A statement has appeared on the website of the National Association of Regional Games Councils headed “Hunter Competence Assessment Programme (HCAP)”. That statement is at best misleading and at worse just plain dishonest.
The statement addresses the requirement for mandatory certification as a prerequisite for issue of a Deer Hunting Licence (DHL), which follows a recommendation from the Irish Deer Management Forum (“the Forum”). In March 2016, after exhaustive debate, the Forum unanimously adopted the following recommendation for submission to the appointing Ministers: “That the IDMF recommend to the Minister for Arts, Heritage and the Gaeltacht and the Minister for Agriculture, Food & the Marine that Certification of Competency from an accredited source in knowledge of wild deer species, disease recognition, management, culling and safe methods of control, together with marksmanship and safe usage and storage of firearms, be a mandatory requirement before the grant of a licence to hunt wild deer; and that mandatory certification be introduced on a phased basis over a five year period commencing on the 1st day of January 2018 for existing holders of deer hunting licences, and with immediate effect from the same date for all new applicants for deer hunting licences”.
This recommendation was duly submitted to the Ministers concerned and confirmation of adoption of the recommendation was subsequently received by the Forum.
The NARGC statement asserts that “there was no consultation that we the NARGC were aware of and have this requirement forced upon us”. The NARGC have had a seat at the Forum table from Day One and were fully involved in all deliberations of the Forum, including representation on the Communications, Training & Best Practice Working Group which was responsible for framing the Recommendation. Training and certification for deer hunters was adopted as a priority objective for the Forum from date of appointment of the Forum and was dealt with in detail in numerous submissions made in the process of public consultation over a two-year period. It is at best disingenuous to suggest that the NARCG were not party to consultations, which were exhaustive.
In fact, as can be seen from the Recommendation, certification is not limited to Deer Alliance HCAP. So far as Deer Alliance HCAP is concerned, “HCAP or equivalent” has always been and continues to be, the criterion for certification. By no means does mandatory certification place Deer Alliance (HCAP) “at the centre of what is a commercial venture, with no viable alternatives open […]”. Deer Alliance HCAP is a not-for-profit body, operating on a break-even basis and with full disclosure of all finances. It is open to any third party to put forward a programme for training, assessment and certification, with HCAP as a valid benchmark for measurement of equivalency. HCAP has processed some 2400 candidates since 2005, when certification became a mandatory requirement for hunters wishing to hunt deer on Coillte forest property. HCAP des not consist of merely of “answering 30 multi choice questions and attending a range test”. Candidates must answer a minimum of forty questions correctly, and then passing a rigorous test of firearms handling and marksmanship. Both stages are demanding of ability and generally, only those candidates who engage in optional Training Workshops and careful study of the Deer Alliance Stalker Training Manual, and then show up for the Range Test with firearms correctly zeroed, safe to use and being capable of putting the requisite number of rounds onto the target on their first attempt, achieve maximum results.
It may be the case that internal dissension and seismic change interfered with the NARGC’s involvement with the different processes and debates engaged in by the Forum in recent months. That is no excuse for misleading their membership as to consultation, or for denigrating a process of assessment and certification recognised as fit for purpose by Coillte Teoranta and National Parks & Wildlife Service; or for disrespecting the voluntary work of all those engaged in Deer Alliance HCAP, including the different deer organisations such as the Irish Deer Society and the Wild Deer Association of Ireland, which have done far more for deer and for deer hunters than any other shooting organisation over the last forty years.