Minister of State for Heritage and Electoral Reform,
Malcolm Noonan TD (Minister with Responsibility for NPWS)
The recent (and ongoing) debacle affecting issue of Deer Hunting Licences (DHLs) for the Season 2020-2021 highlights inherent defects in the system of dealing with applications from qualified applicants.
The current system requires that qualified hunters apply annually for the DHL, valid from date of issue to the following 31st July. The DHL is issued subject to the provisions of sections 9, 25 29 and 33 of the Wildlife Act 1976 (as amended), section 29 being the principle operative section.
The applicant is required to provide evidence of entitlement to hunt deer over a minimum of100 acres of land on which the owner or occupier holds sporting rights. The landowner permission is normally subject to verification by a NPWS Field Officer (Conservation Ranger), a time-consuming exercise if conducted properly. The applicant must give details of the firearm to be used (maker’s name, calibre, bullet weight and identifying number), which need not be licensed to the applicant. The applicant must be aged 16 years or over, full details of name, address and contact details must be provided, and the applicant’s signature must be independently witnessed. There is no fee for the DHL, although provision is made in the Act for possible introduction of a fee.
From 2021, all first-time applicants for the DHL will be required to be HCAP-Certified or equivalent, in accordance with the syllabus for mandatory certification published by NPWS on 13th March 2020. It is also expected that in time, all existing holders of the DHL will be required to be compliant with certification requirements, allowing up to five years for this to be achieved, and with no “grandfather clause”.
In recent years, applicants have been advised to submit their applications “well before 30th June” to be sure of getting the DHL by or before the start of the hunting season on 1st September. This was the case in 2020, regardless of the impact of Covid 19 restrictions and the requirement to submit landowner permissions was dispensed with (presumably for the current season only).
This system has applied from commencement of the Act in 1977 when the number of licensed deer hunters was less than 400 and has continued for the last four decades, when the number of licensed hunters has grown to a number in excess of 6000.
Even without the fiasco surrounding issue of DHLs in 2020, it is well past time for review and reform of the licensing system.
The following reforms are now put forward for adoption with effect from March 2021:
1: The duration of the DHL to be changed from an annual licence to a licence for a three-year duration. This would cut down enormously on the workload associated with assessment and issue of the DHL and would bring the DHL in line with the duration of Firearms Certificates, which are for three-years’ duration from date of issue.
2: All applications should be made online. Citizens can apply for a driving licence online, conduct their banking online, make their annual tax return online, apply for their GovID account online, apply for a supplementary passport online, and apply for a Personal Services Card online. It should be well within the competence of the NPWS to introduce an online system.
3: Landowner permissions should be dispensed with and replaced by evidence of competence to HCAP standard. Landowner permissions have been dispensed with for the current 2020-2021 Season, so the precedent has been established. By way of comparison – when a citizen obtains a driving licence, having undertaken the appropriate training and passing both the theory and practical tests, he or she is not limited to driving on highways but not on secondary roads. A person is either trained and competent (and certified as such) or is not. In the same way, the trained, competent and certified hunter should not need to prove access to 100 acres (out of 17.36 million acres). It is an irrelevancy where the hunter is deemed safe to use a deer-legal firearm (and is in any event assessed as such by the Garda Siochana) and competent in his or her knowledge of deer management practices. It is not suggested that landowner permission is not required for hunters entering private land, such permission remains an absolute necessity, but the necessity for the hunter to renew permissions every year, and each permission having to be validated by NPWS, would be eliminated.
4: It follows that in addition to the requirement for first-time DHL applicants to be certified to HCAP standard from 2021, all others should be certified to the same standard, subject only to an acceptable time-frame for implementation (up to five years as recommended by the Irish Deer Management Forum),
5: A fee of up to €80.00 should be applied to each application for a three-year DHL, in line with the fee of €80.00 applied to the three-year Firearms Certificate. The revenue from the three-year DHL (projected at up to €480000.00 or an annualised €160000) would more than cover the cost of a switch to an online system. The cost saving in dispensing with verification of landowner permissions and physical issue of DHLs (to be downloaded by the applicant after online application and grant) can also be factored in. Ideally, licence fees should be ring-fenced and used for further research into relevant issues surrounding deer.
6: The foregoing reforms should take effect in 2021, requiring early adoption by all relevant decision-makers and implementation by NPWS Wildlife Licensing Unit.
The foregoing proposals for reform are put forward by Liam M. Nolan, Secretary of Deer Alliance HCAP, writing in his personal capacity and will be delivered now to the relevant decision-makers at Government and Department level, with or without agreed amendments.