NatureScot seek public engagement on deer licences

NatureScot are seeking stakeholder responses on proposals to fully recover the cost incurred to process and issue licences, such as night and out of season licences. We have made it clear that wildlife management licences should not generally be charged for, as the majority benefit the public in a number of ways. Conservation, biodiversity, net zero and tree damage are all firmly on the Scottish Governments’ radar, and most of the licences affected benefit at least one of these.

We have compiled our position in our answers in the questionnaire and hope these provide a guide for your own response as a stakeholder or interested party. The closing date is Wednesday 20 November.

2. COMMENTS ON CURRENT LICENCING SYSTEM

The current system (where deer is concerned) seems to work well and licences are issued where they are required, and to those who are suitably qualified. The reporting factor ensures that NatureScot remains in control of the licence and can interrogate information supplied by the licence holder at the end of the licence term.

3. Do you support the principle of charging for species licensing?

No

4. Please indicate a preference regarding either a standard cost for all licences, or tiered costs according to complexity and public interest.

Tiered costs - In the absence of a no cost option.

5. Justification for #4

This questionnaire seems to be missing a third option of no cost recovery. We oppose full cost recovery as the control of deer numbers is firmly in the public’s interest and a part of the government’s Net Zero aims and policies. The Scottish Government requires more deer to be shot and so this cost should not be passed on to those who will be responsible for delivering this effort. Currently, 80% of all deer control in Scotland is undertaken by the private sector, at no cost to the Scottish Government, and additional costs will only discourage some from contributing as they do now. On this occasion, tiered costs is only preferred as the only other option given is standard costs.

6. Tiers / bands

If a cost recovery system is introduced, we fail to see how a simple application and grant could cost the same as a complex application. This questionnaire stated that the fee would not exceed the cost of processing and so cost recovery should be based on the amount of work required to process the licence, otherwise, simple applications will be subsidising extensive licence applications. If a 3-tier cost recovery process was introduced, there would still be an option for the lowest tier to have no chargeable fee if the licence was clearly for public benefit. Most wildlife management licences are, by design, public interest licences, since conservation, biodiversity, carbon capture and damage reduction form part of the greater work towards Scotland becoming a Net Zero nation, assisting the Scottish Government in achieving its own targets.

7. What information would you want to be included in a public register of licences?

We have seen already that individuals have been inadvertently identified by NatureScot because of some of the information in the response(s) that have been issued to requests. It was one of the main causes of someone resigning from their role following pressure from those who wish to see all wildlife management stopped completely. There should not be a public register for licences, and we fail to see the benefit of creating one. If a register were created, then any available information should be general enough in nature that an area of land or an individual cannot be identified. It can be a very simple process to identify an individual from information that is too specific relating to areas that have been granted licences. The very suggestion of a public register of licences will disincentivise deer managers from participating, thus hampering the Scottish Government’s achievement of its targets.

8. How would you use a public register of licences?

We are aware that a public register for wildlife management licences is likely to be created and so would ask for caution when designing. An area could be described by the county it is in, or at the most detailed, by using "in the South of Perthshire", for example. Any more specific and it will be far easier to deduce where and whom the licence refers to. Licence holders must be protected while they conduct lawful and necessary practices.

9. Would you want the register to be able to be interrogated (filtered/specific searches)?

Absolutely not. As far as we can understand, the only reason this function may be utilised would be to find specific detail to use against a licence holder who is carrying out lawful control. This information should only be available to licensing staff and the issuing authority.