The  Consultation Document and associated scientific documents relating to the review are available here:

www.npws.ie/legislationandconventions/irishlaw/openseasonsorder

The National Parks and Wildlife service invites submissions from interested members of the public and organisations. Submissions should be sent by email to npwsdeerconsultation@ahg.gov.ie  or by post to:

Thank you.

2.2: Countryside Alliance Ireland[2] (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.

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.

·         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.

·         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. 

·         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.

·         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.

·         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 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.

·         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.

·         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. 

·         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 would like to be given examples where issues have been identified and what policy support measures are envisaged to reconcile possible conflict areas.

·         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.

·         CAI is again pleased to read that the deer management policy group appreciate and understand the key benefits of recreational deer hunting.

·         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.

·         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.

·         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.

·         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.

·         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.

·         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.

·         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.

·         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.

·         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.

·         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. 

·         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 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.

·         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.

·         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’.

·         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.

·         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”.

·         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.

·         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 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

·         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.  

·         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 would like relevant stakeholders to be represented for the interest of all parties.    

·         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.

·         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.

·         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?

·         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 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.

·         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 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.

·         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.

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Submissions  invited  by email to: dmpolicyvision@agriculture.gov.ie, or by post to: Deer Management Policy Vision, Forest Service, Department of Agriculture, Food and the Marine, Johnstown Castle Estate, Co. Wexford.

.22 Hornet, .222 Rem., .220 Swift, 6mm Rem., 6.5×55, 7×57, .284 Win. and .300 Savage.

Group 3

.30-30, .308 Win., .30-06, .300 WSM, .300 Win. Magnum and .300 Ultra Mag.

7mm-08 Rem., .280 Rem., 7mm WSM, 7mm Rem. Magnum and 7mm Rem. Ultra Mag. 

Winchester Short Magnums: .270, 7mm, .300 and the .325.

Arising from a recent Deer Alliance HCAP Range Test, the question arises, is the .220 Swift a suitable round for use on our Irish deer species?

The current minimum legal calibre for use on deer in Ireland is not defined by calibre but rather by bullet weight and muzzle energy. The minimum legal bullet weight is 55 grains and the minimum legal muzzle energy is 1700 foot-pounds, as provided for under Statutory Instrument No. 239 of 1977. Effectively, this is taken to mean the .22/250 which in the period 1972-1993 was probably the most widely used centre-fire round, although for many hunters, the preferred round was the 5.6 x 57 m.m.  with 74 grain bullet (typically with 1915 ft-pds ME).

However it should be noted that at the time of publication of SI 239/1977, it was established that many manufacturers of .22/250 ammunition were producing ammunition delivering less than 1700 ft-pds of ME, the average being 1637 ft-pds ME. This remains the case and in fact, most if not all .22/250 ammunition currently available in Ireland at retail level fails to meet the legal minimum requirement – which in turn means that unless applicants for a Deer Hunting Licence specifying use of the .22.250 can prove that their brand of ammunition delivers 1700 ft-pds ME, then the NPWS Wildlife Licensing Unit are entitled to reject the application for the DHL, as to grant it would lead to a breach of the Wildlife Act 1976 (as amended) and/or SI 239/1977.

Meanwhile, from 1993, larger-calibre firearms became available and accepted by the licensing authority (Garda Siochana). This came about as a result of certain legal actions in the form of judicial review in the High Court against refusal of firearms certificates for calibres above .22 inch. Thus the keener deer hunters switched over to calibres such as the .243, .270, 6.5 x 55 m.m. and .308, while newcomers to deer hunting automatically went for the larger calibres.

 Nevertheless, there remains a hardened corps of hunters who still use the .22/250 and in a few cases, the 5.6 x 57 m.m. This is despite the fact that unanimously, the various deer organisations, and especially Deer Alliance HCAP, are committed to the promotion and use of .240 inch, 100-grain bullet with muzzle energy of 2100 foot-pounds as the recommended minimum legal calibre for our Irish deer species.

 For purposes of the Range Test element of HCAP, candidates must use the legal minimum calibre (not necessarily the minimum recommended legal, which is a different calibre). For a small handful of candidates, this has meant the .22/250. More recently, one candidate presented with a rifle in calibre .220 Swift, with 60 grain bullet. While the standard .220 Swift with 40- or 50-grain bullet  does not meet the minimum legal calibre requirement, the same calibre with 60 grain bullet does, since in Winchester 60 grain, it delivers 1772 foot-pounds (2403 Joules) of energy at muzzle.

Thus Deer Alliance HCAP are satisfied that the .220 Swift with 60-grain bullet may be used for purposes of the HCAP Range Test, while strongly advocating that the minimum legal calibre should be .240 inches, with 100-grain bullet and muzzle energy of 2100 foot-pounds, for all purposes relating to the humane and effective management of wild deer. HCAP Range Test Candidates wishing to use the .22/250 with 55 grain bullet must prove that their chosen ammunition also meets the legal minimum requirement of 1700 ft-pds ME.