by the
relevant Directorate-General during the elaboration and monitoring of EU
legislation dealing with
hunting, wildlife management, nature conservation, firearms, wild animal health, game meat hygiene, etc.
WDAI is also a member of CIC International which represents hunters in over 80
countries around the world. Through their national membership and various
social media outlets WDAI run numerous campaigns promoting the discussion of
topics such as the illegal taking of deer (poaching), road traffic accidents
involving deer and the support of landowners who suffer genuine deer crop
damage. The Wild Deer Association of Ireland has been to the fore in recent
years in calling for the implementation of a National Deer Management Strategy
and will be a key stakeholder in any policy regarding deer management.
Countryside
Alliance Ireland (CAI) is an all-Ireland membership organisation with 10,000
individual members and over 25,000 affiliated members. CAI reflects the views
and concerns of a broad range of rural people and their livelihoods. Their vision of a vibrant and diverse
countryside is based on the principle of responsible and sustainable use of our
natural resources, coupled with local community support through meaningful
consultation and proper stakeholder participation.
CAI
regularly partake in, and host, conferences and forums discussing many topics
relevant to the integration of country sports with sustainable wildlife
management. For these reasons we have
the expertise necessary to comment, for both the organisation and our members,
and to make recommendations on the Draft Deer Management Policy Vision.
CAI
commend the Department of Agriculture, Food and the Marine (DAFM), and the
Department for Arts, Heritage and the Gaeltacht (DAHG) for developing a second
Draft Policy Vision for Deer Management in Ireland. This has been long overdue and CAI therefore
supports the initiative.
CAI
call for a more detailed and thorough explanation of what the Draft Deer
Management Policy Vision literally proposes and how these proposals are to be
implemented.
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