by James W Aris

On 4 August DEFRA launched a month long consultation on the management of deer in England.

There are more deer in the UK than at any time since the Norman conquest and, in many places, densities are far too high. Overgrazing by deer has been having a huge impact on other species, as well as the biodiversity of our environment due to the excessive browsing of vegetation, shooting shrubs and sapling trees. After years of the Countryside Alliance campaigning for regulation change on deer management in England it is great to see that DEFRA has finally produced this consultation.

We have responded to the consultation and are broadly supportive of the direction, especially the focus on invasive species, but due to the format of the consultation (the inability to write a response unless you ‘disagree’ or ‘strongly disagree’ with the statement posed), we have had to ‘disagree’ with the question, in order that our written answer is read.

The consultation seeks views on the key proposals to ensure the sustainable management of the English deer population, and a reduction in the impacts of deer on the natural environment.

A summary of our responses to the key proposals are below:

Q: We propose to review and amend existing legislation to allow shooting of male deer during the existing close season. To what extent do you support this proposal?

A: Disagree

  • We believe that protection should be maintained for males as well as females of the indigenous species of roe and red deer in order to maintain a stable and thriving population.
  • The focus must be on a female cull of non-indigenous species, as the shooting of only male deer will not reduce population levels, contrary to the proposals aims.
  • An open season for male deer only would also result in resources being focused on them, again not solving the issue.
  • Landowners already have the ability to shoot male deer outside of the season by a grant of a licence, therefore it is unnecessary. This licence can however be made less restrictive by amendment.
  • We also have concerns that an open season will force deer to change their natural habits and will serve only to push deer to other areas, therefore not resolving the issue.

Q: We propose to review existing legislation to either reduce or remove the Licensing process to permit shooting of deer at night to enable appropriate, proportionate, and effective control. To what extent do you support this proposal?

A: Disagree

  • The current licensing system must be made more accessible and user-friendly where it is required.
  • The removal of a licensing system would be detrimental to poaching prevention efforts, and create an adverse risk to public safety.

Q: Which actions would you consider, to allow more effective means of controlling muntjac to prevent them damaging woodlands and biodiversity, and expanding their range into areas they are not currently present?


  • Incentives targeted towards females, paid for by Government and administered through Approved Game Handling Establishments (AGHEs).
  • This would support the ambition to develop the wild venison market as a carbon-positive healthy meat, and a product of sustainable woodland management.

Q:  We propose that everyone who culls deer in England has to reach the same standard. To what extent do you support this proposal?

A: Disagree

  • There is no evidence to support this proposal. 
  • The sector currently self-regulates well and offers DSC1 and DSC2 qualifications, with over 50% of deer managers holding the former.
  • There is no evidence that mandatory training is required.
  • Introducing a minimum level will cause a financial barrier to entry that currently does not exist, and it will lead to fewer deer being controlled in the long run - contrary to the aims of proposals laid out in this document.

Q: What would you consider the most effective means of developing a consistent national approach to responding to deer collisions and deer welfare incidents?


  • Standardisation across police forces via Home Office issued guidance.
  • This should be based on the Hampshire and Thames Valley scheme.

The consultation closes on 2nd September and we urge all with an interest to respond. Responses can be submitted here.

Our full submission can be found here.


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