In the light of sometimes conflicting advice and contradictory statements circulating around the “five kilometres” rule and hunters’ right to travel in connection with deer control activities, Deer Alliance HCAP has today communicated with Minister Charlie McConalogue TD, Minister for Agriculture, also with Ministers Pippa Hackett TD and Malcolm Noonan TD. Our email communication is set out below.

We have also invited the Irish Farmers’ Association to support the proposal to designate deer control for stated purposes as an essential service to agriculture and forestry

TO: Minister Charlie McConalogue TD, Minister for Agriculture.

Dear Minister,

The purpose of this letter is to briefly make the case for designation of deer control as an essential service in the context of current Covid 19 regulations.

The control of wild deer is accepted as a priority objective by most stakeholders in the agriculture and forestry sectors. Wild deer, if not properly controlled and managed by competent, trained and certified hunters, offer the potential for serious damage and loss to agriculture and forestry. Coillte’s deer management strategy across their entire forest estate is predicated on containment of damage from excess numbers of wild deer. The question of possible inter-species cross-infection of disease is also a concern for farmers as well as for groups concerned with deer welfare.

Deer control for purposes of crop protection is not to be confused with recreational deer hunting but instead should be seen as an essential support service for agriculture and forestry provided it is carried out by licensed, trained, certified and competent persons working towards a coherent management plan for local populations of deer.

Deer control is not currently identified as an essential support service and consequently, licensed persons are curtailed in their activities by the current “five kilometres” rule. An unwelcome increase in populations can be predicted if culling is not carried out in-season and with the female hunting opening on 1st November, it is critically important that travel restrictions be eased. This can be achieved by designating deer control for stated purposes as an essential service to agriculture and forestry.

Deer Alliance HCAP now calls for the immediate designation of deer control for stated purposes as an essential support service for agriculture and forestry.

The safe, humane and efficient management of wild deer by trained, competent and certified persons, leading to a working balance between sometimes conflicting stakeholder interests while ensuring the welfare of wild deer, remains a priority objective for Deer Alliance HCAP.

Yours sincerely,

DEER ALLIANCE HCAP

30th October 2020.

There appears to be confusion as to whether deer hunting under licence is permitted under current Covid 19 travel restrictions. One deer organisation has issued an advisory notice to its members to the effect that National Parks & Wildlife Service have determined that deer hunting is not an “essential service” as defined under government directions around travel restrictions.

Well intentioned as this advice is, it is not an accurate interpretation of advice issued by NPWS.

The NPWS advisory notice can be viewed here.

The question is, whether deer control is an essential service. NPWS make no statement as to whether deer control under licence is an essential service. They advise that “Licences issued by the National Parks and Wildlife Service do not in any way confer exemptions in respect of compliance with public health guidelines”.

This is not the same as a determination that deer control under licence is not an essential service.

At time and date of this posting, Coillte Teoranta have not issued any statement concerning hunting on Coillte forest property. Coillte’s deer management strategy is predicated on the perceived need to prevent damage to forestry – prevention of damage to crops, in other words. Forestry, which must include prevention of crop damage, is an essential service conferring an exemption in respect of travel restrictions, under the list of essential services published by the Office of the Taoiseach on 14th October 2020 and updated on 21st October 2020, whether under Section 1 or Section 13 of that List.

The List of Essential Services can be viewed here.

Regardless of forestry interests, and pending any statement from farming’s different representative bodies, the agricultural community will no doubt continue to regard deer control under licence as an essential service.

Suspension of hunting on Coillte forest property could potentially lead to claims for rebate or return of substantial licence fees paid by licensees.

All persons are of course urged to fully observe guidelines for prevention of spread of infection by Covid 19, including wearing of barrier masks and social distancing. The National Association of Regional Game Councils has issued a statement on Shooting and Hunting under Covid 19 Regulations which is available to NARGC Members on the NARGC website (members only, as it is a closed site requiring member login). It offers no guidance on the issue of deer control as an essential service but is otherwise excellent and relevant advice.

BOTTOM LINE: based on subsequent discussions with key NPWS personnel at management level, Recreational Deer Hunting is NOT deemed to be an essential service covered by exemptions to the five kilometre travel restriction. Deer Control for stated purposes of protection of forestry and agricultural crops IS deemed to be an essential service and thus exempt.

Unfortunately, against the background of Covid 19 travel and group gathering restrictions, it is not possible to fix HCAP dates at this time.

A schedule of dates will be posted here as soon as circumstances permit.

Any and all candidates listed to participate will be notified at that time.

Liam Nolan discusses sika deer in Ireland in conversation with Éanna Ní Lámhna on Mooney Goes Wild, RTE Radio 1, Monday 12th October 2020

To listen click here.

(Interview commences approximately 14 minutes into the podcast)

On behalf of Deer Alliance HCAP-Certified hunters who are Coillte licensees and permit holders and who have asked for advice in relation to Level 3 Covid 19 travel restrictions now in place and affecting county-to-county travel, Deer Alliance HCAP has proposed to Coillte Teoranta that they issue a letter to each licensee and permit holder confirming their status as providers of an essential service within the meaning of the list of exempt providers published by the Office of the Taoiseach in March 2020.

The text of the proposal sent to Coillte is set out below. A response is awaited.

EMAIL TO COILLTE TEORANTA INCLUDING BUSINESS AREA UNIT ADMINISTRATORS, SENT 9th OCTOBER 2020

Dear (Coillte named BAU Administrator/Forest Manager)

As you can imagine, current Level 3 Covid 19 travel restrictions are impacting negatively on some Coillte deer licensees and permit holders, unwilling or unable to visit their forest areas without possible breach of the current travel regulations.

On behalf of those HCAP-Certified licensees and permit holders who have asked for advice on this matter, Deer Alliance HCAP wish to propose to Coillte nationally and locally that they issue a letter to each licence and permit holder confirming that deer management and deer culling on Coillte forest property by authorised persons is a valid exempt essential service as an essential aid in the protection of forestry and other crops, including both Coillte forestry and surrounding farmland. Persons involved directly or indirectly in crop production and related activities are deemed providers of essential services under the terms of the list of essential service providers under public health guidelines published by the Office of the Taoiseach in march 2020.

Such a letter could then be exhibited by licensed hunters travelling beyond permitted boundaries (county to county) if challenged.

Otherwise licensees and permit holders will be severely curtailed in the exercise of their licences and in the achievement of designated culls.

Email confirmation to each licensee or permit holder would suffice.

We trust you will give this proposal early consideration and implementation.

Yours sincerely,

DEER ALLIANCE HCAP.