The Natural Environment (Scotland) Bill
As we previously circulated, the Scottish Parliament published a consultation at Stage 1 of the Natural Environment (Scotland) Bill. The consultation closes on 9 May 2025.
Part 4 of the Bill deals with deer management.
In its first iteration, the proposed Bill deals with an increase in powers for Nature Scot and, importantly, fails to define a number of matters which would set out boundaries in respect of intervention, etc. There is no definition of nature restoration, and no definition of what circumstances Nature Scot should be allowed to intervene in respect of failing to deal with deer management issues. Our strong view is that definitions should be set out so that the Parliamentarians can consider the true effects of the Bill.
We also have concerns about the capability of Nature Scot in enforcing the legislation in respect of resourcing. We know that they have difficulty meeting demand in other areas, from effectively ‘customers’ seeking advice regarding other wildlife management matters. The provisions of the Bill place a significant burden not only on landowners/occupiers, /managers, etc, but also on Nature Scot.
We are also concerned about the necessity and proportionality of demands which can be made in respect of documents, etc, and the burden this will place upon limited resources on Estates, etc.
A significant change is that of a satisfaction test to be exercised by Nature Scot in respect of someone being added to the fit and competent register. The issue of ‘satisfaction’ is of concern. It insinuates that some kind of mandatory training or qualification to shoot deer will be required. How else are NS to be satisfied?
If that is the case, what evidence at this time suggests that the current practice is not fit for purpose? What evidence exists to suggest that welfare arrangements are not sufficient now? What evidence suggests that the current, excellent record of training and development undertaken by the respective shooting organisations is failing? What recognition will be given to grandfather rights, where people have decades of experience in shooting deer ethically without a formal qualification? These questions need to be answered, but they aren’t in the Bill's current guise.
We understand that the Scottish Government intends to increase the number of deer culled. Of the 25,130 firearms certificate holders in Scotland (not all of whom will shoot deer), 65.2% are aged over 50. 6.66% of certificate holders are aged under 30. As the population of certificate holders ages, who will the Government rely on to undertake such culls? The imposition of mandatory training will likely reduce the number of people available to cull deer, given the financial cost and time to achieve the necessary qualifications.
Beyond that, there will be an impact on the conditions attached to firearms certificates. Before issuing a certificate, the police will be required to confirm that an applicant is on the ‘register’, which will increase the burden on Police Scotland. That will also impact those who travel to Scotland to stalk deer – their licensing force will require access to the register. Is Nature Scot resourced to deal with such enquiries? Will that impact processing time for firearms certificates?
To be clear, and to avoid hares running, this is only Stage 1 of the Bill. The Parliament is seeking views, and we will respond to the consultation fully. Because it is in the Bill, it does not mean it will become law, and we have already highlighted matters to policy officials in respect of unintended consequences.
In the meantime, both the Bill and the explanatory notes can be found at
Natural Environment (Scotland) Bill as introduced
and
You must read this. It will impact you if you shoot deer. We are keen to hear your views, which will impact our final submission.
Should you wish to contribute to our response, please don’t hesitate to contact the office at info@scas.org.uk or alternatively, 01350 724 228.